Okay, let's break this down and understand the arguments.

Understanding the Issue: Working Space around Electrical Equipment NEC 110.26(A)(1)

This section generally mandates specific clear working space (depth, width, and height) in front of electrical equipment that is likely to require examination, adjustment, servicing, or maintenance while energized. It's about safety for personnel working on the equipment. The exact depth requirements depend on the voltage and conditions present.

NEC 110.26(A)(2)

This section describes situations where equipment is installed in narrow spaces and what to do if the space requirements of 110.26(A)(1) are not met. Essentially, it allows for the exception where the equipment is installed in a recess or limited space if the working space (depth) extends the full width and height required by 110.26(A)(1).

Your Argument (and where it might be flawed)


Panel is Recessed

You're stating the panel is recessed within the stud space along the long dimension, implying this creates a narrow workspace situation. The key here is whether the depth of the space, from the face of the panel to the opposite wall, meets the minimum depth requirements of 110.26(A)(1) for the voltage of your panel.
2.

Depth is 24"

You're stating the depth of the space is 24". This is a critical measurement. You need to compare this depth to the required depth in Table 110.26(A)(1) of the NEC based on the voltage of the panel and the conditions of the surrounding area (e.g., grounded parts on one or both sides, or insulated conditions).
3.

Door Opens Outward

The fact that the door opens outward is good. It's not an obstruction.4.

Panel Doesn't Require Work

This is where your argument is likely weakest. While you may not plan to work on the panel frequently, the NEC assumes that electrical panels will require examination, adjustment, servicing, or maintenance at some point. Tripping a breaker, replacing a breaker, troubleshooting a circuit, labeling, or even just visual inspection all fall under these categories. The code doesn't allow you to circumvent the working space requirements just because you anticipate minimal work. The NEC is about providing safe working conditions when that work is necessary.

Why the Inspector Is Likely Correct (and what to check)


Minimum Depth Requirements

The inspector is likely saying that the 24" depth you're providing does not meet the minimum depth requirements of NEC 110.26(A)(1) based on the voltage and conditions. You must consult Table 110.26(A)(1) in the NEC to confirm this. For example, a 120/240V panel with grounded parts on one side might require a deeper working space than 24".
2.

Focus on 110.26(A)(1) Requirements

The inspector is emphasizing that you must still meet the minimum required working space depth even if the panel is recessed. This often means having that clear and unobstructed 36" wide and proper depth working space.

How to Proceed (to either confirm or refute the Inspector's position)


Determine Panel Voltage and Conditions

What is the voltage of the panel (e.g., 120/240V)? What are the conditions on the opposite side of the working space (e.g., grounded metal parts, insulated surfaces)?2.

Consult NEC Table 110.26(A)(1)

Based on the voltage and conditions, determine the required minimum depth of the working space.3.

Is the Width correct? The width of the working space must be at least 30 inches wide or the width of the equipment, whichever is greater.4. Ensure the Height is Correct

The working space must be at least 6 1/2 feet high.5.

Compare Your Depth to Code

Does your 24" depth meet the minimum required depth from Table 110.26(A)(1)?6.

If 24" is Insufficient

If the required depth is more than 24", the inspector is correct. You'll need to either: Relocate the panel to a location with adequate working space. Modify the existing space to increase the depth to meet the code requirement.7.

If 24" is Sufficient

If the required depth is 24" or less, you can politely explain your reasoning to the inspector, providing the NEC reference (110.26(A)(2) and Table 110.26(A)(1)), and demonstrate that you meet the code requirements. However, be prepared for them to still disagree based on their interpretation.
8.

Document Everything

Take pictures of the installation, measurements, and the relevant sections of the code.

Important Considerations



Local Amendments

Always check for local amendments to the NEC. Some jurisdictions have stricter working space requirements.

Inspector's Discretion

Ultimately, the inspector has the final say on whether the installation meets code. Be respectful and try to understand their reasoning. If you strongly disagree, you can appeal the decision, but be prepared to provide solid evidence to support your case.

Safety First: Remember, these working space requirements are in place for safety. Adequate working space can prevent serious injuries during electrical work.In summary, while you're trying to leverage 110.26(A)(2), the inspector is likely focusing on the fundamental depth requirements of 110.26(A)(1). You need to prove that your 24" depth meets the minimum required depth* based on your panel's voltage and surrounding conditions, as specified in Table 110.26(A)(1) of the NEC. Don't rely on the argument that the panel won't require work. Flag for review