[Stoves] Webinar 29th and 30th Aug - Gold Standard’s Methodology for Averted Disability Adjusted Life Years (ADALYs) from Cleaner Household Air

Tue Oct 31 15:40:01 CDT 2017

Ron, Anil, List:

I remembered this e-mail of mine to Gold Standard folks Abhishek Goyal and
Vikash Talyan a couple of weeks ago. I had mentioned a webinar a couple of
times and posed some questions. They were kind to reply in followup text.

The whole Q&A on the webinar may be on their website. My questions and
their answers at the bottom of this e-mail.

Before that, my response to Gold Standard.  I happen to think there are
serious reputational risks all around - including to Gold Standard itself,
since its work crucially depends on credibility, not just academic modeling
(though Ajay Pillarisetti and his co-authors are amply cautious about the
utterly untenable assumptions behind the HAPIT model).

The more I dig in hope that there is something somewhere, I come empty.
There is no there there. Even Goldman Sachs and C-Quest Capital ought to
rethink how many people they can fool how long. [Disclosure: I happen to
have been "present at the creation" - back in mid-1990s, before Kyoto, when
GHG/CO2 reduction certificates were being discussed in Washington DC. I
don't remember if Chatham House rules applied, so I won't name names. Those
who were present there would remember me.)

I have more detailed critique of the Gold Standard Methodology and may post
it later. There are multiple documents - including Ajay Pillarisetti's PhD
thesis - I would need to collate; nothing in my reading has thus given me
any hope for this charade.

Nikhil

---------- Forwarded message ----------
From: Nikhil Desai <pienergy2008 at gmail.com>
Date: Thu, Oct 12, 2017 at 4:42 PM
Subject: Re: Webinar 29th and 30th Aug - Gold Standard’s Methodology for
Averted Disability Adjusted Life Years (ADALYs) from Cleaner Household Air
To: Abhishek Goyal <abhishek.goyal at goldstandard.org>
Cc: Vikash Talyan <vikash.talyan at goldstandard.org>

Abhishek:

Thank you for taking and reporting on my questions at the webinars. I
reproduce your answers below with my underlines on statements that I find
highly contestable. Credible claims depend on credible theories, not the
black box of models stuffed with academic pretense.

I have no problem with feel-good altruism of the super-rich who can afford
to pay Gold Standard or Goldman Sachs fees. What private parties do with
mutual consent and even non-disclosure agreements is their business.

But when a "saleable health product" of no particular specification, and
mutable by the year, is offered, I am curious whether you regard this
product as a health product - to be recognized in the US, say, by the Food
and Drug Administration (FDA), or a financial product (say, an option) to
be recognized by some financial regulatory agencies.

Have you prepared a prospectus and draft contract documents for the sale of
this "saleable health product"?

I also wonder who will buy aDALYs for what kind of household cooking
interventions. Who do aDALYs accrue to, who owns them? If you are
suggesting that large-volume ADALYs be bought from one government (host
country) by some other government, with the two GSs and GACC as brokers,
some legal questions of product specifications and procurement rules are
bound to arise.

I don't think such transactions could rely solely on your
credibility. Credibility is an interactive function of glibness and
gullibility.  And surely GS cannot be a monopoly broker.

And at what price? I vaguely remember Kirk Smith once using a figure of
something like USD 7,000+ for an aDALY. I would like the HAPIT promoters to
make the market by buying a thousand aDALYs a year from any household
energy intervention of their choice. If they buy it at USD 3,000/aDALY net
of their consulting fees, I would give their estimates some credence. I
want some aDALYs myself, having been exposed for years to HAP from biomass
as a chiild and then outdoor HAP as an adult.

I imagine children building sand castles and trade them in exchange for air
castles.

If Gold Standard Foundation is protective of its credibility, it should
drop this gimmick. HAPIT is not a salvageable instrument for anything. It
is an academic fancy like "social cost of carbon", "shadow prices",
"aggregate production function".

