That limitation is a Windows thing. AFAIK all PAE-enabled 32-bit Linux operating systems can use up to 64GiB of RAM.
That's correct, for the most part, it's a Windows deal. Though there are some workarounds to that, to the best of my knowledge, they're licensed apps (such as RAMDisk by Raxco). $79 (the app's licensing fee) would purchase that same user a true 64 bit OS on promo. Though I'm sure there are exceptions, I've never seen more than 4GB RAM in a mass produced 32 bit computer of any type, most all of these were for home/small business use.
However, PAE doesn't totally make up for having a true 64 bit OS, and since the images are at no cost, why not install a 64 bit OS onto a 64 bit computer, even one with only 4GB RAM installed? One reason is that only the 64 bit OS unlocks all of the features of the CPU, such as being able to load a whole lot more into virtual memory than a 32 bit OS could possibly muster.
The other has to do with the Linux 32 bit OS only being able to use RAM in 4GB clusters. Note that when referring to RAM, I use GB, rather than GiB, because there's no catch involved in the capacity, we get what we purchase. It's not measured in the way storage is, fortunately. Now, about those 4GB clusters, and I've seen this issue come up more than once, maybe a half dozen times.
If say one wanted to create a virtual machine, and assigns it 8GB RAM, there's going to be problems. That's twice the allocated cluster limit to the one app, not to mention the software to fire it up. With today's ever demanding software taxing both RAM & CPU resources, plus Linux support for 64 bit computers are as great as ever, there's no need to messing around with a 32 bit OS if the computer is 64 bit capable. The only exception to that rule that I can see, if there's other legacy hardware to be attached to the computer that only has 32 (or 16) bit support/drivers, in which case is likely dated anyway, and budget restraints are preventing upgrades. This would be likely more of a business than a home issue, there's wireless printers beginning at $29 (in USD). Nicer or 'workstation' units for $100 or so. I can't blame a small business whom paid $3,000 for a top of the line printer 8-10 years ago to hang on a little longer, as long as it doesn't need costly repairs. In which case, these can be replaced with one for a fourth of the price of the old & will pay for themselves with lower ink & maintenance costs, as well as being in compliance of today's needs.
At least in the US, to the best of my knowledge, the last 32 bit computers that were distributed widely were netbooks, this was during the early Windows 7 years & many had a 2GB RAM restriction, because the installed OS was Starter. Even most popular smartphones now are or about to become 64 bit only.
I'm not saying that the PAE concept is totally useless, however Linux has advanced beyond the days of being able to run most any distro on any device, and this is good. There are a few exceptions, such as Puppy, that will, it's just that mainstream versions will no longer run on a 10+ year old PC picked up from the curbside w/out some hardware upgrades. This is part of the notion that holds LInux back, is what it's long been known for, reviving computers from the dead. For Linux to have a good chance at becoming mainstream, it must become better known for living in tune with the times.
Which is why 64 bit LInux is as popular as ever & growing, across the board. Mainstream Linux distros are living & thriving in 2015. 
Cat