Lets say your service gear sits in the same room as your transformer. And you used a concrete encased electrode as your service GEC. Can you use the same GEC for your transformer also? Could you in this scenario run a #4 copper from your transformer to your #4 GEC and be code compliant?
If not could you run a properly sized GEC to the panel feeding your transformer as long as it's rated as service gear? 250.30(A)(3) Exception 2 seems to permit it.
If not could you run a properly sized GEC to the panel feeding your transformer as long as it's rated as service gear? 250.30(A)(3) Exception 2 seems to permit it.