I always felt that the requirement for an equipotential grid for outdoor hot tubs was ridiculous anyway.
It’s completely useless and unnecessary, IMO. On all the units I wired, even many years ago, the branch circuits were GFCI protected with no equipotential grid installed and to this day, I’m not aware of one single incident where anyone has gotten so much as a tingle from contact with any of this equipment.
Like submitter says in his proposal, where is the data to support this requirement?