Pages 9, and 10. The design will fail compliance with the latest ITU-T K.20, K.21 and K.45 Recommendations. These require for the rated impulse voltage test that the post-test resistance shall be at least 2 MΩ when measured at 500 V d.c. The recommended VxxE230P will cause non-compliance as it typically is 360 kΩ at 360 V. Note the ITU-T does NOT allow removal of surge protective components for this test. This 500 V value ensures that any surge protective component conduction will not occur in the event of power contact and compliance with the IEEE 802.3 500 V test. A higher voltage MOV needs to be specified to be compliant with these ITU-T Recommendations.
Pages 3, 8 and 10. Referencing IEC 61000-4-5:2005 is behind the times as it is withdrawn. Current version is IEC 61000-4-5:2014.