The line of demarcation between utility and customer is the service point.
IMHO, what you are trying to do is illegal, and I can't imagine any AHJ buying into such a philosophy. Here is an excerpt from the 2014 NEC Handbook (page 2), which clarifies this exact point:
Exhibit 90.1 illustrates the distinction between electric utility facilities
to which the NEC applies and those to which it does not apply.
The electrical equipment in the generating plant is not governed
by the rules of the NEC. The warehouse is a typical commercial
facility in which the electrical installation would be governed by
the rules of the NEC, regardless of its ownership. Office buildings
and warehouses of electric utilities are functionally similar to like
facilities owned by other commercial entities.
Industrial and multibuilding complexes and campus-style
complexes often include substations and other installations that
employ construction and wiring similar to those of electric utility
installations. Because these installations are on the load side of
the service point, they are within the purview of the NEC. At an
increasing number of industrial, institutional, and other campus style
distribution systems, the service point is at an owner-maintained
substation, and the conductors extending from that
substation to the campus facilities are feeders (see definition in
Article 100). NEC requirements cover these distribution systems in
225.60 and 225.61 and in Article 399. These overhead conductor
and live parts clearance requirements in the NEC correlate with
those in ANSI C2, National Electrical Safety Code? (NESC), for overhead
conductors under the control of an electric utility.