I hope I will be forgiven for opining that that POCO's requirement for burying the Grounding Electrode Conductor and it's connections to the Driven Rod Electrodes is, at least, rational. Can anyone quote me the exception that excludes Grounding Electrode Conductors from the NEC's Minimum Cover Requirements. Maybe I just never found it and I'm all wet but the NEC seems to require that underground electrical conductors must be buried 2 feet deep if they are not enclosed in an appropriate raceway. I'd love to be shown I am wrong about this because it is extra work. Please except that I'm unwilling to read argument as to why it is unnecessary. What I'm after is what code language excludes GECs from the NEC's Minimum Cover Requirements.
I'll make a confession here. Once I had dug down to 2 feet I sometimes went to 2 & 1/2 feet and installed the rods twice there length apart. I got that out of a white paper published by the National Institute of Standards and Technology (NIST) on effective grounding for surge protection of residential services. I only did that in properties that didn't have other more effective Grounding Electrodes. If the well doesn't have a metal casing or it is too far from the service to actually be "present at each building or structure served" with plastic used for the water lines you can run out of other electrodes pretty quick. In the same vain I would usually make the connection of the Grounding Electrode Conductor to the Neutral Service Entry Conductor just on the building side of the splice between the Neutral Service Entry Conductor and the POCO's Service Drop Neutral Conductor. I never worked in a State were that splice was not the demarcation point. Making the Grounding Electrode Conductor connection at that point is a requirement which many electrical cooperatives retained from the service standards of the Rural Electrification Administration (REA). The NEC has always allowed the connection to be made there, although I think that there was a proposal for the 2020 Edition to require that the connection be made in an enclosure. I have no idea whether it got adopted or not.
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Tom Horne