[Stoves] Aprovecho's ISO certificates

[Nikhil Desai]

Crispin:

Thank you for correcting my error. Even with my arithmetic, I recognize "
If you need a 1 ppm CO2 instrument, getting a 100 ppm device will not do.."
Back in 1997, I learned that the CEMs (continuous emission monitors) atop
coal power plant stacks were not reliable enough and could not be
calibrated well.

">Tiers for PM2.5 were changed from the Lima Consensus to IWA without



Word(s) missing."


*** I had meant to end with "explanation". Which you have provided aplenty.

HOWEVER, you fall in the trap EPA wishes for all "science" types to fall
when you say "An emission rate has meaning, a % reduction does not because
there is no universal baseline stove, not 3 stone fire." and "That is
meaningless because there is no such thing as a stove that ‘reduces IAP by
95%’. "

I will now take this up in the other thread because it has nothing to do
with Aprovecho. The summary point is that from a policy perspective, %
reduction is as good a vehicle as an average emission rate. It depends on
the service standard, the objective, and available means. ***

+++++++++++++

Passions can be whipped up by ideology of "clean energy", "clean fuel" -
protecting  the virginity of Mother Earth in pursuit of zero DALYs -
turning scientists into ideologues of absolutism. ("No stacking" is one
such example, "truly health protective" is another. )

I go back to my days of pollution control policies for large stationary
sources in the US and other OECD countries, Taiwan, and South Korea. Fuel
bans, industrial relocation, tall chimneys, % emission reduction, annual
and weakly average with short-term spikes for emissions, all come into
play.

To recite the mantra - "context means everything."


GACC has been turned from an Alliance for Clean Cookstoves to an Advocate
for Clean Fuels by EPA/Berkeley/WHO shenanigans. Connect the dots. History
will judge whether this was a matter of crookedness or incentives.

What you have written in your post is of huge consequence. WBT, LEMS are
sideshows or smoke-screens; what is really going on is a campaign - of
crookedness or incentives and ignorance - to bring the whole GACC bandwagon
to the point it is now -- to get Rachel Kyte to the podium in New Delhi and
sing the praises of LPG as "clean fuel".

I happen to know something about politics and bureaucracies, about
incentives and integrity. Back ten years ago, I would have written a speech
for Rachel Kyte in support of LPG (except that LPG prices spiked after my
first draft concept in 2005 in support of LPG) and as late as five years
ago I advanced an idea for India to decontrol kerosene, LPG prices and
introduce capital subsidies for solar lanterns, LPG stoves and pressure
cookers, at $100/household, continuing on to "advanced" biomass stoves as
proven.

But I wouldn't have accepted for a minute the charade of HAPIT and aDALYs,
and Kirk Smith's claims of "no stacking" and "truly health protective."
(His incentives are different.)

Anyway,
Nikhil




On Thu, Oct 19, 2017 at 2:46 PM, Crispin Pemberton-Pigott <
crispinpigott at outlook.com> wrote:

