[Stoves] Thought on TC 285 process

Wed Apr 26 01:56:42 CDT 2017

This is in response to Ron's 3 April post below. I will have more to say on TC 285 objectives - not process, which Ron knows about and I don't - later on. 

First, I wonder what is meant by the assertion "Standards are not effective until they are complete and published."

In the legal sense, this is valid up to a point. Who is to publish and where, how? The EPA and ANSI have no jurisdiction or mandate to do anything with cookstoves in any country, including their own. I for one don't see any basis under US law authorizing EPA meddling here. For any other country, including but not limited to the TC 285 member countries, it will have to publish the standards under its own laws for them to be effective, i. e., enforceable. Then it's problematic whether countries that cannot have enough police enforcement, or enforcement of chemical spills, building safety or power plant regulations will have enough customs inspectors for imported cookstoves or university children volunteering to be stove operations certifiers. 

I happen to have some familiarity with ISO processes as relates to another class of consumer products offered to the poor in the developing countries - the so-called Solar Home Systems (about 23 years ago) and Pico-PV lanterns and phone chargers (about 8-12 years ago).  In one case, standards did help catalyze a market in some countries under foreign aid projects; the other has been less shining. 

The technology exists. The standards exist. There is no basic variation in the service standard or the public policy objective across regions. There are, however, options to solar - the grid or the generator or battery-charging by them. 

The net result of some 50 years of research and advocacy for PV lighting for the poor, after the standards? A lot of PV debris around the world - not many systems in working conditions. (I stopped keeping the count ten years ago because REN21 started doing that. I stopped being their reviewer but might contribute this coming year).

Past failures in a different technology are no guarantee of future failures. Still, it is worth going back to check the validity of the primary assumption behind TC 285 exercise - that somehow the publication, adoption and enforcement of stove standards will change anything, at least as far as solid fuels are concerned. 

People can be forced or incentivized to make assumptions. I for one take the Tier 4 proposed target for hourly PM 2.5 emission rate as WHO's sexy kiss of death for solid fuel cookstoves for the poor. It is a promise or life, served in a poison pill. 

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I am sympathetic to those who have burnt kilo liters of midnight oil designing and testing biomass stoves, boiling waters and inhaling smokes. Even when the TC 285 standards are legally effective and enforced, I wonder whether they would be effective in achieving the clients' objectives. 

I have very little confidence that ISO standards for specific tiers will mean much to anybody. Without a service standard, lab testing protocols mean nothing, and without an objective (or more), performance metrics mean nothing. 

I repeat - boiling water is not a service standard. And emission rates or fuel efficiency may not be - perhaps are not - relevant to other objectives of the cook. 

Waving arms has to stop when we land on earth. 

There is no basis for assuming that fuel  efficiency and PM 2.5 hourly average emission rates have predictable outcomes to be relevant across all contexts. Or that these metrics have controlling influence on changing stoves. 

The tragedy of the poor is that presumptively well-meaning outsiders come to disturb the intimate parts of their life and then, based on some anecdotes and unrepresentative measurements, publish thousands of pages of data and theories that have provably led to failures in mass adoption of new biomass stoves. 

TC 285 has been a US driven fantasy, with no justification for WHO interference - in the form of SFU Guidelines or throwing in ludicrous air models and Kirk Smith's theology of "truly health protective" emission rates (instead of exposures).

Oh, well. The Implementation Scientists are ready to roll with LPG and electricity - both of which I do favor, next to eating out and home deliveries - because we lost quite a bit of ground arguing about WBT and protecting, praying to holy cows, taking, praising all their gifts. Thank God, LPG prices are low enough to make India the largest LPG importer (followed by China and Japan).

When and how did the biomass cookstove business become so dominated by the EPA? Paul, Crispin, Tom, Ron?? This is not how I remember about 12 years ago, after which I fell off the cliff. 

I suspect this whole ISO affair - publish international standards, force or incentivize miracle clean cookstoves to reach 100 million households by 2020 - is PCIA/EPA legacy thrust upon the GACC CEO. She was fed an utterly wrong script and may find it difficult to defend not just TC 285 operations but the underlying assumption that international standards would have any quick benefits for anybody. 

EPA may be forced to shut down coming Friday unless Trump and the Congress can reach an agreement on spending authority for the next 153 days. 

Nikhil 
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Nikhil Desai
(India +91) 909 995 2080
Skype: nikhildesai888

> On Mon, Apr 3, 2017 at 9:55 PM, Ronal W. Larson <rongretlarson at comcast.net> wrote:
> List:
>  
>             As a fledgling member of the ANSI part of the ongoing TC 285 process I was able to listen in 6 days ago as representatives for several dozen countries commented on inputs from a smaller number of recent country deliberations (on which I had also listened earlier - only to the US discussion).  The rules of the ISO process preclude my/anyone giving out details;  the rules say we must wait for a final consensus approved document.  But I think it is OK for someone like myself who has not influenced the document in any way to say that I have been impressed with the entire process.  The stove community should be proud that a huge amount of volunteer effort has been invested in producing about 7 different documents- most nearing completion.
>  
>             Here is one slide from last week that summarizes where I am at for this forthcoming standard: .  I think ones like this and similar slides will be available soon on the ETHOS website.
> 
> 	In sum - there has been a great deal of good work that  I urge we get behind.
> Ron

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