I see your point though and believe you are correct. Though I do think 10 sets of 350kcmil is an unlikely feeder vs 7 sets of 500 where it would be a non issue. There was a 2011 ROP that supports your comment.
5-287 Log #3816 NEC-P05 Final Action: Reject
(250.122(A))
_______________________________________________________________
Submitter: Christel K. Hunter, Alcan Cable
Recommendation: Add new text to read as follows:
250.122 Size of Equipment Grounding Conductors.
(A) General. Copper, aluminum, or copper-clad aluminum equipment
grounding conductors of the wire type shall not be smaller than shown in Table
250.122, but in no case shall they be required to be larger than the circuit
conductors supplying the equipment, including in parallel circuits. Where a
cable tray, a raceway, or a cable armor or sheath is used as the equipment
grounding conductor, as provided in 250.118 and 250.134(A), it shall comply
with 250.4(A)(5) or (B)(4).
Substantiation: Until the reorganization of the Code in 1999, the EGCs in
parallel circuits were not required to be larger than the circuit conductors.
When 250.122 was reorganized, the exception that clarified this case was
moved into (A). Until recently, AHJs have agreed that the language in (A)
applies to (F), parallel circuits. However, there has been a change in
enforcement in the last few years after the publication of articles interpreting
this code language. Even with the addition of the language “in no case” in the
2008 NEC, there are still AHJs requiring that the EGCs be larger than the
ungrounded conductors in some parallel circuits.
The language proposed would clarify that the EGCs need not be larger than
the ungrounded conductors in parallel circuits. This was clearly the case until
the 1999 NEC, and no proposal was made nor substantiation provided to
change the application of the code. It appears that the intent of the changes
made at that time were simply to clean up the language and use positive
language. However, the editorial changes have resulted in an unintended
technical change that was never proposed nor discussed by the CMP.
Panel Meeting Action: Reject
Panel Statement: The substantiation provided does not support reducing the
current sizing requirement. The panel concludes that the rating of the
overcurrent device is the determining feature for sizing all equipment
grounding conductors, including those installed in parallel circuits.
Number Eligible to Vote: 16
Ballot Results: Affirmative: 13 Negative: 3
Explanation of Negative:
DOBROWSKY, P.: Accepting this change would match the requirements for
supply side bonding jumpers installed in parallel.
MOHLA, D.: This propsal should have been either accepted or as a minimum
required a clear statement by the panel that that parallel circuits conductors are
also circuit conductors and included. The submitter is correct in stating the
requirement that “in no case the equipment grounding conductors are required
to be larger than the circuit conductors” apply also to parallel circuits.Identical
requirements exist in 250.24 (C) (1) for grounded conductor brought to Service
Equipment and in 250.30 (A) (8) (a) for grounded conductor for separately
derived systems. Grounded conductor on the supply side of overcurrent
protective device performs the same function as EGC on the load side of the
overcurrent protective device i.e. provides a path for ground fault currents.
Sizing requirements for supply side grounded conductors and load side EGC
should be same as they perform the same function during ground fault
conditions.
TEMBLADOR, R.: One primary factor that limits the current that flows
during a ground fault is the impedance of the circuit or circuits. Within a
specific circuit, the weakest link (highest impedance) in the chain of devices
connected together limits the current.
There are multiple circuit paths that are formed during a ground-fault
condition which are primarily comprised of the ungrounded circuit conductor,
equipment grounding conductors (EGC) and bonded metal enclosing the circuit
conductors. During a phase-to-ground fault in a circuit with paralleled
conductors, ground fault current will travel down all available paths to return to
the source. The current that flows divides at the point of the fault and travels
back to the source through both ends at which the ungrounded conductor, and
the bonded metal enclosing the circuit conductors or EGC’s are paralleled, or
both. Current flowing down the EGC’s and bonded metal enclosing circuit
conductors does not only flow down one path. It too will travel down all
available paths to return to the source. Consider a ground fault scenario where
the EGC’s are larger than the phase conductors. In this instance, the weakest
link in the circuit is the paralleled ungrounded phase conductor and it will limit
the fault current.
The equipment grounding conductors should not be required to be larger than
the ungrounded phase conductors where conductors are paralleled in multiple
raceways or cable.