© Kristen Overmyer, M.S.M.E., December 1, 2024, info@getgreenright.ca

Introduction

In Tim Houston’s December 15, 2023 announcement of Nova Scotia’s “Green Hydrogen Action Plan,” the Premier claimed it would help us “fight climate change” while his Natural Resources and Renewables Minister Tory Rushton claimed it will “help us reach our climate change goals in Nova Scotia.” Two, peer-reviewed, scientific studies that analyse projected CO2 emissions for planned hydrogen and ammonia[1] production projects such as those proposed for Nova Scotia contradict both these claims. This monograph summarizes their findings which include:

• Ammonia produced from wind power plants connected to the Nova Scotia grid and then used as a replacement for fossil-based ammonia, as a replacement for fossil-based hydrogen, or as a fuel in electricity generation in the European Union (EU) will increase, not decrease, CO2 emissions globally.

• Ammonia produced from wind energy not connected to the Nova Scotia grid but connected directly to an ammonia production facility in Nova Scotia and then used to transport hydrogen to the EU’s hydrogen grid, the CO2 intensity of said hydrogen will exceed the EU standard for “green” hydrogen by more than double.

• Because of EU regulations, any carbon reduction benefits inherent in the Nova Scotia renewable energy used in ammonia production will accrue to whomever consumes the ammonia in the EU and not to Nova Scotia. Specifically, the renewable energy cannot be counted towards Nova Scotia reaching its percent renewable energy or greenhouse gas emissions climate change goals.

The first study titled  “Nova Scotia ‘Green’ Ammonia Will Increase CO2 Emissions Globally While Exporting Renewable Energy Benefits” is authored by Kristen Overmyer, M.S.M.E., a Nova Scotia engineer, software developer, and consultant. This study can be accessed at https://getgreenright.ca/content or by clicking here.

The second study titled “Worldwide greenhouse gas emissions of green hydrogen production and transport” is authored by Kiane de Kleijne, PhD., Department of Environmental Science, Radboud Institute for Biological and Environmental Sciences, Radboud University, Nijmegen, The Netherlands. Dr. de Kleijne is also a Chapter Scientist and Contributing Author in Chapter 12 (Cross-Sectoral Perspectives) in the Working Group III contribution to the IPCC Sixth Assessment Report. This study can also be accessed at https://getgreenright.ca/content or by clicking here.

Carbon Free Claim for Electricity Producing Nova Scotia Ammonia

A display at an EverWind Fuels[2] (EWF) open house in Goldboro, Nova Scotia during summer 2024, claimed “One tonne of ammonia produced by EverWind will displace 2 tonnes of CO2.” The CO2 is supposedly displaced by not producing the ammonia from methane which emits about 2 tonnes of CO2 for every tonne of ammonia[3] but from EWF hydrogen for which their website claims, “EverWind’s green hydrogen is carbon free and made from 100% newly constructed renewable resources.”[4] Hence, the electricity producing the hydrogen must be carbon free as well.

Actual Carbon Content of Electricity Producing Nova Scotia Ammonia

The notion that EWF’s hydrogen is carbon free is suspect given that the Nova Scotia grid relies heavily upon coal and natural gas to produce electricity. In 2022, Nova Scotia Power, Inc. (NSPI) reported an annual average, CO2 intensity of 557 grams of CO2 for each kilowatt-hour (g/KWh) of electricity generated[5]. For comparison, the annual average, CO­2 intensity of Quebec electricity in 2022 was 1.2 g/KWh[6] which is essentially carbon free.

To determine the actual CO2 intensity of electricity supplying EWF’s ammonia plant, a mathematical simulation of the Nova Scotia grid using NSPI’s 2022 grid performance data was created[7]. To the existing 615 MW of wind capacity, 372 MW of new wind capacity to be online by 2025 (February 2022 NSPI Request for Proposals) was added along with 527 MW of new wind capacity representing EWF’s three, grid-connected, wind power plants whose combined output was exactly matched by EWF’s ammonia plant’s electricity consumption. The simulation calculates a best-case, annual average, CO2 intensity for electricity supplying the EWF ammonia plant of 239 g/KWh. Since every tonne of ammonia produced from electricity requires approximately 10 to 12 megawatt-hours (MWh) of energy[8], a minimum of 2.39 tonnes of CO2 is emitted for every tonne of ammonia produced by this process. This  is not “carbon free” as EWF claims and as would be expected if the ammonia plant were powered by wind energy alone and is also greater than the CO2 emitted had the ammonia been produced from methane. Using EWF’s ammonia to replace fossil-based ammonia for agriculture, hydrogen transport, or power production will increase CO2 emissions globally[9].

