I don't see many maps that include them in the visuals of border so I'm not sure of the status of that and if the feds are arguing it would count and I think they would if there was an indication they were. I do remember that that was part of the discussion when the policy/rule first got a lot of attention a few years ago but it's not showing up in the visuals now. Maybe there was a clarification or restriction added either by courts or by the executive?
See the map here: https://www.southernborder.org/100_mile_border_enforcement_z...