[Stoves] A policy perspective on ISO DIS 19867-1 - Harmonized laboratory test protocols Part 1

[Nikhil Desai]

Friends, List, cc'd:

It was a little over a year ago that Cecil said something about the ISO
TC-285 exercise as putting the cart before the horse (or which is how I
interpreted it).

It was also around then that Xavier began an advocacy action to ask GACC to
stop supporting WBT, reminding me of my decades-old gripes with water
boilers of the labs.

The ISO process is opaque, but the Draft International Standard (DIS)
19867-1 Part I has been available on ISO website for some time. I don't
know if there is any process for public input, but I wanted to wait until
after 20 October 2017, when this DIS was to have been voted by, I
suppose, the 45 member states.
The DIS may change, and other draft products from TC-285 may become
available. I offer my comments below on the version I got from ISO. I
cannot share particular texts, but would be glad to share details of my
policy perspective and implications for policy treatment of specific
sections of the DIS text.

Here I pretend to advise a government with many agenda, goals, interests
and conflicts.  I am addressing a hypothetical policy-maker responsible for
planning and budgeting for short- to long-term (a year to 15 years, in what
used to be called “perspective planning”). The term “planning” is
deliberately left vague and reflects economic as well as environmental
planning at various levels of government, recognizing that government
decisions also influence private plans and budgets. To borrow from a
one-time US government cabinet member, “The job of budgeting is to separate
weak claims from weak claimants.”

It is not a "Draft Confidential Memorandum",  just that any such writing
would start out as such. I also hope to refine and revise these arguments
on my own and respond to criticism and advice from all sources.

I consider it an affront to human rights that cook-free performance metrics
and lab-testing protocols are formulated by a secret international cabal -
with so-called "international organizations" as UN Foundation and Gold
Standard Foundation permitted as "liaison" members but allowed to intervene
and control the process on behalf of the US EPA. This is a charade of
science. Ignorance and private incentives need to be exposed.

Comments?

Nikhil
-----------




*ISO/DIS 19867-1 Clean Cookstoves and clean cooking solutions – Harmonized
laboratory test protocols *




*Part 1: Standard test sequence for emissions and performance, safety and
durability (2017, no particular date, apparently before July)*


*Summary **Draft Confidential Memorandum for a policy decision with advice
– Reject. *

  I accept that the TC has based its work on these metrics and intends to
develop desired target slots in Tiers along the lines of ISO IWA 2012:11.
There is no evidentiary basis to claim these metrics are necessary or
sufficient across all countries. Published literature is woefully
inadequate in terms of its coverage over populations and periods, and
claims that “clean cooking” confers empowerment of women, reduces
deforestation, protects global climate, or avoids particular diseases and
deaths are no more than third-rate propaganda to beg for time and
attention.

It is not as if the benefits of “clean” cooking – or safe, reliable cooking
– have to be argued only with imaginary estimates of damage. Humanity has
known since cave days and nights that excessive smoke has immediate
unpleasant health effects such as eye irritation and coughing. Nor is the
engineering of “improved” or “better” stoves new; it started centuries ago
in the design of kitchens and innovative adoptions of cooking practices to
the local environments.

Choices in types of fuel – not just physical and chemical qualities of
biomass or coal – expanded rapidly about a hundred years ago, and the
history of food systems transformations “from farm to table” (or from shore
to table, or yard to floor mat) over these years is structurally embedded
in the entire world economy. Put differently, these changes are part and
parcel of the economic, social, and demographic changes of what Simon
Kuznets called “Modern Economic Epoch”; the problem of “cooking by the
poor” becomes a wicked problem because the processes of change and
stagnation at the Bottom of the Pyramid have no “standard” theory of change
across regions and over time.

Every generation is entitled to make the same mistakes as by made by the
previous ones, if only in the hope that the lessons learned will be more
productive. Still, it bears reminding ourselves that mistakes have been
made, premises and promises of technologists have proven false. I joked
once that Maggis (and other) noodles saved more trees than all “improved”
woodstove or charcoal kiln projects combined. (All trees have to die some
day. We know what happened to “acid rain” as the demonized “risk factor.”
Something similar would happen with dreaded PM2.5. People will die,
something else will be blamed.)

If new mistakes are being risked, it is incumbent upon us to at least shed
the false premises of the past. Deforestation is not going to be arrested
by more efficient stoves because there are multiple sources of wood and
multiple demands for trees and land. Same goes with water and labor inputs
to maintaining trees; opportunity costs vary and “hellfire and broom”
tirades against “development” aren’t going to go anywhere. Same about
girls’ and women’s status and rights in communities; there are multiple
sources of violence to the human body and dignity as also multiple means of
redress and progress. Needless to say, health is one, a sense of wellbeing;
diseases will happen, and many diseases and deaths have multiple risk
factors and causes. A stove is not a pill, WHO is not the health planner or
health savior for the world.  However many DALYs are attributable to “dirty
cooking” – defined by WHO as use of solid fuels, no matter what the stove
and the fuel or by whom, where, when, how – attributability is
associational not causal. Even attributions are in doubt because of
non-existent data and force-fitted functions, but in any case because the
past is no guide to the future.



*There is no convincing case that adoption of these Laboratory Testing
Protocols changes anything other than pressures for favoring USEPA-ordained
methods and equipment with a poor or no record of reliability or usefulness
in designing useful cookstoves.*


We are struggling with high levels of urban air pollution, and we need to
have local air quality management plans. Banning the use of particular
fuels or stoves and replacing with other fuels or stoves is but one of the
elements in such air quality improvement strategies.

For specific reasons outlined below, I consider this document 19867-1
unripe for a decision and recommend that it be rejected and returned to the
ISO.



*There is no convincing case that adoption of these Laboratory Testing
Protocols changes anything other than pressures for favoring USEPA-ordained
methods and equipment with poor or no record of reliability or usefulness
in designing useful cookstoves.*

For specific reasons outlined below, I consider this document unripe for
decision and recommend that it be rejected and returned to the ISO.

a) the document fails to meet its stated goals and is thus not mature for
final publication;

b) the metrics of “performance’ that are beyond the control of the stove
designer or supplier must not be mandated upon them;

c) in particular, there is no justification for including in any particular
protocol for laboratory or field testing performance targets that do not
meet an explicit public policy objective articulated in a  policy framework
and enforced; and,

d) the required procedures, equipment and calibration techniques have not
been proven to be reliable guides to stove design and testing in the past,
and it is not necessary to rely on a fixed set of parameters for fuel type
and quality, cookstove type, residential environment, cooking tasks, foods,
and non-cooking co-products (space heating, charmaking) if the only benefit
is reduced conflict between stove theorists, with no showing that the
designers and suppliers of stoves and fuels benefit from it.

No case has been made that international harmonization and alignment of
methodology and metrics according to DIS 19867-1 has a logical, if
uncertain, path to solving any particular problem. This DIS has to be
revised and offered for review simultaneously with Part II of 19867-1 and
all other documents in preparation for 19867 series in order for the
serviceability of the package to be assessed.

After settling what the policy goals and particular problems are, the
protocols should be piloted in a select number of locations – urban and
rural, with varying seasonal patterns in stove use and fuel quality,
different altitudes and residential structures – to verify that the methods
are used and useful for stoves of different sizes, temperature and power
patterns, and contribute to design of stoves that are proven acceptable in
use. Only then they can be attractive to individual member states.
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://lists.bioenergylists.org/pipermail/stoves_lists.bioenergylists.org/attachments/20171030/0e1e82fb/attachment.html>