arc fault for panel change out

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An inspector asked today if we needed to do arc fault breakers when we change out a panel. We haven't had to here but a friend of mine says that they do in his area. I'm curious about ya'lls take on this. I cant think of any way to price that out ahead of time given that I know we'd have to split up neutrals on three ways and all kinds of other joints. I don't see this as a modification to the circuit.
 
Direct panel swap, same location... no. If you start extending circuits over 6', or modify circuits in addition to the upgrade then you should review 210.12 for sure.
 
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