I certainly include it. If I truly had an emergency, I have many other sources of funds to tap before I'd need to try to get at that last $10k. I also don't discount other I bonds on their 3 month penalties for the first five years. Didn't discount the early withdrawal penalties from CDs I've owned, or retirement funds I can't access without penalty either.
Yes, in a true emergency that required $100k or more, I might end up having to pay a penalty here or there, but that doesn't materially affect my planning for FIRE.