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I agree. By rule if a player were to tackle the holder while in possession of the ball it is roughing the holder but I don't think anyone would want to see that call made nor should it be made. To just tackle a player in possession of a live ball should never be a foul.
You said it could be changed by changing the definition of a holder but also the roughing rule could be changed so that roughing the holder is only possible after the ball is kicked.
Or we start to get into the issue of when does this player become a holder and when does he stop. He becomes one when he controls the ball on the ground or tee but it never specifies when he stops being a holder. By definition he is not a holder anymore when the ball is kicked as he is not now controlling the ball. However this is when all of the roughing the holder fouls are committed.
After a kick is blocked when do we say that contact against the holder is no longer roughing and just an attempt to gain possession of the ball? I would say that it has some to do with R's actions as well as some to do with the holders actions. So at some point the holder must lose his protection just as the kicker and passer.
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