NEC 230.72(A) Six disconnects and surge suppressor

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DW98

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interpretation question: Does the surge suppressor and its disconnect have to be built into a panelboard or switchboard not to count as one of the six disconnects, or can you have a disconnect with a separately mounted surge supressor. What is "installed as part of the listed equipment" referring to?

Looking for opinions on how to interpret this.
 
Opinion based on '08, I would say it would have to be a 7th disconnect
internal with a listed piece of service equipment.
 
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