This is from the HB
The requirement for bonding perimeter surfaces now applies to paved and unpaved surfaces. An example of an unpaved perimeter surface would be the lawn surrounding a permanently installed aboveground swimming pool. Where the paved portion of the perimeter surface extends less than 3 ft horizontally from the inside walls of the pool, the perimeter bonding grid must be continued under the adjacent unpaved perimeter surface. If physical constraints (such as a wall or other physical barrier) prevent the perimeter from extending 3 ft beyond the inside walls of the pool, the bonding grid is required only to extend under the available perimeter area.
The perimeter bonding grid can be comprised of structural reinforcing metal (re-bar or welded wire mesh) that is conductive to the perimeter surface and installed in or under the perimeter surface. Where structural reinforcing steel is not available, a single, bare, solid 8 AWG or larger copper conductor can be installed around the perimeter of the pool in an area measuring between 18 in. and 24 in. from the inside pool walls. This 8 AWG bonding conductor can be installed in the paving material (i.e., in the concrete), or it can be buried in the material (subgrade) below the paving material. Where buried, the bonding conductor is to be not less than 4 in. and not more than 6 in. below the surface level of the subgrade material.
The perimeter surface bonding medium has to be connected, at four evenly spaced points around the pool perimeter, to either the structural steel of a conductive pool shell or to the copper bonding grid provided for the conductive pool shell that has encapsulated re-bar or no re-bar at all. Connection between the perimeter bonding medium and nonconductive pool shells is not required.
I think the steel walls are conductive.