[Stoves] News (Uganda): Government official cautions on standards for cookstoves (aDALYs next?)

[Nikhil Desai]

Crispin:

So you think the $4.4 billion
<http://allafrica.com/stories/201709211154.html> a year
<http://allafrica.com/stories/201709211154.html> need SE4ALL ha identified
for cooking energy access has nothing to do with TC-285 standards for IWA
Tier 4 stoves (across all metrics)?

Rachel Kyte is going to the LPG for Development Summit tomorrow afternoon
<http://www.worldlpgforum2017.com/conference-programme/lpg-for-development-summit/63>
.

Let's not fool ourselves. The WHO meddling in the ISO affair had only one
purpose -- to make a fictitious health case for "clean fuels", the code
word for LPG. (I support LPG promotion, without the red herring of "health
benefits" quantified at individual or collective levels.)

The "implementation science" experts
<https://ehp.niehs.nih.gov/wp-content/uploads/125/1/EHP1018.alt.pdf> seem
ready to implement Tier 4 stoves with LPG tomorrow. They speak of "In
choosing among clean fuels or combinations (e.g., LPG, biogas, alcohol,
electricity, solar, tier 4 indoor emissions biomass stoves) ..." but you
know what they mean.

And they reveal the agenda behind WHO Indoor Air Quality Guidelines for
Solid Fuel Combustion and the Johnson-Chiang (2015) paper

"One of the key conclusions from the IAQG was that, despite impressive
exposure reductions of 50–80% in the best stove programs, in absolute terms
average post-intervention concentrations remained well above the WHO
interim target (35 μg/m3 annual mean)—that is, levels estimated to be
necessary to yield significant health improvements (WHO 2014). Based on the
limited data available at the time, clean fuel technologies [e.g., liquid
petroleum gas (LPG), biogas, electricity, ethanol] performed best overall,
but households using them also fell short of the target. Stove stacking
(using multiple stoves and fuels) and other pollution sources inside (e.g.,
kerosene lamps) and outside the home were likely explanations. These
findings suggest that* near exclusive, community-wide use of clean fuels is
needed to meet the PM2.5 guideline and to maximize health benefits*
(Johnson and Chiang 2015). " (emphasis added).

Nobody NEEDS to meet the WHO PM2.5 guideline for anything, leave alone in
poor people's homes; otherwise, the first thing to ban would be smoking,
dust, organic pathogens. There is no control of PM2.5 for household or
ambient air pollution anywhere in the developing world that I know of that
meets the elitist fancies of WHO "guidelines".

Nor is there an iota of evidence that "near exclusive, community-wide use
of clean fuels" will "maximize health benefits".

There has been no such evidence over the past 100 years, and I challenge
the authors of this fanciful rhetoric to show one. For a start, they could
explain the decline in Indian mortality rates in the last 15 years by
switch to "clean fuels" (even as coal-fired power grew by leaps and bounds
without any specific New Source emission standards by the Government of
India.)

WBT, TC-285 are all minor noises to keep advocates of solid fuel stoves
busy with fine-tuning their instruments lest they burst out in a symphony.
LPG advocates will have the last laugh. That is what GACC was meant to do,
and now it may wither away as the UN Foundation contracts wrap up.

Nikhil

PS: You and I may get some intellectual satisfaction that "If the metrics
of the IWA are definitively judged to be scientifically invalid, those
cannot be applied to anything. If there are conceptual errors invalidating
other claims, such as the ‘fuel consumption’ metric, that too is out the
window. What is left? You see, before a standard can be made a National
one, it is reviewed by experts at the national level. They might review the
literature and interview experts about the protocol, tiers, methods,
investigate anything they like. Following that, like China and India and
South Africa and Kenya, they would ignore it."

Many in this sport would have made their money and gone home laughing.

