Trailer Hitch Part of Bumper?

[FRC1511]

Is the Trailer Hitch considered part of the 2/3 Bumper Perimeter that must be covered by Bumpers? Or is it considered uncovered?

Specifically if there is a 28"x38" robot, it has a perimeter of 132", thus 44" of the robot can be uncovered (provided it meets all other rules in R08). Does the Trailer Hitch count as part of the 88" of covered bumper perimeter, or the 44" of uncovered bumper perimeter?

[GDC]

The Trailer Hitch is not a BUMPER. It is included in the portion of the BUMPER PERIMETER that is not protected by BUMPERS.