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I got a heavy-up in 2003, and the inspector said that a new panel is new work, and new work requires wired detectors. I was working with a VA-based electrician — I prefer not to name them
, because it wasnt a super experience — and this requirement was new to them. Eventually the electrician came to some understanding with the inspector (or her supervisor), and we didn’t need them.
We are thinking about converting our basement into a rental with separate service panels, and I will budget for wired detectors in both area of the house.