​On August 26, 2019, NRECA submitted comments to FERC with other industry trade associations supporting 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.