<div dir="ltr">Crispin: <br><br>I am afraid I would have to disagree on some points with you. You have an "expert" answer but only a partial acknowledgement of the complexity of political economy of clean cookstoves as I have slowly discovered over the last year.<br><br><div><div>1. I had carefully worded my first question about "<span style="color:rgb(80,0,80);font-size:12.8px">lab-tested energy efficiency of renewable biomass a significant consideration for buyers of a manufactured stove."<br></span><br>You have cited one survey but not linked it to lab test results or "renewable biomass". Some 700 million biomass stoves are running in the world, and the annual market is probably 400 million, considering average stove life and population growth, stove types, whatever. New manufactured stoves with a lab-tested energy efficiency rating have made zilch of a difference in the world market. All this "efficiency" competition is in the heads of theorists selling stoves to donors, not to users.<br><br>2. If the customer does not know, and mass manufactured (rather than artisan or fixed) stoves have not proven themselves in the market place, what difference does it make if the test uses WBT or anything else? Again, you are making the point about theorists finding confirmation in surveys rather than markets. <br><br>3. This test protocol or that, the ISO ratings exercise is a dead-end alley. I agree with you about "<span style="font-size:12.8px">undue influence exerted during the process". It is the TC management's job to moderate such influences and vet draft standards with public review and comment, plus in this case an independent audit by people who know something about energy markets overall. <br></span><br>I am not at all sure "..<span style="font-size:12.8px"> it is difficult for the WB to avoid using an ISO standard if it exists, even if it is a dreadful product." For one, the ISO product has to be accepted by the client country. Why, Kenya and Rwanda may accept it and with it, World Bank money may flow - if the finance minister agrees - for stoves that may not deliver what the standards are intended for. But if India or China or Indonesia, Brazil, Mexico, Nigeria reject ISO standards and Tiers, or only use them selectively - say, for Safety - the World Bank does not have to impose ISO standards. <br><br>But that is the next stage - if money flows, people may be surprised.<br><br><br>Nikhil<br><br>PS: </span></div><div>Supplement to 3: <br><br>a. I have no means of judging whether TC-285 is a "<span style="font-size:12.8px">project of and by those who manage it, not those who participate in it." All I know is the 2012 IWA and a 2013 paper by Susan C. Anenberg and Jacob Moss, notionally the founding parents of GACC from US State and EPA, with five others, with an evident push to convert the whole "clean cookstove" enterprise to a bandwagon for a US-style "New Source Performance Standard" the way EPA had done for power plants and boilers in my earlier life and spent 30 years doing for residential wood heaters. (Regulations are still to be fully effective only in 2020, and may not happen.)<br><br>What is worse, whereas in US, wood or coal combustion sources were regulated or banned in reference to National Ambient Air Quality Standards (NAAQS, tightened around 2010, but I may be mistaken) as applied to individual CONTEXTS - cities, towns, multi-jurisdictional metropolitan areas. <br><br>In the case of household cookstoves in the developing countries, EPA had no such "reference objective" - achieving and maintaining ambient air quality standards. So what do EPA contractors (GACC, others) do? They jump on the bandwagon of IHME/Kirk Smith and get WHO to concoct Household Fuel Combustion Guidelines: Solid Fuels. There are "guidelines" for indoor air quality, but nobody to my knowledge has applied them in standards in developing countries, at least not for the inside of the homes of poor people. No matter; without any air quality standards, they rush to declare Tiers and ranges for PM2.5 emissions in terms of units per delivered energy. What do emissions have to do with concentrations? Nothing, unless you not only cook a standard meal on a standard stove on a standard fuel by a standard cook for a standard family at a standard time, you also assume a standard home, standard ventilation, standard wind pattern, and standard mobility. <br><br>Plus, you ignore all other sources of PM2.5 like ambient air pollution from activities other than cooking, or from neighbor's cooking, or smoking, or burning garden wastes, anything. <br><br>There is no basis for computing the total PM2.5 exposure by controlling just the cookstove hourly average emission rate, leave alone the cookery of HAPIT going from concentrations to aDALYs.<br><br>That is, whatever you think of the "efficiency" debates that is so heated in this forum - linked to test protocols - it is the PM2.5 metrics and Tiers that have zero credibility. <br><br>Unless Kirk Smith is God. Why, he too says, "There is a natural urge to forget that the CRAs, at best, estimate “attributable” impacts and apply </span><span style="font-size:12.8px">them directly to estimate what might be achieved by interventions today, i.e., “avoidable” impacts."<br><br>WHO's natural urge to forget should be remembered by all or us. WHO is fooling us, and billions of prospective users. While I don't think much of HAPIT model for computing aDALYs, it makes adjustments for "ambient air pollution" and other such confounding variables (though not the health confounding variables). WHO has no basis to issue emission rate targets, and certainly not in PM2.5 terms.<br><br>This deceitful manipulation of what Lima Consensus presented as "Potential Standards" into utterly arbitrary IWA "Standards" - referring to 40CFR60 (a section of US Code of Regulations) which has nothing to do with cookstoves - is an obvious abuse of ISO processes.