From a hexread, yes, the Simon CD32 executable requires cd.device.
There's also an official Commodore cd.device wrapper in the CD32 devkit (part of the Amiga Developer CDs). Using it, I was able to get Simon to start on an emulated 4000/uaescsi.device. It's unstable and the voices are garbled but I'm unable to do full testing (i.e., booting with no startup-sequence to start from raw shell) because I'm away from an external mouse and this stupid Mac trackpad doesn't let you press LMB and RMB simultaneously. WolnyCD didn't work for the emulated CD drive so I couldn't slow it down.
So I'm sure it can be made to work, but some more trickery is needed.
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