self contained hot tub
Yes, he is misinterpreting NEC 680.23, the section for underwater pool lights. I have had this argument with other electricians who think the same thing.
IMO this section DOES NOT apply since these package spas have the lights all ready wired from the factory.
You ARE NOT wiring an underwater light, you are wiring a factory assembled package spa!
If this were a field assembled spa put together like a pool he would definitely have a point.
Unfortunately, a hard ass inspector can interpret things wrong, yet require you to do them.
If it was me and he pressed the issue I'd go over his head until I got satisfaction.
Sometimes I feel like if I answer any more questions it is like someone trying to climb over a fence to jump off a bridge and me giving them a boost.