I picture the "permanent moisture level" for a given spot as being, the depth at which you find easy digging with a shovel when digging with a shovel. Around here, if you
can dig it, the soil tends to get moist about a foot deep, give or take.
A sprinkler system would taint that definition, because the moisture really begins at the surface in the summer months when it's in operation.
I view this as different than the water table, which
could be very shallow (as evidenced by looking in the sump pit in some of the houses around here). The water table, IMO, is where you find standing (or flowing) water when you dig.
Do I install ground rods under the line I would call the permanent moisture level? No. I can't even stand behind the defense that I could call it "impracticable", since I could generally dig down a ways where I'd install a ground rod. I just don't see the point in all that work, and it's never practiced around here.
A bit hypocritical of me, I guess, but the common practice trumps the code in this case.
In fact, some folks would actually fail a buried ground rod, for reasons I can't understand. If the copper is okay in the soil, and the ground rod obviously is, and the connector is rated for direct burial, then there's no reason the top of the rod can't be a foot deep. But some will claim the connection has to be accessible, despite an exception to the contrary.