The NEC defines the heigth of the working space around panels as "clear and extend from the grade, floor, or platform to the heigth required by 110.26(E).
As this pic shows, this install takes advantage of this "loophole" by putting the stairs to the basement directly under the panel.
Now I had a service upgrade in a NEC area, and the only spot available on the back wall of the house(local code) was over a crawlspace window well. I had to build a platform of treated lumber for the entire hole for access, not just 2' from the wall, but the entire hole(42"). Does that picture really utilize a loophole in the NEC? Wouldn't you need a railing on that "platform"? At 36" away from front, it looks like that meter is a bit high, 'cuz you're standing in the stairwell.