This is not the first time this has come up here:
Recently our local authority having jurisdiction has indicated that they will not pass any installation where we have put our own knock out in a panel if it has factory knockouts. In other words any panel that has KO's on the bottom cannot be entered from any side or the top by punching a new...
forums.mikeholt.com
Conclusions are the same, I'm just pointing out that this issue with AHJs is not unheard of. I have had similar discussions with a couple of AHJs regarding punching holes in ANY enclosure, as to it "violating the UL listing of the enclosure". UL had available, at one time, a response letter that explained that once a hole is made, whatever goes INTO that hole must have the same or HIGHER level of environmental protection as the original enclosure rating (I can't find that any longer). So if a panel is rated for indoor use, i.e. Type 1, then pretty much any penetration that restores that to Type 1 is fine. Now IF the panel is outdoors, Type 3R, then any penetration must use a "Wet Location" rated connection method, i.e. Myers Hub for example. That is actually codified in 312.2, and repeated specifically FOR PANELBOARDS in 408.16. So if this was a 3R panel, punching a hole and not using a conduit connector method equal to or greater than the enclosure rating might be an issue.