 ---------------

> On Sep 30, 2017, at 4:32 PM, Crispin Pemberton-Pigott <
crispinpigott at outlook.com> wrote:
>
> Dear Nikhil
>
>> You seem to be endorsing Ron Larson's view that the ISO TC-285 is just a
sport of "voluntary" gathering.
>
> On many levels it is. There is nothing coercive about the ISO process.
Most countries use ‘the ISO process’ which means the rules for creating a
Standard. Participants especially at the Working Group level have a vested
interest in the outcome. I got involved with stove standards because I
manufacture stoves. At the time I intended to manufacture paraffin stoves
and in fact one of my designs won a large sum in a competition for clean
burning stoves. That was shortly after I won 3 design awards for the Vesto
stove which I hoped would become a major export product. Times change,
however…
>
>> A standard may not be adopted or "Any standard can be applied (required)
in part, not in entirety, depending on the whim of the Minister
relevant."?? Sorry, things may not be that simple.
>
> Agreed it is not simple, but it is up to the Minister in nearly all
countries.
>
>> If you don't involve any government or multi-governmental actor in your
stove project, anything goes.
>
> Totally agree. That becomes a private contract. The CSI project is like
that except there is a government involved as well. It is ultimately a
government pilot, not a WB-as-NGO project.
>
> Re: the Government of Uganda when creating the National Mirror Committee
of TC-285; see Establishing and Running a National Mirror Committee  for
ISO/TC 285 –Uganda’s Experience<
https://share.ansi.org/Shared%20Documents/Standards%20Activities/International%20Standardization/Standards%20Alliance/Ghana%20NMC%20training/Est%20NMC%20TC%20285%20%20in%20Uganda.pdf>
(2014?). Or for Malawi, ISO MIRROR COMMITTEE IN MALAWI – THE BIG PICTURE<
https://share.ansi.org/Shared%20Documents/Standards%20Activities/International%20Standardization/Standards%20Alliance/SADC%20National%20Mirror%20Committee%20Training/Presentation%20on%20MALAWISs%20MIRROR%20COMMITTEES%20(1).pdf>
(2014?)
>
> In order to fully participate a country’s standards body needs a mirror
committee that will discuss things at the national level and make
recommendations to their body, which if approved, are passed along to the
ISO TC. These bodies frequently do no transfer all comments and suggestions
to the TC. It depends on what they want to say. In short there is politics
involved.
>
>> All the 45 participating and observing national members of TC-285 and
the international organizations that are liaison - including GACC - are
surely waiting for standards. Nationally adoptable, useful and enforceable
standards. (Enforcement may be limited only to certain procurements under
public control).
>
> And other countries that are not participants, I expect.
>
>> If a standard corresponding to a product cannot be enforced, it is
useless. Means of enforcement may vary, but I am assuming TC-285 is not
simply card-games-and-coffee club or billiards-and-beer bar for experts.
>
> Well, that is not really the whole picture. You can have voluntary
standards for decades. It depends on the market. If Uganda implemented a
national standard for all domestic stoves it would just create a massive
illegal market for products already being sold. It would be better to say
there is no point in making a standard compulsory unless there is a viable
enforcement mechanism and staff to do it. South Africa has only 4 people to
manage their kerosene stove market, worth about ZAR300m per year. That is
nearly hopeless.
>
>> Why was IWA 2011:12 constituted?
>
> At first blush, because the EPA wanted to create a set of tiers for
performance similar to the ones they have for other industries, and to
embed the WBT as the go-to test method before it was seriously challenged
in academic circles. Obviously it was already being challenged by the
private sector.
>
>> "Although progress has been made to establish interim fuel use,
emissions, and safety guidelines, further development and adoption of
voluntary industry consensus standards is required to provide transparency
to governments, donors, investors, and others regarding the potential
benefits of different solutions and to develop certification procedures,
performance benchmarks, and meaningful test infrastructure for the global
cookstove market." (emphasis added)  Cleaner Cooking Solutions to Achieve
Health, Climate, and Economic Cobenefits, Environ. Sci. Technol. 2013, 47,
3944−3952 dx.doi.org/10.1021/es304942e<http://dx.doi.org/10.1021/es304942e>
|
>
> The code word there is ‘fuel use’ which they meant to include ‘clean
fuels that are by definition ‘clean; and avoid ‘dirty fuels’ which they
said were coal and kerosene (both to be avoided). Biomass was only to be
tolerated in the interim because of a lack of choices.
>
>> What does "required" mean for "voluntary"? There is no "voluntary"