> Dear Nikhil
>
>
>
> *>*I understood test method and equipment are different. My concern with
> both is about PM2.5 claims.
>
> OK.
>
>
>   Any IAP calculation has to be based on some model of dispersion which
> has no meaning outside the context of use. It is speculative and cannot be
> used for product regulation, trade or procurement.
>
>
>
> >IWA by contrast had five Tiers and for PM2.5, Tier 3 cut-off was set at
> =< 8 mg/min and Tier 4 at =< 2 mg/min.
>
>
>
> That is a rate which can be measured, but suffers from the error of
> thinking that all stoves are one size which obviously they are not. A large
> domestic stove meeting that Tier 4 emission rate would have to be far
> cleaner per MJ delivered than a small stove with the same emission rate.
> Several EPA and state regulations are trapped in the same paradigm. Do they
> permit a home to emit a certain mass total, a mass per minute in use? And
> total per kg burned? A total per delivered (useful) MJ of heat? Selecting
> one rating creates problems. Which type of problem do you want?
>
>
> >Then again, another rating was in terms of power levels - "High Power PM"
> Tier 4 was =< 41 mg/MJd and "Low Power PM" Tier 4 was =< 1 mg/min/L.
>
> Calculating from the max emission per MJ delivered and comparing it with
> the max mass that can be emitted per unit time gives a performance curve.
> If you fall above that curve, fail, below, pass. This only applies to the
> high power metric.
>
>
>
> The Low power metric is not valid (has no scientific basis) because the
> emissions are divided by the number of litres ‘simmered’ and there is no
> causal relationship between that number and the emissions (See Zhang
> <http://ieeexplore.ieee.org/document/6827753/?reload=true&arnumber=6827753&sortType%3Dasc_p_Sequence%26filter%3DAND(p_IS_Number:6827745)>,
> Y et al 2014). In effect the emission rate is divided by a random number.
>
>
>
> >There is some chicanery going on here - from concentration (in Lima) to
> per MJd and per min/L. Sure, there is a cooking cycle defined somewhere
> that can link these three with the use of some kitchen circulation model.
>
>
>
> The performance of the stove is rated independently of the kitchen. Again,
> there is no causal relationship between a stove and a kitchen. You could
> put any stove in any kitchen. Any claim about IAP and a stove is puffery.
> There is no universal ‘indoors’ and as any kitchen of a given size could
> have any ventilation rate, there is nothing real about the result of a
> model. The emission rate is the only valid number and as any other number
> is speculative, one is restricted to using the emission rate. The IAP claim
> is no more than a mechanical change to the emission rate by mathematical
> means.
>
>
> >That is, I am not prepared to buy the argument that this was just
> over-simplification so that emission rate and concentrations can be linked
> via a model of standardized cooking cycle, standardized fuel, standardized
> kitchen volume and airflow, mobility. Rather, it is a deceit of
> environmental health zealots, namely EPA and its contractors.
>
>
>
> That is possible. The claim for a health response is the problem. Even if
> one could prove that in a certain region kitchens have typical ventilation
> rates, egress points for smoke, volume and weather, that doesn’t fill the
> gap between a speculative exposure and an equally speculative health impact
> from that speculative exposure. It has reached the point of being silly.
>
>
> >While you, Ron and many others on the List were arguing about efficiency,
> EPA and WHO (who had some money from DfID via its "Evidence Base" contract
> with GACC) were concocting PM2.5 emission ratings in such a way as to drive
> solid fuel stoves out of market.
>
>
>
> It seems so.
>
>
> >That is, the whole purpose of TC-285 and WHO grandstanding about
> Guidelines for Household Fuel Combustion was NOT to galvanize market for
> BioLite, EnviroFit, or Paul Anderson's TLUD stoves - any biomass stoves at
> all - but to give Kirk Smith the chance to argue that no biomass stove was
> "truly health protective".
>
> That also seems so. There is a consistent pattern of making such claims
> while jerrymandering the targets and test methods to produce results that
> are always a ‘fail’ for most stoves. Obviously the key ingredient is the
> ‘single box Berkeley model of dispersion and concentration’ contained in
> the WHO calculations. The text of that same document says that the model is
> not realistic. I don’t see how you can conclude that an emissions rate is
> ‘unsafe’ if the exposure model is unrealistic.
>
>
> >On the basis of emission rates or concentrations, Prof. Smith has never
> been explicit.
>
>
>
