I think so,.. if the gutter is used to supplement
( Something added to complete a thing, make up for a deficiency, or extend or strengthen the whole.)
the wiring space at the distribution center why would it not be able to function as that witch it is supplementing ??
Ok, so the auxiliary gutter is installed to supplement the wiring space at a cabinet, but that does not make the auxiliary a cabinet it is still a gutter.
The definition of auxiliary gutter in 366.2 tells us that a metallic auxiliary gutter is:
"A sheet metal enclosure used to supplement wiring spaces at meter centers, distribution centers, switchboards, and similar points of wiring systems. The enclosure has hinged or removable covers for housing and protecting electrical wires, cable, and busbars.
The enclosure is designed for conductors to be laid or set in place after the enclosures have been installed as a complete system."
Here is the definition of a raceway:
"Raceway.
An enclosed channel of metal or nonmetallic materials designed expressly for holding wires, cables, or busbars, with additional functions as permitted in this Code. Raceways include, but are not limited to, rigid metal conduit, rigid nonmetallic conduit, intermediate metal conduit, liquidtight flexible conduit, flexible metallic tubing, flexible metal conduit, electrical nonmetallic tubing, electrical metallic tubing, underfloor raceways, cellular concrete floor raceways, cellular metal floor raceways, surface raceways, wireways, and busways."
It seems that an auxiliary gutter sounds an awful lot like a raceway to me.
Chris