Even the IAEI, when they presented this application to three of it's own experts, got four answers!
Codewise, the guy can probably get away wit only a ground rod, treating the feeder as if it were a separate service.
I am something of a simpleton, and like to consider the "service" to be where the PoCo drops in, with everything from that point to be part of the same system. But I can see where the code might not limit me to that approach.
