August 26, 2019, NRECA submitted comments to FERC with other industry trade
with no modifications FERC approval of the NERC revised Reliability
Standard TPL-001-5, Transmission System Planning Performance Requirements,
which addresses the non-operation of non-redundant primary protection systems.
The comments oppose, however, FERC’s proposal to direct NERC to modify the
standard to require corrective action plans for protection systems where
non-redundant elements fail in combination with a three-phase fault if planning
studies indicate potential cascading.