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

[Nikhil Desai]

Crispin:

Consider the CONTEXT, please. I shouldn't have to beg you for that. You
seem to be endorsing Ron Larson's view that the ISO TC-285 is just a sport
of "voluntary" gathering. 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.

If you don't involve any government or multi-governmental actor in your
stove project, anything goes. But that is NOT, to my knowledge, the purpose
of ISO and WTO. And that is also not the dream of GACC or external
financiers of stove projects. I very much doubt private charities - NGOs,
Foundations, what a friend calls

Or of 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?)

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 there is readiness to implement standards and labels - as in "The
Virtuous Cycle of  Standards and Labelling Programs ", CLASP
presentation *Standards
and Labelling:  Benefits and Approaches for Cookstoves
<https://share.ansi.org/Shared%20Documents/Standards%20Activities/International%20Standardization/Standards%20Alliance/Standards%20Alliance%20web%20site%20EAC%20and%20SADC%20documents/Uganda%20Ethanol%20Fuel%20Workshop%20(November%202016)/CLASP_Cookstoves_Presentation.pdf>
*(November 2016).

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.

+++++++++

Why was IWA 2011:12 constituted? In response to urgent market demand. Whose
demands? USEPA's. Why, Susan C. Anenberg and Jacob Moss - the godparents of
GACC, from State and EPA - wrote, with Jim Jetter of EPA, Sumi Mehta of
GACC and three others, in 2013:

"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 |

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. TC-285 and GACC will be forgotten in five
years.

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"). 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.

Without indoor air quality standards and means of compliance, it makes  no
sense to think that stove standards alone will achieve indoor air quality.

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.

IWA itself  says "This.. serves as a guideline for policy-makers..."

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.

Accidental imperialism, as Brita Victor might say. Well-meaning evangelism
by the cults of environmental health and climate change.

Chef Jose Andres and GACC CEO said last year,

"Thanks to innovative technological advances in stove and fuel
development, *formation
of standards and testing*, and greater investment in market-based
approaches, the Alliance has helped nearly 50 million households gain
access to cleaner, more efficient cookstoves and fuels in the past five
years alone." (How Cooking Technology Can Save Lives around the World
<http://www.huffingtonpost.com/radha-muthiah/how-cooking-technology-ca_b_10504432.html>,
Huffington Post, 16 June 2016 , revised 17 June 2017. This is funny. Maybe
next revisions 18 June 2018 so on to 30 June 2030?)

The Alliance role in "formation of standards and testing" must have helped
early 50 million households, saving lives around the world.

So long as nobody disagrees, this must be true.

++++++

Please do not let yourself be fooled nor fool others by pretending
"voluntary standards" from ISO can mean anything. IWA "guidelines" have
perpetrated an ideology of WBT as the golden protocol and the IWA Tiers as
golden Tiers; just ask GACC or Xavier.

Every standard - by whomever, enforced or not, governmental or private --
has to be justified in reference to a purpose and a product.

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?

I repeat - there is no service standard in a vacuum, only for specific
contexts and purposes of cooking. There is no purpose of a standard unless
a government, a trade association (licensed by a government) or some other
specified authority articulates a public policy objective in having a
standard - safety, for instance.

This is no sport. It is a big game - to lure donors and recipient
governments into an "international standard", whatever the consequences. We
have known for decades now that promises matter and premises are not
examined.

Nikhil



On Thu, Sep 28, 2017 at 1:31 PM, Crispin Pemberton-Pigott <
crispinpigott at outlook.com> wrote:

> Dear Nikhil
>
>
>
> Just to remind readers, there are options beyond having or not having a
> national standard.
>
>
>
> There can be an ISO standard that no one adopts.
>
> There can be a national standard that is an adopted ISO standard.
>
> There can be a national standard that is an edited version of an ISO
> standard (quite common).
>
> There can be a national standard that is voluntary and not a law.
>
> There can be a national standard that is a law, but only partly required,
> the rest being voluntary such as SANS 1906 in South Africa.
>
> There can be a national standard that is a law and enforced such as SANS
> 1243 in South Africa (both apply to kerosene stoves).
>
> There can be provincial standards such as those in Ontario for smoke
> emissions which are enforced.
>
> There can be industry standards such as those common in China.
>
> There can be municipal standards such as Montreal’s ban on wood fireplaces.
>
> There can be trans-national standards such those in the EU.
>
>
>
> Any standard can be applied (required) in part, not in entirety, depending
> on the whim of the Minister relevant.
>
>
>
> Regards
> Crispin
>
>
>
>
>
>
>
>
>
> Dear Ron:
>
> You wrote a few days ago that the ISO TC 285 work was not meant to imply
> any kind of enforcement.  Something like "enforcement" was a long way off.
>
> To me, there is no "voluntary" standard at the national level. Either you
> have a standard or you don't. Voluntary ratings system like Energy Star in
> the US is complementary to appliance standards but not a standard in
> itself. Some standards may also be according to size/design - such as for
> refrigerators - and may be at the corporate average level (for passenger
> vehicles, say).
>
> I will have to check on WTO rules. True, an ISO TC may propose a standard
> that national members may or may not adopt. However, it is in the very
> nature of WTO rules and ISO mandate that countries adopt product standards
> and enforce them in order to facilitate smooth international trade.
> Pertinent legal issues merit an investigation.
>
> The story below suggests that Uganda is prepared to respond to the East
> Africa Global Alliance on Cookstoves for mandatory standards. Who knows,
> taxation of imported cookstoves may lead to a trade war with Trump.
>
> I also wonder if Gold Standard and GACC would have to register aDALYs as a
> product with national standards agencies and if any standards can be
> applied to aDALYs.
>
> Nikhil
>
> ------------------------
> * Gov't official cautions on standards for cookstoves
> <https://www.newvision.co.ug/new_vision/news/1462509/gov-official-cautions-standards-cook-stoves>*,
> New Vision, 27 September 2017
>
> Wilson Wafula, the acting commissioner in the Ministry of Energy and
> Minerals Development, says "The standards should be enforced after the
> Uganda National Bureau of Standards has approved the product."
>
> "The commissioner was backed by the regional representative of East Africa
> Global Alliance on Cook stoves, Daniel Wanjohi who said any cook stove must
> meet the mandatory standards.
>
> Wanjohi enumerated benefits of standardization as growing the market,
> discourage open fire and product uptake will go up among others."
>
>
>
>
>
>
>
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