Bonding down conductor to steel rebar

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m sleem

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Hi all, i'm in a situation where 10 stories car parking building is constructed without executing any requirements for lightning protection system, now i'm trying to resolve through adding exposed down conductors connected to grounding rods in ground, the question is "can we connect the down conductors directly to grounding rods without bonding to steel rebars?"
 
Bonding down conductor to steel rebar

NFPA 780
4.9.13 Down Conductors and Structural Columns. Down conductors coursed on or in reinforced concrete columns or on structural steel columns shall be connected to the reinforcing steel or the structural steel member at their upper and lower extremities


4.9.13.1 In the case of long vertical members, an additional connection shall be made at intervals not exceeding 60 m (200 ft).
4.9.13.2 The connections for 4.9.13.1 shall be made using listed clamps or listed bonding plates or by welding or brazing.
4.9.13.3 Where the bonding requirements of 4.9.13.1 and 4.9.13.2 are not satisfied, provisions shall be made to ensure the required interconnection of these parallel vertical paths.
4.9.14 Down Conductors in Nonmetallic Enclosures. The use of PVC conduit or other nonmetallic chase shall not eliminate the need to satisfy the bonding requirements of Sections 4.19, 4.20, and 4.21.
 
NFPA 780
4.9.13 Down Conductors and Structural Columns. Down conductors coursed on or in reinforced concrete columns or on structural steel columns shall be connected to the reinforcing steel or the structural steel member at their upper and lower extremities


4.9.13.1 In the case of long vertical members, an additional connection shall be made at intervals not exceeding 60 m (200 ft).
4.9.13.2 The connections for 4.9.13.1 shall be made using listed clamps or listed bonding plates or by welding or brazing.
4.9.13.3 Where the bonding requirements of 4.9.13.1 and 4.9.13.2 are not satisfied, provisions shall be made to ensure the required interconnection of these parallel vertical paths.
4.9.14 Down Conductors in Nonmetallic Enclosures. The use of PVC conduit or other nonmetallic chase shall not eliminate the need to satisfy the bonding requirements of Sections 4.19, 4.20, and 4.21.
But my down conductors are exposed not embedded!!
 
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