Jeff, not in all instances. But do you think that the "water" John speaks of in the following verse is referring to the Spirit?:
"This is he that came by water and blood, even Jesus Christ; not by water only, but by water and blood. And it is the Spirit that beareth witness, because the Spirit is truth" (1 Jn.5:6).
Let us look at the following verse which is also speaking of the new birth of John 3:5:
"he saved us, not because of righteous things we had done, but because of his mercy. He saved us through the washing (loutron) of rebirth and renewal by the Holy Spirit" (Titus 3:5; NIV).
In regard to the Greek word
loutron Sir Robert Anderson writes that
"the LXX uses it twice; namely in Cant. iv.2 (where it is the washing place for sheep); and in Ecclesiasticus xxxiv. 25 where the Son of Sairach writes: 'He that washeth himself after the touching of a dead body, if he touch it again what avails his loutron?'"
Anderson continues, writing that
"This last passage is of the very highest importance here, and gives us the clew we are in search of. The reference is to one of the principal ordinances of the Mosaic ritual--a type, moreover, which fills a large place in New Testament doctrine--especially in Hebrews--namely the great sin-offering with the 'water of purification' (Num. xix.)."
At Ecclesiasticus 34:25 the reference to " touching a corpse" and "water" is in regard to the sin-offering of the red heifer spoken of here:
"'The one who touches the corpse of any person shall be unclean for seven days.That one shall purify himself from uncleanness with the water on the third day and on the seventh day, and then he will be clean...." (Num.19:11-12).
A red heifer, which was a sin-offering, was slaughtered by a priest and the ashes were gathered up and placed in a clean place. This sin-offering is a type of the Lord Jesus's death and Alda R. Habershon writes that
"The ashes speak of the finished work; for they show that the sacrifice has been accepted."
Then water was poured over the ashes and as a result the water served as a purification from sin:
"'Now a man who is clean shall gather up the ashes of the heifer and deposit them outside the camp in a clean place, and the congregation of the sons of Israel shall keep it as water to remove impurity; it is purification from sin" (Num.19:9).
We can also see the Greek word
loutron used here:
"Husbands, love your wives, just as Christ also loved the church and gave Himself up for her, so that He might sanctify her, having cleansed her by the washing (loutron) of water with the word," (Eph.5:25-26).
At Ephesians 5:25-26 Paul is using the words "the washing of water" in a typical sense, meaning that the Jews received the benefits of the sin-offering by the water and those in the church receive the benefits of the death of the Lord Jesus with the "word"--
"the washing (loutron) of water with the word."
Anderson wrote,
"We know what the sacrifice typified, what did the water typify? What is the means by which the defiled sinner is brought into contact, as it were, with the great sin offering of Calvary? By 'the word of the truth of the gospel.'"
So the Lord Jesus at John 3:5 was using the word "water" in a typical sense where the anti-type is the "word."
"It was revealed to them that they were not serving themselves, but you, in these things which now have been announced to you through those who preached the gospel to you by the Holy Spirit sent from heaven - things into which angels long to look" ( 1 Pet.1:12).
"for our gospel did not come to you in word only, but also in power and in the Holy Spirit and with full conviction; just as you know what kind of men we proved to be among you for your sake" (1 Thess.1:5).