I agree George. I am just afraid you will get tangled up in the mythology that got this guy's panties in a wad about the "clean ground" in the first place. You may hear the definition of "with" thrown around.
You can certainly toss back that the inside of the raceway is a "cleaner" environment than the outside but that is probably beyond the scope of your job.
Is this ground going to be protecting the case of metal equipment or is it just for his electronics in an insulated box. That could be the deciding factor about whether it requires the mechanical protection the raceway provides.