Temporal Correlation

If the actual CO2 intensity of EWF’s ammonia would be around 239 g/KWh instead of zero, how does EWF reason that their ammonia will be carbon free? The short answer is creative carbon bookkeeping. It is a basic principle of electrical grids that all electrical generation supports all loads all the time to maintain voltage and frequency. Consequently, the energy from EWF’s three, grid-connected, wind power plants will satisfy demand at all the other loads on the Nova Scotia grid in addition to EWF’s ammonia production plant. In doing so, this renewable energy will displace a combination of hydro, oil, gas, and coal electricity on the grid. Since some of the electricity is fossil-based, some CO2 reduction will be achieved. The math is such that if the ammonia plant consumes electricity at the exact amount and time as the energy generated by the three EWF, wind power plants, then the CO2 reduction on the grid equals the additional CO2 emitted by the ammonia plant[10].

This matching of renewable energy generation and ammonia plant consumption is called “temporal correlation” and is an EU requirement for the electricity to qualify as fully renewable. Many have construed this condition to, in effect, create a direct connection between the renewable electricity generating and ammonia producing plants while at the same time excluding any fossil-based electricity generation on the same grid. This interpretation, while appealing, is nonetheless contradicted by the abovementioned, grid simulation which enforced this “temporal correlation” condition exactly, and still produced a high CO2 intensity.

Typically, “temporal correlation” would mean that the electricity generated by the renewable energy installation is consumed at same the time and by the same amount by the ammonia producing facility as described above. In practice, the temporal correlation requirement can only be met to a degree. This is reflected in the EU regulations which through December 31, 2029, require that the ammonia be produced in the same calendar month that the renewable electricity is generated. After January 1, 2030, the requirement is that the ammonia be produced in the same one-hour period that the renewable electricity is generated[11]. The former case yielded the 239 g/KWh average, annual CO2 intensity as discussed above. The latter same-calendar-month case was also simulated and yielded an average, annual CO2 intensity of 389 g/KWh. This is a 63% increase in CO2 emissions over the one-hour case and represents a plausible operational scenario for EWF through this decade’s end.

Cancellation of Guarantees of Origin

To get the ammonia’s carbon footprint near zero, all the CO2 reductions from EWF’s three, wind power plants displacing fossil generation on the grid must, on the carbon accounting books, be transferred from the Nova Scotia grid to the ammonia production thereby nullifying its carbon emissions[12]. This transfer is accomplished by cancelling the guarantees of origin held by the wind power plants’ owner for the renewable electricity supplying the ammonia plant so that guarantees of origin may now be created for the consumer (ammonia producer) for that same, renewable electricity.

Renewable energy carries the potential to displace CO2 emitting forms of energy generation and this potential is represented on paper as a “guarantee of origin.[13]” For EWF’s grid-connected, wind power plants, their guarantee of origin potential is actualized on the Nova Scotia grid as a reduction in emitted CO2 from some fossil-based generation. For the ammonia producer (also EWF) to acquire the guarantees of origin for the electricity from these three wind power plants, the EU Regulations state that the guarantees of origin as owned by the electricity supplier must be cancelled[14]. Failing to do so, the ammonia, which is now considered by the EU as “fully renewable” by virtue of having acquired the guarantees of origin, can now be used in the EU to further reduce CO2 emissions by displacing fossil forms of ammonia or hydrogen production there. This results in a “double counting” of the original wind energy’s renewable benefits since CO2 reductions were already realized and recorded for the Nova Scotia grid. Notably, this transfer process for cancelling and creating new guarantees of origin does not change the physics of the matter. Global CO2 emissions remain unchanged. Only the burden or responsibility of said emissions has been move from the ammonia producer back to the Nova Scotia grid which in the Nova Scotia regulatory context is impossible. See [15].

