I think that's the problem right there - you're assuming they are bubbles. While I am fairly certain they are solid particles that were on the zinc blank before it was even plated. But in either case, solids or bubbles, it would still be a defective planchet. And since the qualifier for a defective planchet to be a no grade is severity - that coin most definitely qualifies since the entire coin is affected.
I bet you the submission cost it straight grades. Lol. Whats a modern NGC or PCGS submission cost? Not shipping and processing, just the grading.
Given their lax standards in today's world, it really wouldn't surprise me if it did ! But if you had submitted that coin 15 years ago, I'd have bet you a whole lot more than grading fees that you'd get the coin back in a body bag
The 1984 Lincoln DDO may have changed the way PCGS looked at this. Many of these had this same planchet problem. They had to grade them. If they didn't someone else would. This was an important coin for Lincoln collectors.