I am doing a project where they have an environmental membrane under the slab and footings of several tilt-up commercial office buildings. This membrane as a side effect will act as an insulator between the building and the earth.

The E.E. has requested I install 2 ground rods outside the building, which I will do. I will also use the cold-water as a grounding electrode and bond building steel and the ufer.

One last thing, the cold water is just barely over 10' copper in the ground before switching to plastic.

Doing what I described seems to meet the code minimum, but I am just concerned this is not sufficient in practicality. Are there any other issues you guys can see?