You've hit on a long-standing and frequently debated point in residential electrical load calculations. Your understanding is generally correct, and your reasoning is sound. Let's break down the issues and address your questions

Understanding the Issue: 220.14(I) vs. 220.14(J) in Dwellings
220.14(J)

This section is specific to dwelling units and only covers receptacle outlets required by 210.52. These are the general-use receptacles in habitable rooms, small appliance circuits in kitchens and dining areas, and laundry circuit receptacles. The intent is that the 3 VA/ft² general lighting load includes these receptacle loads.

220.14(I)

This section covers all other outlets and is typically used for non-dwelling applications. It requires 180 VA per receptacle yoke. Your interpretation that it applies to dwelling receptacles not covered by 210.52 and therefore not included in 220.14(J) is the crux of the debate.

Addressing Your Questions


Official References, CMP Notes, and Handbook Excerpts



CMP Intent

Unfortunately, the NEC Handbook and CMP Notes don't always provide crystal-clear guidance on every nuance. In this specific case, the lack of direct, explicit statements leaves room for interpretation. This is a weakness of the Code sometimes.

The NEC Handbook (Informative Annex D)

Annex D of the NEC provides calculation examples. While these examples typically don't explicitly apply 180 VA to optional dwelling receptacles, the absence of an example doesn't constitute a prohibition. The examples mainly cover the basic, required load calculations.

Informal Guidance (Technical Forums)

You can often find debates on this topic in electrical forums and from electrical inspectors. The consensus is mixed, but you will find inspectors who require the 180VA calculation for non-required receptacles.2.

Why Doesn't the NEC Explicitly Exclude 220.14(I) from All Dwelling Receptacles? Presumption of Application

The NEC generally operates on the principle that a rule applies unless it's explicitly excluded or modified. 220.14(I) is a general rule; 220.14(J) is a specific rule that modifies the general rule for a defined subset of dwelling receptacles.

Code Refinement

The NEC is constantly evolving through the code cycle. Gaps and ambiguities like this are often addressed (or clarified) in future editions based on proposals and feedback from the field. It's possible this will be explicitly addressed in a future edition.

Complexity vs. Simplicity

The NEC aims to be as straightforward as possible. Explicitly stating that 220.14(I) doesn't apply to every possible non-required receptacle in a dwelling might be seen as overly verbose and unnecessary, especially since the logic follows from the existing structure of the sections.

Arguments for Applying 180 VA to Optional Receptacles



Logic

The text of the code explicitly says that the 180VA/yoke applies except as covered in (J). If those receptacles aren't covered in (J), the 180VA/yoke should apply.

Accuracy

The 3 VA/ft² method is a broad estimate. If you have a dedicated workshop with multiple power tools and receptacles, relying solely on the general lighting load might significantly underestimate the actual demand.

Future Proofing

Adding receptacle circuits with no extra load calculation can lead to circuits being used to greater loads than intended, and in the future, as houses get smarter and use more power.

Arguments Against Applying 180 VA to All Optional Receptacles



Historical Practice

Many electricians and inspectors have historically interpreted the NEC as including all receptacles in the general lighting load, regardless of requirement.

Perceived Burden

Adding 180 VA per receptacle for every optional outlet can significantly increase the calculated load and potentially require a larger service, which can be seen as an unnecessary cost for homeowners.

Diversity of Use

The assumption is that optional receptacles, especially those in unfinished areas, may not be used simultaneously at their full rated capacity.

Recommendations and Practical Advice


Consult Your Local Inspector

This is the most crucial step. The AHJ (Authority Having Jurisdiction) has the final say. Discuss your interpretation and reasoning with the inspector before starting the project. Get their input and follow their direction.2.

Err on the Side of Safety (and Over-Sizing)

When in doubt, calculating the optional receptacles at 180 VA each is the more conservative approach. It ensures you're not underestimating the potential load.3.

Consider Actual Load

If you know the specific appliances or equipment that will be used in the optional areas (e.g., workshop tools, a specific refrigerator in the basement), calculate the load based on the actual VA rating of those devices. This might be more accurate than the 180 VA/receptacle rule.4.

Documentation

Document your load calculations clearly, specifying which receptacles were included in the general lighting load and which were calculated separately at 180 VA (if applicable). This will help with inspections and future reference.5.

Load Calculation Worksheet

Use a detailed load calculation worksheet that breaks down each section of the NEC requirements. This helps you keep track of all the components and ensure you're not missing anything.

In conclusion: There is no definitive "yes" or "no" answer in the NEC itself regarding optional receptacles in dwellings. Your understanding of the issue is correct. The most practical approach is to consult with your local inspector, consider the actual load, and err on the side of safety when calculating the service size. You can also submit a formal interpretation request to the NEC if you want a definitive answer. Flag for review