I base my view on Annex 4 of your proposed ADALYs Methodology (Version 1.0,
17 January 2017). I am not familiar with the work of its authors except
some of Susan A. Annenberg and of Ken Newcombe (ages ago, in particular the
seminal paper he co-authored with Russell J. deLucia on mobilizing finance
for global environmental objectives.)

However, I have read much of UC-Berkeley, GACC, and WHO air pollution
literature. It seems to me that your Jan 2017 methodology Annex 4 is only a
slight revision of earlier documents.

I will be happy to share with you my comments on these documents. The two
GSs may not be able to ride long and fast on the credibility of UC-Berkeley
and WHO, for the simple reason that as one digs into these cited sources
and further primary sources, the "make-believe" of ADALYs Methodology is
exposed.

+++++++++++

Take one example: you claim that "DALYs are a common metric used by public
health and development entities globally as a way of assessing the burden
of disease due to various risk factors and to evaluate and *compare the
effectiveness of health-related interventions*1." (emphasis added), citing
http://www.who.int/healthinfo/global_burden_disease/estimates/en/index2.html
.

However, that link provides no examples that "compare the effectiveness of
health-related interventions."

If at all, WHO/GHE Global Health Estimates 2016 Summary Tables  (March
2017) show country death data in three different colors, and for many
developing countries including India, they say

"Death registration data are unavailable or unusable due to quality issues.
Estimates of mortality by cause should be interpreted with caution.
Estimates may be used for priority setting, however, they are not likely to
be informative for policy evaluation or comparisons among countries."

If data on death by age and sex are this fuzzy, what is the reliability of
DALYs by risk factors? Besides, what is the predictive value of DALYs -
which are for cohorts dead - for ADALYs which are for current and future
cohorts?

To take another example, you refer to SDGs and claim that your methodology
offers a "balance of robustness with cost".

Who, pray tell, is to balance this? USEPA promoting worldwide NSPS for
cookstoves?

Yes, UNSDG does say for Indicator 3.9.1 - Mortality rate attributed to
household and ambient air pollution. I understand this revision was pushed
by two private groups - UN Foundation and Energia - last year, with intents
that are not difficult to fathom.

However, "attributed" is a computational gimmick, nor a verifiable metric.
Under no condition are countries required to be bound by any particular
computational method or database, and I am prepared to state that there is
in fact no valid database or plausible methodology for such attributions.
At the very least, separation of household and ambient air pollution
exposures and mortality rate is impossible except by another round of
computational gimmicks.

Also, it is worth recognizing that "attributable" is not "avoidable", that
the SDG proposed is at the national level and not any random cohort of
choice by Gold Standard Foundation. That is, "avoided" DALYs are not within
the definition of SDG 3.9.1 and any pretense otherwise only undermines your
own much vaunted credibility and independence.

If by mortality rate WHO means gross numbers of death attributed (by WHO or
its member states) to household and ambient air pollution, I am ready to
bet that by 2020, such numbers would only have increased. Technologies
favored by UN Foundation or UC-Berkeley for "Cleaner Household Air" are
unlikely to keep up with the growth in the number of new households in the
population using solid fuel for cooking (which is a metric in another SDG).

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

Whom is a buyer going to find credible - Gold Standard over UC-Berkeley or
WHO? Dropping words like "reputed academics" - who have the integrity to
list utterly incredible assumptions for the sake of cooking up numbers and
"scientifically accepted relationships between personal exposure to PM2.5
and the relative risk of disease onset" will only fool some of the people
some of the time.

That "Gold Standard is well recognised in the industry and with the
public." is a circuitous claim to assert authority outside law - that GS is
credible because its glib credibility is accepted by the gullible who are
themselves not accountable to any law.

Feel free to distribute these comments to all those who received your Q&A
from the webinar.

Nikhil

--------------------------
Background: My questions and Gold Standard responses. Emphasis added.

Q: You spoke of credible ADALYs. Who is granting you the authority that
ADALYs are a credible substitute for the SDG 3.9.1.? There is no other
health intervention where I see ADALYs is being advanced as a metric. Where
do you derive your authority from or it is just by assertion?

