With the exception of arrester with surge counter, were insulation from the tank is required, I personally prefer the transformer thank as ground path for surge arrester.
Flat bars or regular conductors (bare and insulate from the tank) are similar method intended as separate ground path.
The surge arrester ground connection using separate ground leads are the most common practice. However, many utilities, Industrial and IPP’s installations had been using the transformer tank or metallic support structure for ground path for surge arresters. (Ref 9.6, IEEE Std 80-2000)
Both methods are technical sound and proven good practical experiences. For surge arrester with direct leads conductor connected to the ground, still larger amount of current flow via the transformer thanks since surge arrester are also direct bolted to the transformer under the following conditions:
a- Power transformers are typically grounded in two points to the ground grid.
b- Surge arresters are mounted in welded steel brackets.
c- The ratio of the copper conductivity is near 10 times the steel conductivity, but steel thank surface and cross section exceed 10 time the cooper leads equivalent surface and cross section.
Beware that if you work outside utility environment, electrical inspector may enforce the use of separate ground leads. With the pressure to get the job done, I not sure if worth fighting for approval with the local inspector.