Because the NEC does not address open areas below the countertop. Only above the top.
What about wall areas under a ceiling? Under cabinets? Under sinks? Under shelves? Under coathangers? Under curtain rods?
IMHO if they believed that outlets were needed below a countertop they would have addressed that subject.
O is the operative letter here.... opinion. I'm simply asking where you get your opinion's foundation?
			
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