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APPENDIX D
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People International
Electrotechnical Commission (IEC) |
Interests§
Internationally harmonized electro-technical standards §
Clear and clean electromagnetic environment §
Protect power lines §
Reduce electromagnetic interference §
Products immune to EM interference §
Member nations (national committees) |
Options§
Restructure TC77 -
Replace current members §
Rewrite IEC 61000-3-2 (currently doing so) §
Cancel standard §
Ensure TCs have equal representation §
Encourage utilization of “best practices” on a worldwide basis |
Objective
Criteria §
Scientific data instead of theory §
IBM’s survey §
Data from utilities in U.S./Europe §
Cost/benefit analysis §
IT industry papers: “A Manufacturer’s Perspective on Interpretive
and Other Issues with EN 61000‑3‑2” |
BATNA§
Status quo |
|
European
Commission (DGIII) |
§
Harmonized standards to ease flow of trade -
Interests of southern and northern utilities §
Maintain quality of European power lines §
Maintain high quality of European utilities §
Consumers §
Standards and regulations §
Success of EU industry §
Preventive action – may be a problem in the future |
§
Postpone implementation date of 1/1/2001 until IEC/ EN 61000-3-2 is
rewritten §
Implement EN61000-3-2 on 1/1/2001 §
Propose to Council to rewrite EMC Directive 89/336/EEC §
Encourage CENELEC to rewrite EN61000-3-2 §
Return to using IEC 555-2 |
§
Scientific Data: -
IBM’s survey -
Data from utilities in Europe/U.S. -
Data from IT manufacturers in Europe/U.S. -
Data gathered prior to and during use of IEC 555-2 in Europe §
Theory: may be a future problem so regulate now §
SLIM report §
IT industry papers: “A Manufacturer’s Perspective on Interpretive
and Other Issues with EN 61000‑3‑2” |
§
Request WTO dispute settlement panel §
Maintain status quo |
|
Council
of the European Union |
§
Interests of Europeans, companies – constituency §
Interests of EU companies §
Monitoring directorate generals §
Harmonized standards to ease flow of trade in EU/world §
Maintain an acceptable EM environment §
Uphold EMC Council Directive 89/336/EEC §
European citizens §
Maintaining position of authority |
§
Withdraw EMC Directive 89/336/EEC §
Alter the wording of EMC Directive: specifically change/remove the
offending paragraph in the preamble §
Postpone implementation date of 1/1/2001 until EN61000-3-2 is
rewritten §
Implement EN61000-3-2 on 1/1/2001 §
Rewrite EMC Directive 89/336/EEC §
Rewrite EN61000-3-2 |
§
Scientific Data: -
IBM’s survey -
Data from utilities in Europe/U.S. -
Data from IT manufacturers in Europe/U.S. -
Data gathered prior to and during use of IEC 555-2 in Europe §
Theory: may be a future problem so regulate now §
SLIM report IT
industry papers: “A Manufacturer’s Perspective on Interpretive and
Other Issues with EN 61000‑3‑2” |
§
Status quo |
|
CENELEC |
§
European harmonized electrotechnical standards §
IEC §
European utilities §
European manufacturers (less so than utilities) §
Regulated European electromagnetic environment §
Consumers who use electronic/electrical products and energy (power) §
European Commission §
Member companies |
§
Alter the IEC Standard §
Delay 4 more years implementation of
EN61000-3-2 §
Accept alteration of EMC Directive 89/336/EEC §
Do nothing §
Restructure committee CLC/TC 210 §
Support full implementation on 1/1/2001 |
§
Perform own electromagnetic environment tests/surveys §
Use existing evidence: IBM’s Study §
Theory: preemptive measures §
Evidence from studies in U.S. §
IT industry papers: “A Manufacturer’s Perspective on Interpretive
and Other Issues with EN 61000‑3‑2” |
§
Maintain status quo |
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USTR |
§
Economic Impact/costs to U.S. electronic/electrical industry §
Maintain flow of goods between U.S. and EU §
Reinforce the U.S./EU MRA §
Removal of technical barriers to trade §
Good relationship with EU – avoid another trade dispute (if
possible) §
Assist U.S. IT industry (a powerful industry) |
§
Fully support U.S. IT industry §
Take EU standard to WTO as a TBT §
Negotiate a mutually acceptable standard with DG Enterprise §
Do nothing §
Options that provide solutions to EU’s interests -
Offer technical assistance to improve Southern European utilities |
§
IBM’s European plant study §
Evidence of problems with EN61000-3-2 from engineers of major U.S.
companies §
Evidence from EMC European/American experts §
No theory: preemptive measures §
Information from U.S. utilities §
Data gathered prior to and during use of IEC 555-2 in Europe §
IT industry papers: “A Manufacturer’s Perspective on Interpretive
and Other Issues with EN 61000‑3‑2” §
WTO TBT Agreement |
§
Request WTO dispute settlement panel review |
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USDOC |
§
Removal of TBT’s for U.S. IT products §
American consumers §
Imports/Exports from/to EU §
Represent interests of U.S. IT manufacturers §
Strong U.S. economy §
Good economic relationship with EU §
Free trade §
Protect U.S. producers |
§
Do nothing §
Put pressure on DG Enterprise §
Take EN61000-3-2 to WTO dispute settlement body as a violation of TBT
Agreement §
Negotiate more acceptable EMC standard §
Impose trade sanctions §
Advocate for ANSI to draft a standard to limit EU exports to U.S. |
§
IBM’s European plant study §
Evidence of problems with EN61000-3-2 from engineers of major U.S.
companies §
Evidence from EMC European/American experts §
IT industry papers: “A Manufacturer’s Perspective on Interpretive
and Other Issues with EN 61000‑3‑2” §
No theory: preemptive measures §
Information from U.S. utilities §
Data gathered prior to and during use of IEC 555-2 in Europe §
WTO TBT Agreement |
§
Request WTO dispute settlement panel review |
ANSI/USNC
|
§
Acceptable electrotechnical standards from IEC §
Interests of U.S. electronic/electrical equipment industry §
Internationally harmonized standards §
Promoting U.S. standards and standards-setting procedures abroad §
Members interests |
§
Insist on restructuring of TC77 §
Withdraw from IEC §
Insist on equal representation in all TCs §
Appoint U.S. representatives from the IT companies and encourage to
attend TC77 and SC77A meetings §
Block revised EN 61000-3-2 from being published §
Ensure science based methods are used in drafting standards |
§
IBM’s European plant study §
Evidence of problems with EN61000-3-2 from engineers of major U.S.
companies §
Evidence from EMC European/American experts §
IT industry papers: “A Manufacturer’s Perspective on Interpretive
and Other Issues with EN 61000‑3‑2” §
No theory: preemptive measures §
Data gathered prior to and during use of IEC 555-2 in Europe §
Information from U.S. utilities |
§
Block IEC from publishing revised EN 61000-3-2 |