1. Section/Paragraph: 250.52
2. Comment on Proposal No. (from ROP): 5-157 Log #3051
3. Comment recommends: Revised Text
4. Comment: To be generated later, revising the definition of Water Pipe as well.
5. Substantiation: The reason my comment has brought a neighboring electrode into the discussion of this proposal is that this is an issue that effects all electrodes in scope. I hope the panel will forgive the more pedantic portions of my substantiation; in my opinion it's necessary to carefully examine the relevant sections in question in order to cast light on the main problem that the proposal brought to light.
All electrodes are equal in reading 250.50. All electrodes that are present are required to be used. 250.64 is clear, in that a Grounding Electrode Conductor (GEC) is a conductor that begins at the neutral busbar of the service equipment on one end, and terminates at a grounding electrode. (I will ignore the grounding busbar option for clarity.)
The panel's response to this proposal was, "Only the portion of an electrode that is in contact with the earth can be called an electrode. The exposed portion of the rebar could be used as a connection point but cannot be considered as the electrode."
The problem with this statement is that we cannot legally connect a GEC to anything besides a grounding electrode. We can't connect to something that looks like a grounding electrode, but is not. Only that portion of a CEE that fully complies with every detail laid out in 250.52(A)(3) is truly a CEE.
The water pipe electrode is in a similar boat. Only that 10' of metallic water pipe in contact with soil is doing the business of grounding. The water pipe is far easier to connect to inside the building, and so installers like to connect to it there. The only way for an installer to legally connect to a CEE outside of concrete, or a water pipe outside of dirt, is for that "electrode" to continue to be a fully qualified "electrode" for our purposes outside the boundaries of the dirt or concrete. We are not allowed to connect GECs to anything else!
In discussions on this topic, it has been brought up that water pipes have an additional provision to restrict us from using piping farther than 5' from the entrance of the building as a grounding electrode, which is true. What is false is that this prohibition gives us permission to connect inside of five feet. Section 90.5 makes it excruciatingly clear that key words inside a phrase make the phrase either mandatory or permissive. If a water pipe ceases to be an electrode once it leaves soil, then every single water pipe installation in the U.S. (even the ones connected to prior to the mid-1980's five foot restriction of it's use) are illegal. We are required to connect to "the electrode." If it is the panel's contention that "the electrode" ends in the soil, then we are not permitted to connect anywhere else.
Building steel is a commonly used "electrode" to interconnect electrodes. Building steel is not going to go anywhere, or change uses in the life of a building, and so therefore there is no harm in doing so. If the panel is going to go on record as saying that only "business portions" of grounding electrodes are actually electrodes, it turns that practice on it's head.
The simplest solution is to simply grant that an electrode continues to be an electrode as long as it is electrically continuous. A water pipe electrode is a water pipe electrode until you run out of pipe and solder, indoors. A CEE is an electrode until you feel exquisitely silly lashing pieces of rebar together with tie-wire (but without concrete encasement) through the interior of a structure. We will still have language to restrict our use of those electrodes to points where they are sound. A water pipe is only sound for electrical use in the first five feet. A CEE is only sound for the first piece of rebar jutting out from the concrete. Building steel is sound infinitely without restriction, as are ground rods, rings, plates.