That's an easy no, precisely because
> have at least 20 keys on my desktop keyboard that I never use
Very common operations should be ergonomic, i.e. have a convenient location. Unless you mean to make all keyboards split ergonomic with a thumb cluster, so you'd have prime space for copy and paste, adding bad 21st and 22nd key far away will be worse than a more convenient modifier
Also, you forgot laptops where there is not enough real estate to even fit the full standard desktop keyboard
(multiple clipboards would be a great benefit, though)