except that non-standard stoves will sell to non-standard cooks using
non-standard fuels in non-standard homes.
>
> Voluntary means it is not a requirement for production and marketing.
Required means needed for production and marketing. Enforced means there
are consequences for not meeting the requirements.
>
>> International trade in manufactured woodstoves is minuscule. There is no
"clean cooking sector" (LPG companies and electric utilities belong to
energy sector, not "cooking sector").
>
> I feel that is an important observation. The energy sector would agree
with it.
>
>> And I do not know any public health ministries at national or provincial
levels in developing countries interested in developing indoor air quality
standards, leave alone enforcing them.
>
> India might.
>
>> Why, Anenberg, et al. (2013) claimed that the June 2012 publication of
IWA 2011:12 "serves as interim guidelines for evaluating stove performance"
and GACC<
https://cleancookstoves.org/binary-data/ATTACHMENT/file/000/000/46-1.pdf>
also claims that the IWA 2011:12 is serving as a "guideline". I suppose
"guideline" was enough to force regional test centers and stove projects to
use the WBT and Tiers.
>
> The GACC required the use of their test method in order to get funding.
That was for a while, then they backed off putting it in writing, but in
practice it still meant the same thing. No WBT results, no money. Which
version? That is a very important question. The WBT in the IWA refers to
v4.1.2 which in Oct 2011 was really defective. The defects were pointed out
in the public comment stage prior to the meeting. It was not corrected (at
all) before the IWA was created. It was corrected several times afterwards,
with the addition of numerous new calculations and the generation of almost
all of the metrics named in the IWA (only one metric was generated by
v4.1.2 when it was said to be ‘not the only valid test methods’. I do not
see how a test method that doesn’t produce the metrics can be ‘valid’.
>
> Once the invalidity of the three low power metrics was known, then
published, there was a problem: the IWA required them, they had no logical
legitimacy, yes the WBT was edited to produce them. Which external, expert
reviewers approved the version of the WBT that was created to generate
those metrics, such review required by a resolution in the self-same IWA?
No wonder there is chaos.
>
>> IWA itself  says "This.. serves as a guideline for policy-makers..."
>
> Well, that is true whether the metrics are valid or not even generated by
the test method. It is ‘guidance’ of a sort.
>
>> If IWA and WHO "guidelines" are forced upon developing countries, why
does one need TC-285? Only if TC-285 "voluntary" standards are made
"required" by developing countries.
>
> That is a very good question. If the metrics of the IWA are definitively
judged to be scientifically invalid, those cannot be applied to anything.
If there are conceptual errors invalidating other claims, such as the ‘fuel
consumption’ metric, that too is out the window. What is left? You see,
before a standard can be made a National one, it is reviewed by experts at
the national level. They might review the literature and interview experts
about the protocol, tiers, methods, investigate anything they like.
Following that, like China and India and South Africa and Kenya, they would
ignore it.
>
>> …IWA "guidelines" have perpetrated an ideology of WBT as the golden
protocol and the IWA Tiers as golden Tiers; just ask GACC or Xavier.
>
> True, I guess.
>
>> Every standard - by whomever, enforced or not, governmental or private
-- has to be justified in reference to a purpose and a product.
>
> For private purposes that can be a very slim report.
>
>> With the ISO TC-285 exercise, I cannot tell what the purpose is. Whose
purpose is it? Who had the authority to decide a standard had to meet some
"climate" objective, a "deforestation" objective, a "health" objective, in
an inter-governmental forum, which is what TC-285 is?
>
> No idea. Whoever it is does not attend meetings, or is doing so from
behind a screen. One can always ‘try and be helpful’ but that doesn’t mean
there is transparency on every front.
>
>> I repeat - there is no service standard in a vacuum, only for specific
contexts and purposes of cooking.
>
> That is the big problem with cooking stoves standards for a nation –
which context constitutes a valid assessment framework, Without a
contextual test and target, there is no value save in the most abstract
sense. Product regulations are not supposed to end at abstract assessments.
Usually this is handled at the national level with a contextual framework,
and a contextual testing regimen. Obviously one size will not fit all, even
within one nation.
>
>> This is no sport.
>
> It is to some.
>
> Regards
> Crispin
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