I have P45 fenders over 700 x 38 Bontrager CX0 tires on my cross/gravel
bike. They have between 5 and 10 mm of clearance above the light knobs.
Less than optimal, but still ok.
Yes, the fenders plug up with mud more quickly than the stays would plug up
without the fenders. But, they only plug up
I found it to be a noise, annoying idea, but if there is sufficient
clearance you should be fine safety wise. Yes, it will collect snow, mud,
slush much faster than riding fender and fancy free (largely because said
snow, mud, and slush is free to splash and spray you and your bike instead
of g