I know, and I do agree it's consistent, but then it doesn't make any sense to me as a keyword in a language where non-primitives are always by-reference.
You can't mutate the reference, but you _can_ copy the values from one array into the data under an immutable reference, so const doesn't prevent basically any of the things you'd want to prevent.
The distinction makes way more sense to me in languages that let you pass by value. Passing a const array says don't change the data, passing a const reference says change the data but keep the reference the same.