Yes, we all know that an RCD is USUALLY used as additional protection. But that still does not mean that it cannot be used on its OWN to provide ADS in a case where Zs is too high to use an OCPD in the usual way. Obviously we still need to provide overcurrent protection too... If you were not allowed to use an RCD to provide ADS, then what you going to do in a TT system??? How would you provide for ADS then?? The ONLY way you could normally provide ADS would be by using an RCD..john