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Strategy

In order to ensure that the IEC adopts a new harmonic emissions standard that fully accounts for the IT industry’s interests, the IT industry should pursue a comprehensive strategy both domestically and abroad. As detailed below, this strategy will involve legislative, media, and negotiation strategies. The Coalition on Harmonic Emission Issues (CHEI) will be formed to organize and implement the strategy. Immediate action is called for in order to beat the January 1, 2001 deadline for compliance with EN 61000-3-2.

Domestic Strategy  

CHEI will need to build support in the United States from the electronic/electrical industry, the U.S. Congress, the Office of the United States Trade Representative (USTR), and the U.S. Departments of Commerce and State.  

To be successful, CHEI will need to educate members of the electronic/electrical industry, gather objective data, and fund industry participation in the standards-setting technical committees. Each member will be expected to attend CHEI meetings and will keep industry members updated with information and progress reports. Additionally, members will be responsible for lobbying Congress; will be called upon to use their European offices to lobby the European Council; and will be expected to participate in the International Electrotechnical Commission Technical Committee (TC) 77 and its Sub-Committee (SC) 77A.   

CHEI should take two immediate steps. It should:  

  • issue a letter to all electronic/electrical equipment manufacturing companies to inform them about this issue and solicit industry support for the coalition. 

  • collect funds from members of the coalition and from outside sources to fund collection of harmonic feedback data in Europe. This data will be crucial for pushing the IEC and CENELEC to adopt a standard that doesn’t overestimate the problem.

 

U.S. Legislative Strategy

In order to build congressional support for a revision of EN 61000-3-2, individual coalition member companies should focus their attention on each of the congressional representatives in their districts. In addition to this grass-roots style approach, the coalition should send a letter to the entire House of Representatives. 

Objective: The goal of the U.S. legislative strategy is to persuade the U.S. Congress and the U.S. government to pressure the EU to revise or at least postpone the implementation of EN 61000-3-2.  This is important because EN 61000-3-2 in its current state poses a technical barrier to trade and creates unnecessary costs for the electronic/electrical industry.  

The first step is to prepare informational documents to present to the U.S. Congress, the Department of Commerce (DOC) and the Office of the United States Trade Representative (USTR). These documents should include the following:  

  • Lobbying packet, including white paper (Exhibit 7) and dear colleague letter (Exhibit 4).

  • Fact sheet on the costs of conforming to EN 61000-3-2.

  • USCCEMC Harmonics Position Paper (Exhibit 9).

  • Report on the importance of the European market to the U.S. electronics industry and especially the IT industry (Appendix A: Macroeconomic Analysis).

 

Lobbying Congress 

Each core member should send company representatives to visit their congressional representatives. They should:  

  • Meet the congressperson him/herself, if possible. Otherwise meet with a staff member.

  • Mail letters to each member of the House and the Senate.

  • Telephone congresspersons and staff members.

  • If at all possible, give testimony at a committee hearing (including hearings held by the House Ways and Means Subcommittee on Trade and the Senate Finance Committee). 

  • Garner support of a congressperson and persuade him/her to send letters to fellow congresspersons.

  • Convince a congressperson to prepare legislation to support full U.S. participation in international standards preparation.  

Key House members who should be lobbied include:  

F. James Sensenbrenner Jr. (R-9 WI), Chair of Science Committee  
Connie A. Morella (R-8 MD), Chair of Science Subcommittee on Technology  
Bill Archer (R-7 TX), Chair of Ways and Means Committee  
Philip M. Crane (R-8 IL), Chair of Ways and Means Subcommittee on Trade  
Charles H. Taylor (R-11 NC)  
Robert A. Weygand (D-19 FL)  
William Clay (D-1 MO)  
Zoe Lofgren (D-16 CA)  
Sam Farr (D-17 CA)  
Thomas M. Reynolds (R-27 NY)  
Louise Slaughter (D-28 NY)  
Stephanie Tubbs Jones (D-11 OH)  
Christopher Shays (R-4 CT)  
Steven T. Kuykendall (R-36 CA)  
Sherwood L. Boehlert (R-23 NY)  
Eddie Bernice Johnson (D-30 TX)

 

*Please see institutional analysis for tech-friendly rating of each member listed above.

 

Lobbying the DOC, DOS and USTR  

Letters (Exhibit 6) should be sent to U.S. Government officials in the Departments of Commerce and State, and the United States Trade Representative. These letters should be designed to solicit support for the IT industry’s position and request assistance in communicating with the European Union. These letters should contain the following: 

  • Brief background of the EN 61000-3-2 standard

  • Information on the costs of complying with the standard

  • Request for support

 

Letters should be sent to:  

  • Charles Ludolph, Deputy Assistant Secretary for Europe

  • Victoria A. Kader, Office European Union and Regional Affairs

  • Charles Ford, Ambassador, U.S. Mission to the EU

  • Catherine Novelli, Assistant USTR for Europe and the Mediterranean

  • Marc Grossman, Assistant Secreatary of State for European and Canadian Affairs  

After sending letters, a few of the coalition members should schedule meetings with officials at the Departments of Commerce and State, and the Office of the United States Trade Representative.  These meetings are essential because such meetings demonstrate the importance of the issue to the IT industry and give the coalition an opportunity get a sense of these officials’ views on the issue. 

