It use to be when placing shore batteries, you just needed to level the quad the battery was in and the Check Objects function would not report them as being on non-level terrain.
Now you need to level the entire 1sq mile to avoid the non-level terrain error.
Edit: To be more specific, if the SB is defined as a Hard Gun Battery it shows as non-level terrain. If it is defined as a Gun Bat there is no error.