I agree, that sounds fishy. Maybe it's just an oversimplification of some pathological case, but I don't see how. The SF law on its own (as stated) would seem to preclude any counter deeper than 18", and then a receptacle in line with each edge should satisfy the NEC.

Carl Malamud is a saint. It's preposterous that people are expected to be bound by laws they cannot even access. But this obviously only affects the DIYers - commercial electricians benefit from the unjust barriers.