The goal of the lobbying effort should be to ensure that the U.S. government will put pressure on the European Union to rewrite, or at least postpone implementing, EN 61000-3-2. Specifically, the coalition would like to see the Administration: 

  • Officially inform the European Union of U.S. industry concerns.  Charles Ford, the Ambassador to the European Union, is in an ideal position to spread the word about this issue within the EU government.

  • Apply pressure on counterparts in the European Commission to postpone implementation of EN 61000-3-2. 

  • Encourage CENELEC to support delayed implementation of EN 61000-3-2 and to adopt the rewritten version that the IEC is currently preparing.

  • Assign a U.S. representatives to IEC Subcommittee 77A to fully participate in the rewriting of IEC 61000-3-2.

  • If necessary, negotiate with DG Enterprise an acceptable solution to the problem.

 

Lobbying the United States National Committee (USNC)  

It should be quite easy to gain support from the USNC since the U.S. Coordinating Committee on Electromagnetic Compatibility (USCCEMC) has already taken a position that is fully consistent with the IT industry’s (and the coalition’s) own position. Support from USNC is crucial because USNC is responsible for appointing members of the IT/electronic/electrical industry to participate within the technical committees of the IEC. In order to ensure USNC support, the coalition should:

  • Send a letter (Exhibit 1) to Charles Zegers of USNC/ANSI in order to request support and ensure that USNC appoints IT/electronic/electrical equipment industry representatives to participate in TC77 and SC77A. 

  • Meet with representatives (Mr. Zegers) from the USNC in order to coordinate activities within the IEC. 

Media Strategy

 

Objective: The goal of the media strategy is to build support from within the industry itself and to inform industry members of both the seriousness of the EN 61000-3-2 issue and what is being done about it.  

Strategy: To accomplish this, the coalition should prepare op-eds, press releases, and advertisements to draw attention to the issue. Because the general public will not be very interested in this issue, the coalition should focus its efforts on industry-specific publications, not mainstream media outlets such as national and local newspapers (although publications like The Financial Times, The Wall Street Journal, and the Journal of Commerce should be considered). The coalition should also hold press conferences and debates between power-supply manufacturers and electronic/electrical product manufacturers.   

The media strategy should cover both the United States and the European Union (see below for European strategy). It should target:

  • Electronic/Electrical (specifically ITE) manufacturers

  • Electronic/Electrical Engineers

  • Investors in electronic/electrical companies

  • Knowledgeable citizens

  • U.S. government officials (of DOC, USTR)

  • Members of U.S. Congress  

Two key publications that should be given top priority include Electronics Weekly and Electronics Business:

  • Electronics Weekly printed at least two article in 1999 that opposed the IT industry’s goals.  These two articles were “Cross Wires” (February 10, 1999) and “Euro EMC Fudge” (March 24, 1999).  The IT industry needs to present itself in a better light to the readers of this publication.  This could be done by writing an op-ed piece or by placing an advertisement in the publication.

  • Electronics Business attracts over 52,000 management-level subscribers, so it is a great place to gain coverage of EN 61000-3-2.

Other publications that might be targeted include:  

Specialty Publications

  • Electronics Now

  • Electronic Business

  • Electronics Weekly

  • IEEE Publications
    -         IEEE Technology and Society Magazine
    -         IEEE Industry Applications Magazine
    -         IEEE Computer Applications in Power Magazine
    -         IT Professional Magazine
    -         IEEE EMC Society Newsletter

  •  Electronic News

  • Electronic Product Design

  • Electronics Times

  • EMC Engineering

  • Journal of Industry and Technology (Greentrees Publications)

  • Industrial Technology (New Wave Publishing Ltd.)

  • PC Magazine

Business Newspapers

  • The Wall Street Journal

  • The Financial Times

California Publications

  • San Jose Mercury News (Silicon Valley) (Business Section)

  • San Francisco Chronicler (Business Section)

  • Los Angeles Times (Business Section)

 

Washington, DC

  • Washington Post

 

Specifically, the coalition should:  

  • Write op-ed pieces (prepared by technicians and policy experts) and letters to the editors of key industry magazines listed above.

  • Prepare an op-ed piece (Exhibit 7) for U.S. newspapers such as the Wall Street Journal, San Jose Mercury News, the Journal of Commerce, and the Washington Post

  • Meet with newspaper and magazine reporters in order to persuade them to write articles that articulate the IT industry position.

  • Issue press releases on coalition-member activities to industry publications and post them on coalition members’ web sites.

  • Issue press release with results of the coalition’s survey on harmonic problems in the EU.

  • Buy advertising space in key industry publications.

