Many AHJ and utilities consider the meter as electrical equipment subject to 110.26 Clear work space. The utility will be the ultimate judge of location for a meter and may require it to be moved. When people come in for their building permit for a deck the first question we ask is where the gas and electric are located. Firemen do not like to climb under a deck to shut off gas and electric when there is a fire.
Consider the language of 110.26 "likely to require examination, adjustment, servicing, or maintenance while energized". I think service equipment should always qualify. They are not going to drop the primary fuse on the transformer if they open the meter can.