Not really. Consider:
It's not hard to pull off conviction +5, a specialty of +2 (necromancy power), and perhaps two focus items for +4 control, +4 power, that when added to your 2 levels of lawbreaker (necro), nets you a +11/+11 before the kemmler bonus itself. The rest you can do with a little stress and maybe a fate point or two.
Thaumaturgy (-3) with specialty necro power
kemmlerian necromancy (i forget the cost)
-1 refinement, +1 necro power, +1 necro control
free focus items and -1 refinemet = +4 control Focus item
-2 refinement, 4 focus items for the +4 power
-2 refinement, lawbreaker (5th)
at a refresh of -9+ kemmlerian necromancy (so 11-13ish)?
Yeah outside of the starting submerged character, but not impossible for a baddie. A player could swing maybe a +9/+9 easy, at creation, with the proper stats.
So that's, two rounds to get a zombie out (for 2 different spells)? sweet.