You're correct that this isn't a straightforward NEC issue and likely relies on the specific Oregon Electrical Specialty Code amendments and potentially elevator-specific codes. Let's break this down

Why EMT Can Be Problematic as a Sole Ground in Elevator Applications:
Vibration and Movement

Elevators inherently vibrate and move. Over time, the connections on EMT can loosen, increasing resistance and compromising the ground path. While EMT can be a grounding path, relying solely on it in a continuously vibrating application is risky.

Safety

Elevators are complex, and a reliable ground path is critical for safety. A failure in the ground connection could lead to dangerous conditions for maintenance personnel or passengers.

Specific Elevator Requirements

Many elevator codes and standards (beyond the general electrical code) emphasize a dedicated grounding conductor due to the critical nature of the equipment.

Oregon Amendments (Key to Your Issue)



Flexible Metal Conduit (FMC) Grounding

The amendment you mention regarding FMC is extremely important. Most jurisdictions do require a separate grounding conductor to be run inside flexible metal conduit. FMC is never considered an adequate equipment grounding conductor on its own, due to its construction.

Check for Additional Elevator Amendments

Oregon (and many states) often adopts the NEC with amendments.

The key is to find any specific amendments that address elevator wiring. Look for sections within the Oregon Electrical Specialty Code related to "Elevators, Dumbwaiters, Escalators, Moving Walks, Wheelchair Lifts, and Stairway Chairlifts." These sections might contain stricter grounding requirements than the general NEC. This is where your answer likely lies.NEC Considerations (but secondary to Oregon Amendments)



NEC 250.118 (Equipment Grounding Conductors)

This section lists acceptable types of equipment grounding conductors. While EMT is generally listed as acceptable under normal conditions, it also caveats this with requirements for proper connections and that it must be "installed in accordance with 300.10 and 300.
12." These sections address mechanical continuity and integrity.

NEC 250.4(A)(5) (Effective Ground-Fault Current Path)

The NEC emphasizes that the grounding path must be "permanent and continuous" and have "sufficient capacity to conduct safely any fault current likely to be imposed on it." The Oregon authority might be concerned about EMT meeting this requirement in a vibrating elevator environment.

NEC 620 Elevators, dumbwaiters, escalators, moving walks, wheelchair lifts, and stairway chairlifts

Take a look to see if this section refers back to general requirements for grounding or if it details any specific elevator grounding requirements.

Here's What to Do


Consult the Oregon Electrical Specialty Code

Thoroughly review the entire code, especially sections related to elevators. Look for any specific grounding requirements. Pay close attention to any definitions or interpretations related to grounding in elevator applications.2.

Talk to the Authority Having Jurisdiction (AHJ)

This is the most important step. Contact the inspector or electrical authority who is requiring the change. Politely ask for the specific code section they are referencing. Understanding their reasoning will help you comply.3.

Review Elevator-Specific Standards (if applicable)

Some installations might need to comply with additional elevator-specific standards (e.g., ASME A17.1). These standards could have grounding requirements beyond the electrical code.
4.

Run a Dedicated Ground Wire

In many elevator installations, the safest and most reliable approach is to run a separate, insulated equipment grounding conductor (EGC) alongside the power conductors inside the EMT. This ensures a dedicated, low-impedance ground path.

Regarding the 120V Pump

The 120V pump could be for a sump pump in the elevator pit (to remove water) or, more commonly, a hydraulic pump for the elevator itself (if it's a hydraulic elevator). Regardless, it needs to be properly grounded, and the same grounding rules will apply.

In summary: The issue isn't likely a general NEC violation but a specific interpretation or amendment within the Oregon Electrical Specialty Code regarding elevator wiring. Contact the AHJ to understand their requirements, and be prepared to install a dedicated ground wire inside the EMT. Good luck! Flag for review