[Stoves] Tiers and metrics (Re: Ron)

Sat Sep 9 12:02:26 CDT 2017

Ron: (I changed the thread name and dropped ANSI, GACC ccs, added Cecil and
Laurent.)

Thank you so much for clarification.

1. I am skeptical of your view that "*Nothing approaching “enforcement” is
intended.*" A product standard is a legal instrument, and the ISO
requirement that only national standards bodies can be members of a TC is
proof simple that "cookstove standards" are meant to be incorporated in
national regulations and enforced. Whether they are enforceable is very
much a part of a rational inquiry. No, sir, this is not some game or
sport. If EPA/PCIA did not intend to have an international regulatory
standard, just some benchmarks for USG-supported itty-bitty stove projects,
there was no need for an inter-governmental exercise. I very much believe
incorporating PM2.5 emission rates -- rather than % reduction -- is
consistent with EPA regulatory mindset in other situations and that
bringing WHO in was intended to help support the view that only Tier 4 or
gas-equivalent stoves are "truly health protective", as Kirk Smith likes to
say. I agree with you, "*The emerging stove “industry” is a long way from
being ready for that.*" But that is precisely why this extra-jurisdictional
reach of WHO into the  cookstoves business threatens the interests of the
users who are subjected to presumptuous insidious theories like HAPIT. It
is not for nothing that Gold Standard and other players are placed in the
TC as "liaison". All in all, I stand by my view that the ISO exercise has
long-arm intent and that developing countries must think very seriously and
very long before adopting ISO recommendations for "international
standards".

2. You ask, "*What would you have proposed to replace the tier concept?"*

As I have said repeatedly, my concerns are with metrics, then protocols,
then ratings, in Tiers as determined by field testing. In that order. What
is the purpose of Tiers and arguing that a stove that ranks 2 in one Tier
may rank 4 in another, etc.?

It is the "fuel-free", "cook-free" nature of metrics - in particular the
WHO-imposed hourly average PM2.5 - that I most object to; the rest is a
matter of lab v. field, different fuel types and cooking cycles, shape,
weight, what not. I am yet to decipher policy relevance of Monte Carlo
simulations with this assumption or that. And as a one-time student of
econometrics, I have no patience for mindless regressions, whether in stove
testing or putative "burden of disease", aDALYs.

I am also strongly opposed to the idea in so-called "Implementation
Science" - there is a Jan 2017 paper with Sumi Mehta from GACC, and before
that I think in the Johnson-Chiang paper and also a World Bank Technical
Paper, and informal comments by Kirk Smith - that "stacking" must not be
permitted by project designers. I think Kirk Smith rationalizes this as not
sufficiently health protective (which he says of all biomass stoves, and I
find it irrational.)

That is, I am in favor of a Woman's Right to Choose. Kirk Smith and CDM are
all Pro-Life. (In American parlance.)

I would like to see ratings based on fuels and tasks for stoves of
different sizes and tasks. This won't make some expert evaluation easy - a
donkey-dung oven vs. a wood-chip water heater - but would force stove
designers away from physic-ist competition on efficiency to social
acceptance depending on fuel contexts and task preferences.

I wrote in my "Modern Cooking" piece five years ago about adding some
"subjective" elements - non-scientific as they may be considered by
physical scientists - to the list of evaluation metrics. To me, "usability"
- call it "pride of ownership" - tops all metrics. If a stove is not usable
and used much of the time, even if in combination with other fuels/stoves,
and the next stove purchase is not for the same or higher level of
utilization, then I consider that stove design a failure for that market. I
haven't revisited that paper; I did not even know that it was published.
Anyway, Laurent Durix of the World Bank has given us all a delightful
paradigm of "*Contextual Design and Promotion of Clean Biomass Cookstoves*".
(I am writing this title from memory. I posted a link several times.)

I will go check that paper; I remember I had left the list open-ended, so
other metrics can be added as relevant in the context, as smart questions
to women young and old would reveal how the cycle of cooking is and has
been changing, how much cooking is outsourced (e.g., breads like leavened
wheat breads in Africa, naans in Afghanistan, injeras in Ethiopia and
tortillas in Central America.) But first I am trying to tackle the
questions of economic demography, women's lives and work chores, human
environments. How do we get from the mindset "Better biomass stoves are the
solution" without properly identifying what the problem is and whose
problem it is?

---------

In sum, just because some people have set one particular "cause" - save
trees, protect climate, empower women, -  and, as you put it, "really
believe in the importance of the cause" - does not guarantee that the user
at the end of this top-down chain will be pleased. WHO/Kirk Smith/GACC have
picked a cause -- New Source Performance Standards for cookstoves - with a
single Tier 4 (for PM 2.5) stove/fuel completely and permanently replacing
all existing inefficient and presumptively dirty stove/fuels. It is a
quixotic war against solid fuels, a propaganda campaign for LPG, and needs
to be called out for its misplaced concreteness in the vacuum of data.

