Merlin,

I would agree with Jimmy, that it is an AHJ call. The NEC (I believe) says, the disconnect has got to be "AS SOON AS POSSIBLE." (I don't have my code book with me.) So how soon is that? Some say 3' some say 5' some say 15'. Each job is different. Will the "back to back" be subject to damage? Then you might want a disconnect outside and run a 4 wire to the service which becomes a sub panel to protect the conductors. Or you might have to install the back to back in pipe to prevent damage.