"And as for HARM... it might be the first FPS where the player fails and is constantly frustrated by his enemies. THAT would be different "

I think the difficulty is in who your enemies are and how you portray them. Almost all games try to stay clear from beating on the good guys, if only for the sake of sending the appropriate ethical message...GTA3 included. You spent most of your time working for and combating the criminal element. While you could go after humanity, there really was no point or challenge in it, so there was little reason to continue to do so. And as far as the law, the quickly escalating wanted level ensured you didn't spend most of your time beating them down.

My guess is they wouldn't let you meet Archer for the same reason you can never meet freeman....it wouldn't be prudent to allow you to kill the hero(ine)

However, that being said, i still think the game could be a lot of fun playing as HARM. Maybe it could be something where you are trying to increase your status and prestige despite the glowing ineptitude of your fellow villains (the boss sent us down here to watch the bee. AGH, the bee bit my bottom and now my bottom's big!)