How would those recepts qualify for wall space at that height?
210.52 Dwelling Unit Receptacle Outlets. This section provides requirements for 125-volt, 15- and 20-ampere receptacle outlets.
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(A) General Provisions.
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(1) Spacing. Receptacles shall be installed such that no point measured horizontally along the floor line of any wall space is more than 1.8 m (6 ft) from a receptacle outlet.
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(3) Floor Receptacles. Receptacle outlets in or on floors shall not be counted as part of the required number of receptacle outlets unless located within 450 mm (18 in.) of the wall.
(4) Countertop Receptacles. Receptacles installed for countertop surfaces as specified in 210.52(C) shall not be considered as the receptacles required by 210.52(A).
(B) Small Appliances.
(1) Receptacle Outlets Served. In the kitchen, pantry, breakfast room, dining room, or similar area of a dwelling unit, the two or more 20-ampere small-appliance branch circuits required by 210.11(C)(1) shall serve all wall and floor receptacle outlets covered by 210.52(A), all countertop outlets covered by 210.52(C), and receptacle outlets for refrigeration equipment.
Stipulation 1: we all agree that receptacles meeting the horizontal spacing requirement for counter top receptacles meet the horizontal spacing requirement for "bare wall" receptacles because 4 feet is less than 12 feet and the exceptions for countertop receptacles spacing generally do not span more than 8 feet (4+8=12).
Stipulation 2: we all agree it is customary to place "bare wall" receptacles at 18 inches -- 20 inches above (or my hammer's handle length, ...) AFF. However there is no height requirement specified in this section. It is possible that there is a 5-? foot rule somewhere else in the
code that disqualifies receptacles above that height from being counted as "bare wall" receptacles, but I am too lazy to look for that now. In any event the receptacles mounted within normal range for "countertop" receptacles are below 5-? feet. Thus they can be counted as "bare-wall" receptacles.
Stipulation 3:[/B] The SABCs can or must service all wall or floor mounted receptacles.
Therefore: if there are no countertops or cabinets, these receptacles can fill the requirements of "bare-wall" receptacles.
And: if countertops on cabinets exist, no "bare-wall" receptacles are required where the cabinets are.