> Those working under him and guided by him have been. The WHO documentation
> makes explicit claims.
>
>
>
> >But if he claims concentrations, then he is moving away from his ideology
> of "dirty cooking fuels"; there are other pollutants in household and
> ambient air.
>
>
>
> Well, the model is incomplete, eh?
>
>
>
> >His and Ajay's HAPIT model runs on concentrations before and during an
> intervention but adjusts for concentrations other than cooking fuel, even
> chimneys. But only on some impractically high bar such as =< 2 mg/min the
> argument that no solid fuel is ever clean enough becomes sustainable.
>
> India lists LPG as having 8 mg/MJ delivered. There are several wood stoves
> and coal stoves that are below that number. If an LPG stove has a rate of 2
> mg/minute, then it is equivalent to delivering 2/8 = 0.25 MJ/minute.
> 250,000 J/minute is 4,167 Watts delivered. That is a heck of a big stove.
> At an efficiency of 50%, it is a, 8.3 kW fire. 2 mg/minute is easily
> achieved by kerosene stoves, a supposedly ‘dirty fuel’ as Kirk and GACC
> would have it. All it has to be is small enough.
>
>
>
> >Your mention of Aprovecho LEMS not being able to score at Tier 3.5 made
> me connect the dots.
>
> Caution here: I do not know what the current LOQ is for the latest LEMS.
> Maybe someone does, but I haven’t seen it.
>
>
> >On the one hand, we have EPA Final Rule
> <https://www.gpo.gov/fdsys/pkg/FR-2015-03-16/pdf/FR-2015-03-16.pdf)> on
> residential wood heaters dated 16 March 2015, three  years after IWA - see
> p. 13672 - with PM2.5 emission limit maximum 2g/hr = 3.3 m/min five years
> after the rule became effective, i.e., 2020.
>
>
>
> This is for a stove with a chimney. If you combine the leakage that Kirk
> anticipates from the stove (25%) then we have something with which to make
> comparisons. Note that there is no efficiency in that target. 2000 mg per
> hr is 33 mg/minute. Multiple wood and pellet stoves can reach that,
> depending on the test sequence. Let’s leak 25% of that into a room; = 8.33
> mg/minute.
>
>
>
> Well that is a heck of a lot more than 2 mg/minute. It is higher by a
> factor of 4. So where do stoves permitted in the US (the new regs from
> 2021) fit on the list of tiers?
>
>
>
> Why would the EPA be punting an emission rate for poor developing
> countries that is 1/4 the rate permitted in the USA?
>
>
> >The 3.3 mg/min emission rate for PM is between Tiers 3 and 4 of IWA.
>
>
>
> Well, it is 2 g * 1000 = 2000 mg / 60 minutes = 33.33 mg/minute, not 3.3.
> This is IWA Tier 1.
>
>
> >Is there any conceivable rationale that US would have a higher
> permissible PM2.5 emission rates from heating stoves - with air-tight
> insulation - than poor people's cookstoves out in the open or with doors
> and windows open except in very cold areas and during heavy monsoons?
>
>
>
> Nope.
>
>
> >In short, what you think is my misunderstanding may have a grain of truth
> by insight. It is not necessarily the case that "The Tier 4 target for the
> IWA was supposedly based on work by the WHO."
>
>
>
> Well that is why I questioned it. I got a reply that it was all explained
> in the information supplied for the IWA, but looking closely there is no
> ‘there’ there.
>
>
>
> >WHO did not come up with HFC Guidelines until 2014, more than two years
> after the IWA.
>
>
>
> Yup.
>
>
>
> >Besides, where in the world did WHO come up with emission rates ->
> concentration model but for BAMG/EPA?
>
> Bingo.
>
>
> >I have known EPA shenanigans over the decades. Scientist bureaucrats are
> worse than bureaucratic scientists; ideology corrupts.
>
> Dunno. Not in my lab…
>
>
> >Aprovecho equipment, procedures and "certification" merit independent
> audit if any stovemaker relies on such and risks reputation or money. On
> the other hand, businesses ought to be able to take EPA to court for poking
> its nose where it does not belong. I cannot think of any Congressional
> appropriation rationalized in terms of international standards for
> cookstoves. GACC and ANSI have been carrying a secret business on dubious
> legal grounds; it is not clear if Aprovecho is independent of these moves.
>
>
>
> No idea. If you use any equipment, you should find out what it is able to
> rate and what not. Similarly, taking a test protocol as ‘valid’ without
> checking it is pretty wonky as a policy for spending money. The WBT is used
> on the basis of *argumentum populum*.
>



>  It happens that the EPA certified equipment has a 10 ppm resolution.
> 0.01%. Getting a 0.001% instrument means it is well inside the service
> requirement. 0.02% is not. So you buy what is needed.
>
>
>
> Regards
>
> Crispin
>
>
>
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