Additionality

While both temporal correlation and cancellation of guarantees of origin for the electricity supplying EW’s ammonia plant are necessary to qualify EWF ammonia as carbon free, they are not sufficient. EWF must further demonstrate that the energy from their three wind power plants can only be added to the Nova Scotia grid if EWF also adds its ammonia plant to the grid to consume that added renewable energy. This can happen if the dominant share of generation on the grid is already intermittent renewable energy and adding further intermittent capacity alone is not possible[16]. This condition on the new, renewable energy’s use is known as “additionality.” Under these circumstances, EWF could argue that their combination of additional wind energy and ammonia production does achieve some global CO2 reductions.

If, however, the EWF ammonia production load is not necessary to make possible the additional EWF renewable energy, then that energy can be used to achieve greater CO2 reductions by displacing fossil generation on the Nova Scotia grid. Such is the case for EWF. Since NSPI has planning scenarios that include more than 2 GW of additional, renewable capacity by 2030[17], the grid can manage the additional power from EWF’s three, grid-connected, wind power plants. Moreover, under both the calendar month and one-hour temporal correlation cases described above and under which EWF will be operating, the renewable electricity satisfies other loads on the grid prior to the same amount being consumed later by the ammonia plant thereby demonstrating that the grid can utilize the energy and the ammonia plant is therefore not required.

The EU Regulations Article 5 does require additionality but not in the strict physics-based sense. Instead, it states the condition is met if, “The installation generating renewable electricity came into operation not earlier than 36 months before the installation producing the renewable liquid and gaseous transport fuel [ammonia] of non-biological origin.[18]“ There is no obligation that the renewable energy’s availability must be contingent upon the fuel production plant. In this respect, this regulation fails the EU’s objective of reducing greenhouse gas emissions.

Consequently, notwithstanding EWF’s meeting the EU Regulation’s definition of additionality, the primary effect of adding EWF’s ammonia production plant will be to increase the grid’s load which must be met by dispatchable generation including that which burns fossil fuels. This diminishes the emissions reduction that would have otherwise been achieved had only the wind energy been added to the grid and results in a net increase in global CO2 emissions. For one hour of EWF ammonia production operating in December 2025 at 500 MW of power consumption, the aforementioned simulation calculates the net increase to be just over 100 tonnes of CO2[19].

Peer Review

The foregoing results are part of a study[20] shared with both Nova Scotia Natural Resources and Renewables (NSNRR) and Natural Resources Canada (NRCan) and for which a thorough critique was requested. After eight weeks, NSNRR provided three observations which they provided to “refine” (their words) the work. These were helpful in adding clarifying text to the study. Notably, NSNRR did not refute the study’s findings nor offer any evidence to rebut any of its points.

After ten weeks, NRCan said that they had “some concerns about quite a few of the assumptions” but did not identify or describe any of these alleged concerns. Given that over the same timespan, NSNRR did provide review comments while NRCan did not, it’s reasonable to conclude that NRCan likely lacked the evidence to support their claims.

Off-Grid, Life-Cycle Emissions Exceed EU Standard

EWF is also planning nearly 2.4 gigawatts of off-grid, wind power in Guysborough County connected directly to their Port Hawkesbury, ammonia plant. A recent study in the peer-reviewed journal “Nature Energy” by the Dutch physicist Dr. Kiane de Kleijne and her colleagues, analyses the life-cycle emissions for over 1,000 planned “green” hydrogen production projects across 72 countries. The study covers gaseous hydrogen, liquid hydrogen, and ammonia as storage and transport media. While the EU regulations exclude life-cycle emissions in setting their requirements, this study demonstrates “that the current exclusion of life-cycle emissions of renewables, component manufacturing and hydrogen leakage in regulations gives a false impression that green hydrogen can easily meet emission thresholds.” Among their conclusions, “There are virtually no projects for which transport as ammonia would stay below any of the emissions thresholds.[21]” For the UK this is 4.0 kilograms (Kg) CO2 per Kg hydrogen, and for the EU 3.38 Kg CO2 per Kg hydrogen. The study finds that the median CO2 intensity of hydrogen representative of EWF type projects (off-grid generated hydrogen transported 5,000 km as ammonia to Germany) is approximately 7.4 Kg of CO2 per Kg of hydrogen which is more than double the EU standard[22].

Footnotes

[1] While elected officials at all levels of Canadian government use the term “hydrogen,” the hydrogen gas is converted to liquid ammonia for transport to the European Union. Before final use, the hydrogen is most often separated from the ammonia after which it can be piped and/or used in industrial processes or electricity generation.

