In the past few days I have carried out some shunting runs on various routes at speeds well above the limits. The services can be done nonetheless, but when I saw the difference in the distance travelled between the after action report and the accumulated distance for these locos, it is now quite clear that the distance travelled is only counted for the locomotive if it has been driven below the speed limit! It seems, the counting is somehow related with the AP you gain when you're driving below the limit, and so it's not done when you don't get APs. That's really crazy!
So why exactly do you think this is a bug? I guess that is exactly how they wanted the distance to count. Otherwise all the 'drive xxx miles' - trophies would be even easier to achieve... ;-)
On all the routes I know there's definitely no trophy of this kind easy to achieve, they all take an really excessive amount of time doing the same thing over and over again, but that's not the point. The point is, the numbers we're talking about are called "Miles Driven" and not "Miles Driven Under The Speed Limit". When I'm driving too fast I don't get the maximum AP for that service, and that's ok for me. It affects the time to get my route level up. But I did drive the necessary amount of miles without derailing. I don't see any reason not to count these miles.