<br><br>It is the manager who is accountable, to ISO leadership, country members, and the in turn to their own governments. <br><br>Since ANSI is a co-chair of the ISO TC-285 exercise, I wonder just what it owes to the US government, whom it represents. What are the US national interests here? To control the lives of billions of cooks worldwide? <br><br><br></span></div></div></div><div class="gmail_extra"><br clear="all"><div><div class="gmail_signature" data-smartmail="gmail_signature"><div dir="ltr"><div><div dir="ltr"><div><div dir="ltr"><div><div dir="ltr"><div><div dir="ltr"><div><div dir="ltr"><div><div dir="ltr"><div><div dir="ltr"><div><div dir="ltr"><div><div dir="ltr"><div><div dir="ltr"><div><div dir="ltr"><div><div dir="ltr"><div><font face="georgia, serif">------------------------------------------------------------------------<br>Nikhil Desai</font></div><div><span style="font-family:georgia,serif;font-size:small">(US +1) 202 568 5831</span><font face="georgia, serif"><br><i>Skype: nikhildesai888</i><br></font><br></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div>
<br><div class="gmail_quote">On Sun, Sep 24, 2017 at 6:28 PM, Crispin Pemberton-Pigott <span dir="ltr"><<a href="mailto:crispinpigott@outlook.com" target="_blank">crispinpigott@outlook.com</a>></span> wrote:<br><blockquote class="gmail_quote" style="margin:0 0 0 .8ex;border-left:1px #ccc solid;padding-left:1ex">
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<p class="MsoNormal"><span>Dear Nikhil<u></u><u></u></span></p><span class="">
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<p class="MsoNormal"><span><u></u> <u></u></span></p>
<p class="MsoNormal"><span>></span>Would you or somebody else be kind enough to answer the following for me?<u></u><u></u></p>
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<p class="MsoNormal">>1. Is lab-tested energy efficiency of renewable biomass a significant consideration for buyers of a manufactured stove? <u></u><u></u></p>
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<p class="MsoNormal">Yes. In market surveys conducted by professional researchers (for example the Vesto market survey now used as a reference text in the Industrial Designers curriculum at the University of Johannesburg) fuel efficiency is near the top of
the rank ordering of ‘features’ of a stove product. It is usually first, second or third.<u></u><u></u></p>
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<p class="MsoNormal">>2. Is that true even when the test result is for fuels and pots that are unrepresentative of the users' customary use, and that too for just boiling water?<u></u><u></u></p>
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</span><p class="MsoNormal">It is true as a consumer’s ranked purchasing criterion. The customer has no knowledge, of course, as to how a fuel consumption number is generated. They certainly would never guess that it might be based on something as flawed as the WBT
‘specific fuel consumption’ metric.<u></u><u></u></p>
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<p class="MsoNormal">>3. Is there any reason for prospective users to bother with ISO TC 285 pronouncements of stove ratings? How and when?<u></u><u></u></p>
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<p class="MsoNormal">We don’t know, because the contextual test method, which is able to make a prediction of future performance in use, has not been completed. It should be obvious that a ‘standard’ test of stove is about as useful as a ‘standard global meal’
or a ‘standard hair cut’. The current 19867-1 test sequence is taken from my SeTAR Centre heat transfer efficiency test v1.x. It is basically an HTP 2009. How useful that is as a predicter of performance in use is unknown and untested. It is very technical
and was never intended to be a fuel consumption test conducted during a cooking event. It is sort of a WBT-Pro. At present it is used in the Draft Indonesian National Standard but will be replaced by the CSI test method in the coming sessions.<u></u><u></u></p>
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<p class="MsoNormal">>There needs to be a public airing of the discussion on this List that a) far, far too much is being assumed about fuels, operating practices, and cooks' preferences (rather, they are being ignored), and b) the ISO exercise is for the sole
purpose of declaring that stoves for gaseous fuels (of whatever origin) and electricity are only ones meeting Tier 4 for hourly average emission rates of PM2.5. <u></u><u></u></p>
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<p class="MsoNormal">Kind of. I quibble about the assumptions, because a contextual test, still to be written, could provide exactly what is needed by the stakeholders. And re the gas and electric stoves, they will have to ignore the cleanest wood burners then,
because they compete with LPG for PM 2.5 emissions. I don’t know about the ‘tier 4’ business. Numbers are changeable so what exactly is a ‘tier 4’? I had seen coal-fired cooking and heating stoves that meet the current EU Tier 5 which is cleaner than the
IWA Tier 4. I have seen two wood pellet cooking stoves that are as clean as LPG (according to Indian LPG test numbers).<u></u><u></u></p>
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<p class="MsoNormal">>When the definitions and theories of equations debated in this thread are explained to the proverbial "common woman" cooking in rural households of the developing world, I expect much mirth and amusement to follow. <u></u><u></u></p>
<p class="MsoNormal"><u></u> <u></u></p>
</span><p class="MsoNormal">Maybe not. If you take the top 5 or 10 reasons why people select a stove, you may find that the answers (metrics) are present in the contextual test sequences, particularly where the CSI method has been applied in full (which requires assessing
the cooking behaviour of the target market).<u></u><u></u></p>
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<p class="MsoNormal">>ISO TC-285 has become a sideshow even before its work is completed. It is, after all, a project of the experts, for the experts, and by the experts.
