Jon,
I have always rested on Article 200, which although titled "Use and Identification of Grounded Conductors", does not address conductors used for grounding purposes, and therefore would not consider conductors used for connecting Grounded Conductors to ground as grounded conductors, although these indeed are conductors which are connected to ground.

If you followed that, try this...

I can not consider that which is, without considering that by which, which is, is!

As far as 310.12(C), (grounded AND grounding conductors)good call!