This really depends on how you define automation. CI on GitHub depends on webhooks which is an officially supported part of the API. So there isn't anything unsolicited happening.
I just don't think there's any meaningful claim that CI explicitly configured by maintainers using officially supported channels should be lumped in the same category as automated scraping of repositories for creating PRs.
Sure, there are many definitions of automation that would include both of these things, but I think it's obvious what GitHub intends in practice.
If it's defined in the UI, it doesn't make it unsolicited. I can go to any repository for someone I've never heard of and make a PR as a human. That is still unsolicited. I think the concern is the combination of unsolicited and automated.
I just don't think there's any meaningful claim that CI explicitly configured by maintainers using officially supported channels should be lumped in the same category as automated scraping of repositories for creating PRs.
Sure, there are many definitions of automation that would include both of these things, but I think it's obvious what GitHub intends in practice.