I have two thoughts;
1. Any ground potential rise, step potentials and touch potentials on the 44 kV side will be transferred to the building bonded surfaces.
Think lightning strikes or a primary line contacting the steel work.
2. I understand that the grounding rules have changed or are changing in Canada.
I didn't purchase the latest edition of the code, but enough questions have come up that I was about to order a current code book.
Then I found out that the 2021 Edition will be out in early January and decided I can wait a couple of months longer and get the latest edition.
Check the current code and talk to the AHJ.
Bill
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"Why not the best?"
Jimmy Carter