Nikhil

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

On Tue, Sep 5, 2017 at 11:40 PM, Ronal W. Larson <rongretlarson at comcast.net>
wrote:

> Nikhil and ccs
>
> On Sep 5, 2017, at 8:53 PM, Nikhil Desai <pienergy2008 at gmail.com> wrote:
>
> Ron:
>
> I submit there is no such things as “international standards" until
> incorporated in national regulations, if any enforcement is intended.
>
> *[RWL:1  I think you are misunderstanding the expected output of TC285.
> Nothing approaching “enforcement” is intended.   As I understand the output
> of the TC 285 group (to be in 4 parts - with the most important coming out
> soon), these are intended mainly to help stove developers to improve their
> products and to educate potential buyers on how individual stoves have done
> in specific tests.   I doubt you will see the word “enforcement” anywhere.
> The emerging stove “industry” is a long way from being ready for that.*
>
> * I hope that if a manufacturer says his/her stove is “all Tier 4’s” - and
> testing has shown “all Tier 2” was closer - then I hope that manufacturer
> is called out publicly.  *
>
> The real thankless work will come after ISO issues standards in persuading
> that these be adopted in national regulations, especially when they won’t
> be incorporated in US regulations.
>
> *[RWL2:  There might be some national stove regulations I suppose - but I
> doubt that.  Especially in the US (where very few of the tested stoves will
> ever be sold). *
>
> There are many countries where appliance and equipment standards of
> manufacturing countries are adopted by some blanket agreement or if the
> government itself buys under external finance from countries or
> multi-lateral institutions (e.g. power plant or mining/manufacturing
> equipment.)
>
> *[RWL3:  I suppose this is true, but don’t see how this applies to any TC
> 285 activity or output. *
>
> I agree with you that the concept of Tiers is awful. Consensus or not.
>
> *[RWL4:  Apologies.  Obviously, my term “weird” was unhelpful.  What I
> meant was that I doubt that “Tiers” appear at all in any other ISO
> document.    So “weird” as in “rare” or “non-standard".*
>
> * Rather, I think the “Tiers” concept was brilliant - and I fully endorse
> it.  For one, they are sufficiently broad that all should recognize that
> different testers will come up with numbers that are acceptable if they are
> within a few tenths of a tier.  Example: an efficiency computation of 37%
> by one tester should be considered as valid as another of 35% for the same
> stove - both are known as Tier 3.  The lower efficiency score could have
> been entirely due to a tester (maybe the same one) filling his coffee cup
> at just the wrong time.  Or a slightly different fuel or moisture content -
> etc.*
>
> * If the initial group had not (unanimously??) settled on Tiers - I think
> we would today be several years behind where we are in stove improvement.
> I only know the process second hand (mostly at a half dozen stove
> conferences and this site), so hope others will correct me where wrong.*
>
> * What would you have proposed to replace the tier concept?*
>
> *Ron*
>
>
> Nikhil
>
> ------------------------------------------------------------------------
>
> On Mon, Sep 4, 2017 at 8:00 PM, Ronal W. Larson <rongretlarson at comcast.net
> > wrote:
>
>> Xavier et al
>>
>> I’d like to insert a different slant.  Setting international “standards”
>>  (in this case only something on recommended test procedures and this weird
>> thing called a “Tier”) is generally considered by people I have talked to
>> as one of the least desirable ways for any intelligent person to spend
>> their time.  To volunteer (few get paid), you have to really believe in the
>> importance of the cause.
>>
>> To say that for efficiencies to be identified by Tiers (0….4, 5)
>>  linearly related to nominal efficiencies measured by decades (10, 20,….50)
>> doesn’t strike me as bizarre.  Anyone have a better set of tiers?  Anyone
>> think that the concept of tiers is awful?
>>
>> I believe you will find that ANSI and ISO staff do not find it easy to
>> fill the ranks of standard reviewers.  There are many who have and will
>> join to advance their own businesses.  There is big money to be made with
>> standards that influence purchases.  Thanks to Sally and Ranyee for taking
>> on these thankless jobs.
>>
>> So, I trust you will agree that not everyone who says they want to be
>> involved should be involved.
>>
>> I agree with you that protocol development will occur outside the ISO
>> process - AND HAS - especially for the stove world.
>>
>> By chance I today independently found the Lima accord cite:
>> http://www.pciaonline.org/testing/lima-consensus.    The key word is
>> “consensus”.
>>
>> This was cited in a Jetter et al 2012 paper at:
>> http://heatkit.com/research/downloads/cookstove%20rankin
>> gs%20jetter2012.pdf   Kirk Smith is a co-author.
>>
>> Ron
>>
>>
>>
>
>
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