Most likely the case. The pads of the missing PAL connect to these pins.
Chip #5 D1
Other chip's D1
A14, A20, A16, A21, A0, A1
CLK
VCC
BANK03's pin 19
/OE (as per the datasheet, I didn't trace where it leads to)
GND
I don't have a ROM dumper, got a good and cheap one you can recommend? I...