One friend actually charges extra if the work is being performed under hazardous conditions, he will actually take the door off of the hinges to work if needed. Home owners and designers think that is the best possible location for a subpanel and design specifically for that. In fact a couple designers starting showing the sub-panel location behind doors because they know I'll call it out in the field, and that the BO will most likely allow it shown on the plans. He's my boss though so what can I say. Also in reality, there are far larger fish to fry out there. This is not a battle I fight hard for...