   

European Union Strategy

 

The Coalition on Harmonic Emission Issues should establish a working party in the European Union to carry out the European legislative and media strategies.  The members of this group will come from U.S. companies with subsidiaries in Europe, European companies, and from European and American trade associations.   

Coalition Building  

A key first step is to build a coalition that includes European companies and trade associations. It will be essential to have European industry support for sending letters to and meeting with members of the European Commission. European companies will also be helpful if the debate comes down to European utilities versus the American and European electronic/electrical equipment manufacturers. 

 

Key U.S. companies and trade associations with branch offices and subsidiaries in Europe include:

American Companies

Xerox
IBM  
Lucent  
Hewlett-Packard  

American Trade Associations

American Electronics Association Europe (AEA Europe)  
Telecommunications Industry Association  

American Government Offices

United States Department of Commerce Foreign Commercial Service  
United States Embassy

 

Transatlantic Business Dialogue (TABD)

Group I - Standards & Regulatory Policy
EU Chair: Hakan Mogren, Deputy Chairman of Astra Zaneca
U.S. Chair: Fred Smith, President and CEO of FEDEX  

Key European companies and trade associations include:  

European Companies

Thomson Corporation  
Royal Philips Electronics  
Siemens  
Heywood Willliams Ltd.  
Olivetti Lexikon  

European Trade Association

European Information and Communications Technology Industries Association (EICTA)    

 

Short Run Strategy  

Working party members will lobby the European Commission to postpone implementation of EN 61000-3-2 indefinitely or until the IEC rewrites the standard and CENELEC adopts the new version. The working party should immediately:

  • Send letters (Exhibit 3) to DG Enterprise calling for it to postpone implementation of EN 61000-3-2 for another two to four years, or until the IEC rewrites the standard. 

  • Send letters to (Exhibit 2) to CENELEC seeking its support for postponement.

  • Encourage the TransAtlantic Business Dialogue (TABD) to push concerns about the EMC regulations, specifically about the low frequency emissions standard EN 61000-3-2, into its dialogue with the EU government on the issue of technical barriers to trade. The coalition should also solicit the support of the TABD Working Group I – Standards and Regulatory Policy.  This group is working towards an “approved once, accepted everywhere” regulatory model and has worked out detailed action plans for removing obstacles associated with duplicative standards, testing and certification procedures.

  • Send letters to CENELEC (Exhibit 2) expressing support of committee TLC/TC 210’s decision to review EN 61000-3-2. The committee should also be encouraged to support postponement of the implementation deadline for the current version of EN 61000-3-2.  

Next, the working party should schedule meetings with key members of the Commission. At these meetings, the following informational documents should be left behind: 

  • White paper (Exhibit 8)

  • Fact sheet

  • United States National Committee: Powerline Harmonics Position Paper (Exhibit 9)

  • Costs evaluation

  • Results of the IBM survey of European plants  

Finally, the USNC should begin lobbying the European National Committees for their support in rewriting EN 61000-3-2. The Danish National Committee has already shown its support regarding other EMC regulations so this would be a good place to begin lobbying efforts.  

Long Run Strategy  

For the long run, the working party should ensure that IT industry representatives participate on a regular basis in CENELEC Committee CLC/TC 210 as it reconsiders and revises EN 61000-3-2 and considers other relevant standards. 

Because CENELEC committees are closed to foreign national participation, it will be up to citizens of the EU to participate in these committees. However, since CENELEC originally adopted the standard whole from the IEC, European representatives from the IT industry should encourage CENELEC to participate in SC77A as it revises IEC 61000-3-2 and then to adopt the revised-version once it is finished.

   

Media Strategy

The media strategy should cover the entire European Union but give particular attention to Germany, France and the United Kingdom. Targets of the media strategy are: 

  • European Union Government (Commission)

  • CENELEC

  • European utilities

  • European electronic/electrical equipment manufacturers

  • European businesses

  • European consumers

  • the public

  • electronics/IT industry

  • electronic/electrical engineers

  Specific media outlets that should be used include: 

Europe:

  • Electric Utilities

  • Power Plays

  • Financial Times

Germany:

  • Ausgewahlte Zahlen zur Energiewirtschaft

  • Der Elektromeister + Deutsches Eletrohandwerk

  • Elektro Wirtschaff 

France:

  • Electronique Techniques et Industries

  • Industries Electriques et electroniques

  • Science Magazine

United Kingdom:

  • Electrical Wholesaling

The CHEI working group will be responsible for both monitoring domestic and international media and keeping the CHEI in the U.S. informed of activities in support of and against its goals. 

Specific actions the working party should take are to:  

  • Send op-eds pieces to the publications listed above.

  • Meet with editorial boards of these publications in order to inform them of the current situation, with the goal of gaining their support (i.e. write advocacy pieces).

  • Offer to be interviewed on this issue and/or provide information to writers/reporters of above publications.

  • Issue press releases of relevant activities.

  • Issue press release on results of survey currently being conducted in Europe.

  • Buy advertising space in selected publications.

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