Dear Amanda,
I really enjoyed your essay. It is one of the most thorough and clearly focused contributions on the subject of covariance (i.e. observer dependence/independence) in the contest. I share your deep interest in this important subject. A few itemized remarks:
1. One of the most important points, in my opinion, is the absolutely crucial role of spacetime structure in constraining "particle states." As you point out, such states arise in Minkowski spacetime via the representation theory of the Poincare group, and altering (or removing) this background changes the picture completely. Many approaches to quantum gravity involve very complicated spacetime microstructure, and this makes the use of covariance in the form of spacetime symmetry to determine particle states problematic even locally. There is another possible interpretation of covariance, however, and this interpretation is much more general than group symmetry. It is based on order theory, and is related to the relativity of simultaneity. In this interpretation, different frames of reference are, in general, no longer related by a group action, but by different refinements of the causal order. I describe this in more detail in my essay here: On the Foundational Assumptions of Modern Physics.
2. You discuss several different types of horizons (black holes versus cosmological horizons, etc.) I'm probably preaching to the choir here, but there is some disagreement about the equivalence of different types of horizons and the implications for observer independence. There is an essay by Tanmay Vachaspati in this thread called "Preferred observers in quantum gravity" that discusses this and may interest you... along with yours, it was one of the more interesting submissions on covariance.
3. You mention Rovelli's relationism; if you look at my essay you'll see that I have a lot of sympathy for this point of view. You might be interested in some of the submissions here on that topic; for instance Jorge Pullin's essay on the measurement problem.
I particularly appreciate your broad point of view and synthesis of several different problems that are usually considered separately. Take care,
Ben Dribus