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Tony, thanks for your question. The answer is Yes. Based on the information provided in the question from October 10th, the sub-feed panel is installed remote from the renovated seawall, on a “Structure” built from Unistrut. Section 250.32(A) states: A Building(s) or Structure(s) supplied by a feeder are required to have grounding electrode system and grounding electrode conductor(s) to be installed per Part III of Article 250. The Unistrut Structure described in the original question, meets the Article 100 definition of a Structure (That which is built or constructed, other than equipment), therefore Section 250.32(A) would also apply.
Additionally, Section 250.32(B)(1) requires the feeder supplying this sub-feed panel to have a qualifying equipment grounding conductor as listed in Section 250.118 and sized in accordance with Table 250.122, accompanying the supply conductors.
So both a grounding electrode system and equipment grounding conductor are required for this particular feeder because the feeder is located at a structure not connected to the same building as the supplying the feeder.
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