Here is the Code Commentary from 210-70(a)(3):
"Installation of lighting outlets in attics, under floor spaces or crawl areas, and in utility rooms or basements is required only where these spaces are used for storage (e.g., holiday decorations and luggage).
If such spaces contain equipment that requires servicing (e.g., air-handling units, cooling and heating equipment, water pumps, and sump pumps), Section 210-70(c) requires that a lighting outlet be installed in these spaces."
In a new installation, the contractor does not know if the area is to be used as storage, therefore it can be argued both ways as to the requirement. The AHJ has final say.
If this is an existing older residence and additions are made in this area, the AHJ may require it to be updated, if he sees it to be a storage space.