I haven't read through the entire thread, so I don't know if you provided this clarification earlier. The first thing the state AHJ needs to do is ignore this clown, the second is to get him fired and replaced by someone who has a clue. Preferably someone who worked a couple summers for his or her dad, uncle, or older sibling in the trade. In the professional engineering game, this nitwit would be guilty of practicing outside his area of expertise and subject to reprimand, censure, fine or all three.I am not referring to a private practice. I am referring to someone whose job it is to provide Legal Counsel to a states AHJ, who has decided to take liberties in making determinations outside the realm of ones expertise without even consulting the top state level AHJ. You could say that it almost done in a "going rogue" fashion. To the point where someone who you had to explain what a four square box is tells you they feel running conduit is NOT electrical work in the same conversation by the span of a few paragraphs.
It is all well and good to say, in the abstract, that running RMC, IMC or EMT is not, per se, "electrical work". However, the foremost responsibility of the state AHJ is to protect the public safety via enforcement of the state construction code and that is not done "in the abstract". How far would this moron go to parse what's electrical work? Conduit isn't electrical, in and of itself; wire isn't electrical, in and of itself; circuit breakers, panels, transformers, switches, receptacles, all in and of themselves might, might, mind you, be argued as not part of an electical installation until the last connection is made which then turns all of the "non-electrical" components into an electrical system. Make him and his infant children live in the first house, condo, or apartment building put together in this fashion and see what tune he sings then.