I'd say no, and I have a hard time accepting the "too drunk to give consent" bit - since this is apparantly the only thing you cannot be held responsible for doing while drunk.
The "if one party is less drunk than the other, yes" argument also has it's flaws: What are the degrees of drunkenness? If person A has trouble standing and vomits, and person B cannot form a coherent sentence but can walk fairly well and isn't vomiting, would the still-smashed-but-not-quite-as-smashed person B be guilty of rape if they had sex and person A later did not want to?
How about if they're both at a party, but not there together and don't really hang out much for most of the party, drinking on their own. Person A, again, gets hammered by his/her own free will, without any particular encouragement, no drugs etc. Person B is also drinking, but not as much as A. Later on, A initiates contact. B is fairly drunk (enough to get less concerned about taking advantage of people), while A is very drunk and very randy. Would B be guilty here - not nearly as drunk as A, but without planning to get A drunk or use A's drunkenness as a means of having sex, but not saying no when A started putting the moves on?
I have a friend who tends to get very aggressive in her advances (I've seen her walk up to guys, grab their crotch and lick their face several times) once she gets drunk, and she usually gets drunk very early during a party, more often than not passing out before 11. Could she really make the case that she was raped if a guy takes her up on her advances?
There are of course real rapes that happen in similar situations, but since it's usually word against word between two people who at least claim to have been drunk, it's a tricky situation and I don't envy the people who have to decide whether it was rape or not.