[2] This monograph uses the wind power and ammonia production facilities proposed by EverWind Fuels, Inc. as an example. The findings, however, are applicable to any ammonia production facility in Nova Scotia.

[3] “Round-trip Efficiency of Ammonia as a Renewable Energy Transportation Media,“ Ammonia Energy Association, 20-10-2017, https://ammoniaenergy.org/articles/round-trip-efficiency-of-ammonia-as-a-renewable-energy-transportation-media/

[4] “EverWind Fuels, Inc. website home page,” https://everwindfuels.com/

[5] “Nova Scotia Power Air Emissions Reporting,” https://www.nspower.ca/cleanandgreen/air-emissions-reporting

[6] “Canada Energy Regulator - Provincial and Territorial Energy Profiles – Quebec,” https://www.cer-rec.gc.ca/en/data-analysis/energy-markets/provincial-territorial-energy-profiles/provincial-territorial-energy-profiles-quebec.html#s3

[7] “Nova Scotia ‘Green’ Ammonia Will Increase CO2 Emissions Globally While Exporting Renewable Energy Benefits,” Appendix B, https://getgreenright.ca/content

[8] “Round-trip Efficiency of Ammonia as a Renewable Energy Transportation Media,“ Ammonia Energy Association, 20-10-2017, https://ammoniaenergy.org/articles/round-trip-efficiency-of-ammonia-as-a-renewable-energy-transportation-media/

[9] “Nova Scotia ‘Green’ Ammonia Will Increase CO2 Emissions Globally While Exporting Renewable Energy Benefits,” Section 2, https://getgreenright.ca/content

[10] “Nova Scotia ‘Green’ Ammonia Will Increase CO2 Emissions Globally While Exporting Renewable Energy Benefits,” Section 5 Page 16, https://getgreenright.ca/content

[11] “Commission Delegated Regulation (EU) 2023/1184 of 10 February 2023 supplementing Directive (EU) 2018/2001,” Article 6, https://eur-lex.europa.eu/eli/reg_del/2023/1184/oj

[12] “Nova Scotia ‘Green’ Ammonia Will Increase CO2 Emissions Globally While Exporting Renewable Energy Benefits,” Section 6, https://getgreenright.ca/content

[13] “Wikipedia Guarantee of origin,” https://en.wikipedia.org/wiki/Guarantee_of_origin

[14] “Commission Delegated Regulation (EU) 2023/1184 of 10 February 2023 supplementing Directive (EU) 2018/2001,” Whereas (15), https://eur-lex.europa.eu/eli/reg_del/2023/1184/oj

[15] Notably, no Nova Scotia act or regulation contains any requirement for NSPI to add avoided CO2 back to the host grid’s carbon ledger for the purpose of reporting CO2 emissions let alone documents or references instructions for measuring and calculating the avoided CO2 that is to be added back. Consequently, the guarantees of origin for any renewable electricity generated on the Nova Scotia grid cannot be completely cancelled and therefore the EU Regulation requirement cannot be met.

[16] “European Commission, Ref. Ares(2022)3836651-20/05/2022, 2022,” Whereas (3), https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=PI_COM:Ares(2022)3836651

[17] “evergreen-IRP-Final-Modeling-Results-Data-Tables-2023.xlsx” sheet “Installed Capacity Changes” line 223, https://www.nspower.ca/irp/document-library

[18] “Commission Delegated Regulation (EU) 2023/1184 of 10 February 2023 supplementing Directive (EU) 2018/2001,” Article 5, https://eur-lex.europa.eu/eli/reg_del/2023/1184/oj

[19] “Nova Scotia ‘Green’ Ammonia Will Increase CO2 Emissions Globally While Exporting Renewable Energy Benefits,” Section 6 and Appendix C, https://getgreenright.ca/content

[20] “Nova Scotia ‘Green’ Ammonia Will Increase CO2 Emissions Globally While Exporting Renewable Energy Benefits,” https://getgreenright.ca/content

[21] “Worldwide greenhouse gas emissions of green hydrogen production and transport,” K. de Kleijne, Radboud University, The Netherlands, https://getgreenright.ca/content, Page 7, Paragraph 1.

[22] “Worldwide greenhouse gas emissions of green hydrogen production and transport,” K. de Kleijne, Radboud University, The Netherlands, https://getgreenright.ca/content, Page 5, Figure 4b., 2nd bar from right.