It is a chance substitution in the sense that it's a substitution based on a chance-based effect. However, I believe chance substitutions currently cannot be used to change the action that the chance-based effect happens on. For example, "If you lose the speed tie on a1, use Bounce on a2" is ok, whereas "If you lose the speed tie on a1, use Bounce on a1" is not.
Whether it should actually be like that or not is another matter entirely.
Whether it should actually be like that or not is another matter entirely.




