That wasn?t David?s point. He was suggesting that the countertop receptacle that happens to be a simplex and that happens to have a fridge plugged into it could count as one of the two required SABCs, so that only one more would be needed. I am inclined to agree, though I suspect most of us would consider that a poor design.
We don?t have to know or care what the homeowner chooses to plug into any given receptacle. If it is above the countertop, and if it is on a 20 amp circuit (individual or otherwise) then it is a SABC.
I was suggesting the 20 amp circuit serving receptacles in these areas could ware two hats. And by design (placement being one of the design chooses ) it will be one or the other.
A 20 amp individual branch circuit designed to supply the refrigerator could very easily take off that hat a put on the hat of a small appliance branch circuit just by changing the intended design of the circuit.
In my example move the 20 amp single rec. just a few inches until it is blocked by the refrigerator and it in no way could be considered one of the two or more small appliance branch circuits for the purpose of supplying the counters.
You could still design it as a small appliance branch circuit even if it is one single receptacle on its own circuit blocked so that the refrigerator is the only appliance that is intendant to use the rec.
My conclusion is a 20 amp circuit in the areas being discussed by design is either an individual branch circuit for the purpose of supplying a single refrigerator or it is a 20 amp small appliance branch circuit
The small appliance branch circuit could have as many rec. as you choose to add in the areas allowable by the small appliance branch circuit restrictions.
These circuits are not both by design they are one or the other ether a individual branch circuit or a small appliance branch circuit.
As pointed out in this thread some have suggested that if designed as a small appliance branch circuit then a 1500 load calculation becomes a consideration
There is no such load calculation considered if designed as an individual branch circuit supplying a single refrigerator. When designing an individual circuit the load is limited to a specific appliance. However the circuit is not extending to other receptacle unless it is no longer considered an individual circuit and considered a small appliance branch circuit
The 15 amp individual branch circuit is restricted by design to a s pacific load and does not have the option of two hats as its sister 20 amp individual branch circuit does.
The 15 amp circuit is an individual branch circuit an never could be extended to other loads an can not be reasonablev ever consider a small appliance branch circuit