Greenwashing Complaint Against EverWind Fuels, Inc. Submitted to the Canadian Competition Bureau
Canadian Bill C-59 added provisions to the Canadian Competition Act which prohibit misleading environmental representations commonly known as “greenwashing” and require that any such claim be substantiated by proper tests or internationally recognized methodologies.
EverWind asserts that their hydrogen and ammonia fuel products are carbon free and when used to replace their fossil-based equivalents will mitigate climate change by reducing global CO2 emissions. Their website declares, “EverWind’s green hydrogen is carbon free and made from 100% newly constructed renewable resources” despite their wind turbines being connected to the Nova Scotia grid which has substantial coal and natural gas generation that also powers EverWind’s production of their fuels.
Notwithstanding the public’s repeated requests for evidence to substantiate these representations, EverWind has provided neither test results for their products nor adequate and proper substantiation based on internationally recognized methodologies such as life-cycle, emissions analysis. Click here.
Clean Hydrogen Investment Tax Credit Program Defects
Canada’s Clean Hydrogen Investment Tax Credit’s (CHITC) goal is to reduce global, greenhouse gas emissions by offering tax incentives to encourage development of Canadian projects that will produce hydrogen at a lower CO2 intensity than that produced using fossil fuels. Notwithstanding this laudable objective, the current CHITC approval process contains defects such that in the Nova Scotia electricity generation and regulatory context, it will approve proposed, hydrogen projects that: 1) fail the CHITC “green” hydrogen CO2 intensity limit. 2) increase greenhouse gases globally. 3) fraudulently double-count renewable energy, environmental attributes 4) falsely undercount global CO2 emissions. In explaining the CHITC defects and how they produce these counterproductive results, this monograph references the two scientific studies that follow “Nova Scotia ‘Green’ Ammonia Will Increase CO2 Emissions Globally While Exporting Nova Scotia Renewable Energy Benefits” and “Worldwide greenhouse gas emissions of green hydrogen production and transport.” Click here.
Nova Scotia “Green” Ammonia Will Increase CO2 Emissions Globally While Exporting Renewable Energy Benefits
This study is a detailed simulation that demonstrates how adding ammonia production that is synchronized to specific wind generation on the Nova Scotia grid does not produce “green” ammonia with a zero-carbon footprint but rather “grey” ammonia with a significant carbon footprint whose use in replacing fossil-based hydrogen or ammonia production or use in electricity generation will increase global emissions.
The study also explains how grid electricity used in ammonia production and certified as fully renewable under European Union (EU) regulation, transfers guarantees of renewable origin from the owned or contracted renewable energy generation to the ammonia fuel and cannot be counted toward Nova Scotia meeting its climate change goals. The guarantees of renewable origin are instead attributed to the EU member state where the ammonia is consumed. Click here.
Worldwide greenhouse gas emissions of green hydrogen production and transport
This study by Dutch physicist 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 European Union (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 the conclusions, “There are virtually no projects for which transport as ammonia would stay below any of the emissions thresholds.” (UK 4.0 kilograms (Kg) CO2 per Kg hydrogen, EU 3.38 Kg CO2 per Kg hydrogen.) In the bar chart to the left, Nova Scotia hydrogen shipped 5,000 km to Germany as ammonia is in the group represented by the second bar from the right whose median CO2 intensity of 7.4 Kg CO2 per Kg hydrogen is more than double the EU threshold. Click here.
Why Nova Scotia “Green” Ammonia Isn’t Green - Evidence Summary
This monograph summarizes the results of the two scientific studies that precede above and that analyse projected CO2 emissions for planned hydrogen and ammonia production projects such as those proposed for Nova Scotia.
An overview of a Nova Scotia grid simulation that predicts the CO2 emissions for ammonia produced from grid-connected, renewable energy is presented and the reasons why the process will increase CO2 emissions globally explained.
The results from a study by a Dutch physicist as they relate to ammonia produced from off-grid renewable energy in Nova Scotia are highlighted. The study finds that the median CO2 intensity of hydrogen representative of Nova Scotia type projects (off-grid generated hydrogen transported 5,000 km as ammonia to Germany) is 7.4 kilograms of CO2 per kilogram of hydrogen which is more than double the European Union “green” hydrogen limit. Click here.
Wind Power Effects and Limitations on the Nova Scotia Grid
This monograph explains the effects of adding increasing amounts of intermittent renewable electricity generation (i.e., wind) to a conventional electrical grid such as that managed by Nova Scotia Power, Inc. Electrical grid basics are presented and the interaction between dispatch and dispatch limited generation types is illustrated showing why the degree to which intermittent, wind energy can penetrate an electrical grid without ancillary energy storage or generation curtailment is limited to low percentages. Click here.
Isolating and Quantifying Changes in Annual Emissions on the Nova Scotia Electrical Grid in Response to Increased Renewable Energy and other Emissions Factors
While Nova Scotia Power, Inc. (NSPI) annual reports show a reduction in CO2 emissions, the reports do not identify what caused the reductions. Most assume that increased wind generation is responsible. However, other factors such as overall energy consumption, coal plant efficiency and amount of hydro generated also contribute. Using differential calculus, this study analyzes the amount of reductions or increases caused by the various factors. Among the conclusions, from 2007 through 2012, decreased coal plant efficiency more than offset CO2 savings from additional wind generation (graph on left) and over the same period, overall reduction in power consumption dominated CO2 emissions reductions, not wind generation. Main document click here. 2012 addendum click here.
Isolating Component Contributions to Emissions Changes on the Nova Scotia Grid
This document contains the mathematical derivations for the foregoing study. It is a technique based on differential calculus for isolating and quantifying the individual contributions to changes in total grid emission resulting from changes in total grid generation, fossil fuel intensities and proportions of fossil fuel, hydro, and wind generation on the grid. Click here.