The code making panels point in not using a single conductor for both purposes is that under normal operating conditions an EGC should not have current flow, but a GEC can have current flow under normal operating conditions.
I must ask, why would a GEC have current flowing on it between the transformer and the service feeding the transformer? if it does so will the EGC as when run like this they will be in parallel with each other.
To me that reason makes no sense at all?
It also make no electrical sense to require another conductor to be run in the same raceway between the service equipment and a transformer the service equipment feeds, when one sized for the larger requirement of 250.66 would do the same thing and like I said they would be paralleled anyways.
The second problem in requiring a grounding electrode system for a SDS is if you don't have building steel or a water pipe available exception 1 to 250.30(A)(4) allows installing a 250.52(A) electrode which does not relinquish the requirement to bond this new electrode to existing electrode system of the same building as pointed out by the FPN #2 to 250.4(A)(4) so you can't even drill a rod in a call it a day as you would still have to run an electrode bonding jumper back to the buildings electrode system, so even installing a made electrode does nothing to help.
Last if you have run a metallic raceway to supply the transformer then you have to make it electrically continuous because it contains the electrode conductor as required in 250.64(E)
I have never understood why a SDS in the same building as the service should ever need an electrode conductor, while we can run branch circuits or feeders to the same location and the EGC is just fine, unless someone in the code making panel believes that lightning knows to only take the path of the GEC and thinks it won't take the path of the EGC, yep its that stupid.
It makes installing a SDS at a remote location in a non steel structure so costly that most will just install it at the main service with a disconnect and run feeders to the sub panel where they need the circuits because then all they need is an EGC.