Rich, 

I would think that you knew that this would generate discussion? 

One comment of Mr Hunter's that stood out in particular was the very
last . . . 
" . . . the only ones who benefit from the harmonic current emission
standard 
are the European electricity distributors.  They "avoid 
investments in bolstering their networks against the 
theoretical harmonics risk" at the cost of manufacturers 
and consumers." 

I would say that this senitment has been echoed by many compliance
engineers. 
But the comment is 'non-technical' . . . can anyone in this forum offer 
any 'technical' arguments that would a)Back-up such a statement as 
Mr. Hunter's or b) FAVOR the harmonic standard? 

I like to give the benefit of the doubt that the standard was created
based 
on sound technical evidence. 

John Juhasz 
Fiber Options 
Bohemia, NY 

-----Original Message----- 
From: Rich Nute [ mailto:ri...@sdd.hp.com <mailto:ri...@sdd.hp.com> ] 
Sent: Monday, February 26, 2001 12:11 PM 
To: emc-p...@majordomo.ieee.org 
Subject: Harmonics -- WSJ opinion. 


With thanks to Ed Jones... 

On Thusday, February 22, The Wall Street Journal Europe 
published an interesting opinion on the harmonic current 
emissions standard. 

The opinion is by Rob Hunter, a lawyer and Chairman of 
the Centre for the New Europe, a Brussels-based think 
tank. 

Mr. Hunter is quite critical of the EU "New Approach" 
process.  He says: 

    "In this procedure, the EU sets vague safety and 
    technical rules for everything from toys to super- 
    computers -- for example, toys shall be 'safe.'  The 
    EU then delegates to private standardization bodies 
    the drafting of detailed requirements explaining 
    what the delphic rules mean." 

    "The supposed advantage of this New Approach is 
    twofold.  For industry, it gets to write the detailed 
    rules applying to it.  For the Commission, the New 
    Approach frees it from a burdenom task; it also 
    allows the Commission to claim that it has nothing to 
    do with writing the standards, and hence cannot be 
    held responsible." 

    "All this sounds quite above-board.  It isn't." 

    "For one thing, the standards are not merelay a means 
    of proving compliance with the underlying legislation. 
    They actually determine the meaning of the law itself." 

Mr. Hunter discusses "...the way these standard-setting 
bodies can be gamed by industry insiders for advantage." 

Mr. Hunter goes on to show how the New Approach process 
allows the Commission to sidestep "...WTO laws prohibiting 
'mandatory' product measures that create 'unnecessary 
obstacles' to international trade." 

Mr. Hunter's opinion goes on to show that the only ones 
who benefit from the harmonic current emission standard 
are the European electricity distributors.  They "avoid 
investments in bolstering their networks against the 
theoretical harmonics risk" at the cost of manufacturers 
and consumers. 


Best regards, 
Rich 







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