This is the kind of thing that should be caught in plan review. I might joke a bit about how they have found a loophole where they don't need any counter receptacles per 210.52(C)(1) <somewhere> but I want to be there when you explain that to the customer. We would come to an accommodation of some sort that would at least meet the spirit of 210.52. Maybe receptacles in fillers between the face frames or something. That is what kitchen designers are for.
