subpanel location

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Maybe, if it is an existing dwelling 110.26(A)(3), Exception 1. Will your AHJ allow it? Maybe. I've seen it done. I would never do it or accept in my house.
 
The height of the working space in front of the equipment must be 6-1/2 ft unless its an existing dwelling unit
 
I guess we are assuming a typo. Because 48 feet is a pretty good crawlspace ceiling.

Agreed. If there, oh well. If being asked to put it there, well, no.
 
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