A: DALYs are a common metric used by public health and development entities
globally as a way of assessing the burden of disease due to various risk
factors and to evaluate and *compare the effectiveness of health-related
interventions*1. The application of averted DALYs is indeed novel, perhaps
explaining why it has not yet been widely advanced as a metric by others,
but it builds on the work of reputed academics in public health and indoor
air pollution. As you may know, the methods used to prove health outcomes
by research are very expensive and time consuming, this methodology does
not pretend to be a substitute for this method of study. Rather it
uses *scientifically
accepted relationships between personal exposure to PM2.5 and the relative
risk of disease onset* as a way of vastly reducing the costs* to
demonstrate likely health impact *of a household energy intervention. As
ADALYs methodology offers a balance of robustness with cost, we hope that
it will assist health intervention projects in two ways;

- by introducing a new *credible matrix*  (sic) for projects to make *health
outcomes claims in line with SDG 3* and
- by reducing the cost of making *credible claims* by projects that already
devote a significant amount of budget to it.

The first ADALYs methodology focuses on clean cooking interventions, but we
intend to develop similar methodologies for other health interventions such
as WASH or ambient air solutions. This will allow both the comparability of
interventions and also the linking of multiple intervention types under one
programme with a common metric.

We derive our authority from the *expert stakeholders* who were involved in
its development, the fact that it was publically available for comments
during its development and that we always remain open to improve on it. It
is by no means the definitive solution, but what we do hope that it is
the *start
of a journey to a better way of measuring meaningful health impacts
delivered by projects.*

As you know, SDG Target 3.9: By 2030, substantially reduce the number of
deaths and illnesses from hazardous chemicals and air, water and soil
pollution and contamination. *And 3.9.1 is one of its three indicators:
Indicator 3.9.1: Mortality rate attributed to household and ambient air
pollution.* The ADALYs methodology based on HAPIT outputs includes an
estimate of the #of averted deaths (in addition to an estimate of the # of
averted total ADALYs). However, it allows assessing the project level
contributions to target 3.9, which aims to substantially reduce the number
of deaths and illnesses from hazardous chemicals and air, water and soil
pollution.

Q:: You claim to be a standard and certification body under which law,
Swiss law or what else?

A: Standards bodies generally work by providing independent voluntary
standards, that is they do not have to be followed by Law. As such, they
stand as a mark of quality for those who recognize the standard and what it
is trying to achieve.
To maintain the independence, transparency in the standard setting, impact
evaluation and assurance of outcomes, we follow the ISEAL's Codes of Good
Practice, a benchmark for strong, credible sustainability standards
systems. We maintain independence in the certification process by relying
on independent auditors’ opinion before making a decision on a project. We
are also governed by independent body of experts called Technical Advisory
Committee (TAC) that has access to project documents for review before we
make any certification decisions. Also, decision on our rules and
requirements are made by TAC. Currently more than 80 international NGOs
supports Gold Standard.

On Tue, Sep 12, 2017 at 12:31 PM, Vikash Talyan <
vikash.talyan at goldstandard.org> wrote:

> Dear All,
>
>
>
> Thanks for attending the webinar on Gold Standard’s Methodology for
> Averted Disability Adjusted Life Years (ADALYs) from Cleaner Household Air.
>
>
>
> Please find enclosed the summary of Q&A session and slides presented in
> the webinar.
>
>
>
> The webinar recording is also available at the link below
>
> https://youtu.be/4-PTiawvfd8
>
>
>
> Please let me know if you have any questions.
>
>
>
> Regards,
>
> Vikash Talyan, PhD
>
> Technical Director - Standards and New Programmes
>
> The Gold Standard Foundation
>
> Geneva, Switzerland
>
> Tel +41 22 7887080 <+41%2022%20788%2070%2080>
>
> Email: vikash.talyan at goldstandard.org <claire.willers at goldstandard.org>
>
> www.goldstandard.org
>
>
>
> Follow us on Twitter @cdmgoldstandard
>
> Like us on Facebook: www.facebook.com/TheGoldStandardFoundation
>
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