CEE is a requirement of a new service in new construction. An addition does not require you to install one. It is not required that you ground the footer steel, the requirement is to ground the service using the footer steel. Even upgrading the service would not require you to use the footer steel as you would have to distroy the existing concrete footer to attach to it. Add a room with new footers and a new service then yes you would have to us it. In new construction, the 2005 code says "If Present". That means that if some provision wasn't made to make it accessible during construction, you will get out the jack hammer and find it. In 2002, you got away with 2 ground rods because the code said "If availible". different story.
Unlimited Electric Contractor/Standard Electric Inspector/Traffic Signal Inspector/Highway Lighting and Level One Traffic Signal Installer.
I know you believe that you understand what you think I said but I'm sure you realize that what you heard is not what I meant.