According to your docs -> https://github.com/fastly/fastly-magento2/blob/master/Documentation/Guides/RATE-LIMITING.md
According to your docs -> https://github.com/fastly/fastly-magento2/blob/master/Documentation/Guides/RATE-LIMITING.md

Following users are exempt from blocking:

IPs defined in var/.maintenance.ip (See Maintenance Mode guide for more details)

var/.maintenance.ip updates acl maint_allowlist but this acl is never used to exempt the ips from getting blocked.

As a result rate limit will return 429 also for ips that are on the maintenance list.

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