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</span><p class="MsoNormal">That is not my experience of it. It is a project of and by those who manage it, not those who participate in it. There is a great deal of leeway accorded to the management group to steer the result to a conclusion of their choice. That
is why I had said from the beginning that it should not be confused with ‘peer review’. External expert review, as called for in the IWA, is not at all the same as having anyone and everyone who wants to participate, and be titled ‘expert’, join the ISO process
and “be there” when something is created. Anyone who has been involved in the development of a Standard using the ISO process (which is by far the most common) knows there can be a lot of undue influence exerted during the process. Powerful private interests
(manufacturers) often ‘deliver’ the standard they prefer. Examples are too many to enumerate. Pick any product.<u></u><u></u></p><span class="">
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<p class="MsoNormal">>Experts who by and large know very little about the diversity in cooking, fuels, climates, in the world and even less about changes therein over the last 30 years or expected over the next 30 years. <u></u><u></u></p>
<p class="MsoNormal"><u></u> <u></u></p>
</span><p class="MsoNormal">Well, that is the difference between a real ‘expert’ and someone participating in an ISO process where everyone is an ‘expert’. We are polite about it, but we are also realistic. “Trust all men, but tie up your camel.”<u></u><u></u></p>
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<p class="MsoNormal">>Scientists who have reduced household cookstove, and human bodies, to mere oxidation machines should be held answerable to the 5-10 billion people they purport to use taxpayers' monies for. <u></u><u></u></p>
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</span><p class="MsoNormal">Nah – we are quite a bit better than that. The evolution of the contextual test methods – in that name so as to divorce us from the ‘standardized’ tests of the past – is well-recognized in most sectors of regulation, just not for domestic
cooking stoves. Most product testing is use-contextual. Look at the trouble Volkswagen got into for deviating slightly from it.<u></u><u></u></p>
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<p class="MsoNormal">>I am afraid ISO TC 285 has become a millstone around the necks of those billions of people.
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</span><p class="MsoNormal">It certainly has for the World Bank because it is difficult for the WB to avoid using an ISO standard if it exists, even if it is a dreadful product. It would have to contain significant reputational risk before they could avoid using it.
The WBT is avoided at present because of the reputational risk associated with using it.<u></u><u></u></p><span class="">
<p class="MsoNormal"><u></u> <u></u></p>
<p class="MsoNormal">>A thorough independent audit of the US participants in that process must be initiated by US Congress to examine the objectives and the rationale of the exercise and the likely benefit of its Voluntary Performance Standards. <u></u><u></u></p>
<p class="MsoNormal"><u></u> <u></u></p>
</span><p class="MsoNormal">That will probably not yield much. The ANSI members participate in the ISO process ‘as individuals’ though it is clear they form a team objective to implement ‘as individuals’ in sessions. I don’t think that is as surprise. In short, if
you say they are acting against the public interest <i>as a group</i> they will reply that those were the actions of individuals acting on their own, even if they were indeed acting as a group on promise of sanctions of they didn’t.<u></u><u></u></p>
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<p class="MsoNormal">>I don't for a moment believe that any public sector donor is desperate for the Tier ratings so billions of dollars can at last start flowing in subsidies. <u></u><u></u></p>
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</span><p class="MsoNormal">You are correct. The only obvious purpose is to attempt by the use of WHO box models to ban entire classes of fuel by tying it to a ‘tier’ mechanism. If solid fuels start performing well into the Tier 4 space, the WHO will change the performance
requirement so they fail. This is not rocket science,. The EPA has been doing this for years.<u></u><u></u></p>
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<p class="MsoNormal">Apparently it is not about ‘clean’, it is about LPG.<u></u><u></u></p>
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<p class="MsoNormal">Regards<span class="HOEnZb"><font color="#888888"><br>
Crispin<u></u><u></u></font></span></p>
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