If there is no rebar then no Article 250 CEE is required.
I don't agree, if there is not any rebar then you have to put 20 feet of bare copper per 250.52(A)(3)(2).
(3) Concrete-Encased Electrode. A concrete-encased elec‐
trode shall consist of at least 6.0 m (20 ft) of either (1) or (2):
(1) One or more bare or zinc galvanized or other electrically
conductive coated steel reinforcing bars or rods of not
less than 13 mm (1∕2 in.) in diameter, installed in one
continuous 6.0 m (20 ft) length, or if in multiple pieces
connected together by the usual steel tie wires, exother‐
mic welding, welding, or other effective means to create a
6.0 m (20 ft) or greater length; or
(2) Bare copper conductor not smaller than 4 AWG
Metallic components shall be encased by at least 50 mm
(2 in.) of concrete and shall be located horizontally within that
portion of a concrete foundation or footing that is in direct
contact with the earth or within vertical foundations or struc‐
tural components or members that are in direct contact with
the earth. If multiple concrete-encased electrodes are present
at a building or structure, it shall be permissible to bond only
one into the grounding electrode system.
Informational Note: Concrete installed with insulation, vapor
barriers, films or similar items separating the concrete from the
earth is not considered to be in “direct contact” with the earth.