"What if we simply treat time as frequency and have it emerge from action? Then we can have a universal present, but different clock rates."
No, John, we couldn't. You assume that there is a universally valid time in which all observers agree. Your present, e.g., differs from the present of a hypothetical observer in the Zeta Reticuli region. The frequencies at which events pass here and there can be locally measured at the same clock rate, while distantly, the rates have to differ.
Your view is Newtonian, in which "time flows equably" over the universe. It was replaced by relativity in which "all physics is local." Albrecht's discovery (with which I agree) is that the cosmological condition (i.e., the past condition assumed to determine the present) is sensitively dependent on one's local choice of the Hamiltonian (the system's energy content). The idea of random Hamiltonians corresponds perfectly to Everett's branching worlds, and it agrees with what we know about both relativity and quantum mechanics, so long as we allow a noncollapsing wave function.
Tom