NOTE: This answer relates to a rule proposed by REC and does not reflect current regulations in effect:
No. The Commission's post-Auction 83 computer program included "water files" which identified the 1-minute points within the grid that were either over major bodies of water or located in foreign territory. While the Commission's and REC's computer programs did take these "water points" into account, there may be times when a channel point will appear over the ocean, in a major body of water or in foreign territory. A channel point located entirely over a small lake or in the middle of a river may need to consider the immediately adjacent land area (including islands) that are close to the 1-minute channel point location. REC has no issue with not protecting channel points that are in lakes or other inland waters where the nearest land area is more than 2 minutes in all directions.