250.24(C) and 250.92(A)(1)
The problem with Smart$ argument is that neither of these sections unambiguously applies to a supply side PV disconnect if such a disco is not already considered a 'Service Disconnecting means' or 'at the service' (respectively).
Again, if we simply change the definition of the service so that applies to any conductors and equipment connecting a utility to a premise, regardless of the direction of energy flow, then most of the ambiguity goes away.
The only remaining problem sections would be those that refer to the 'supply-side of the service disconnecting means' in a way that could be taken to imply, grammatically, that any such thing on the 'supply side' is not the service disconnecting means. This interpretation is contradicted by some other sections, such as 230.82(5) and 230.71(A), which imply that certain (not all?) of such connections are service disconnecting means or service equipment. Perhaps regular use of the word 'normal', as in 'supply side of the normal service disconnecting means' is all that is necessary to nix this interpretation. Currently the word 'normal' appears in only one such spot that I'm aware of (230.40 Exception 5), but at least that means there's a precedent for it.
In all, these proposals would substantially fix the problem, in my opinion, without adding more than one word to any section of the code.

I think shortcircuit's proposal in this thread is also in the same spirit.