GR3 SWOT analysis

SWOT ANALYSIS

Date of publication: June 2015

Author(s): Santino Di Berardino, Luis Silva, João Bidarra – LNEG, Portugal

IEE project : IEE/12/046/SI2.645700 – GR3

Project website:

http://www.grassgreenresource.eu/

http://www.grassgreenresource.eu/

2 IEE/12/046/SI2.645700 – GR3

Disclaimer

The sole responsibility for the content of this publication lies with the authors. It does not necessarily reflect the opinion of the European Union. Neither the EACI nor the European Commission are responsible for any use that may be made of the information contained therein.

Le contenu de cette publication n'engage que la responsabilité de son auteur et ne représente pas nécessairement l'opinion de l'Union européenne. Ni l'EACI ni la Commission européenne ne sont responsables de l'usage qui pourrait être fait des informations qui y figurent.

Die alleinige Verantwortung für den Inhalt dieser Publikation liegt bei den AutorInnen. Sie gibt nicht unbedingt die Meinung der Europäischen Union wieder. Weder die EACI noch die Europäische Kommission übernehmen Verantwortung für jegliche Verwendung der darin enthaltenen Informationen.

El contenido de esta publicación solo compromete a su autor y no refleja necesariamente la opinión

de la Unión Europea. Ni la EACI ni la Comisión Europea son responsables de la utilización que se

podrá dar a la información que figura en la misma.

3 IEE/12/046/SI2.645700 – GR3

Table of Contents

Table of Contents .................................................................................................................................................... 3

Table Index .............................................................................................................................................................. 4

Figure Index ............................................................................................................................................................. 4

1 Summary ......................................................................................................................................................... 5

2 Introduction .................................................................................................................................................... 6

3 Identification and mapping of potential NTB’s ............................................................................................... 7

3.1 Methodology ......................................................................................................................................... 7

3.2 Description of the S.W.O.T. Analysis ..................................................................................................... 9

4 S.W.O.T. analysis results for each country .................................................................................................... 10

4.1 Germany .............................................................................................................................................. 10

4.2 Belgium ................................................................................................................................................ 13

4.3 Denmark .............................................................................................................................................. 16

4.4 Italy ...................................................................................................................................................... 18

4.5 Portugal ............................................................................................................................................... 20

5 Conclusions ................................................................................................................................................... 23

6 Bibliography .................................................................................................................................................. 25

4 IEE/12/046/SI2.645700 – GR3

Table Index

Table 1: Countries overview .................................................................................................................................... 7

Table 2: Topics selected for SWOT analysis ............................................................................................................ 8

Table 3 - SWOT result to Germany ........................................................................................................................ 12

Table 4 - SWOT result to Belgium ......................................................................................................................... 15

Table 5 - SWOT result to Denmark ........................................................................................................................ 17

Table 6 - SWOT result to Italy................................................................................................................................ 19

Table 7 - SWOT result to Portugal ......................................................................................................................... 22

Table 8 - NTBs detected ................................................................................... Fout! Bladwijzer niet gedefinieerd.

Figure Index

Figure 1- SWOT Analysis matrix cell ........................................................................................................................ 9

5 IEE/12/046/SI2.645700 – GR3

1 SUMMARY

The five participant countries have verified that a considerable amount of grass cuttings is poorly valorised in

Anaerobic Digestion (AD). This substrate can either be planted for several reasons as soil protection and

conservation against erosion and aesthetic, or it occurs from natural vegetation (e.g. road sides, natural parks)

and has to be maintained for assuring bio-diversity. Green cover crops have many positive effects on the

environment. Furthermore is available both close to the cities and on the countryside, offering an opportunity

to increase biogas production. It is crucial to know about the possible cause of this lack of interest, namely to

identify the non-technical barriers (NTBs) that hinder the investments. Consequently in this study the

identification and role of non-technical barriers and drivers facing the use of grass cuttings in anaerobic

digesters was investigated.

To achieve this overall objective and understand why investments concerning adding grass cuttings are

uncommon, the project sought to discover whether a range of factors and perspectives on biogas, held by the

involved stakeholders, might currently act to inhibit the use of grass cuttings in existing and new AD plants.

This information is essential for planning adequate measures and to overcome the problems.

The factors which hinder the investment can be numerous and related to different areas and countries. The

key question is to outline an appropriate methodology capable to uncover and identify these non-technical

barriers.

In this project data were collected on the inventorying of grass residues, the best practices and available

technology, environmental and socio-economic analysis, business development, legal framework and policy

support. All these reports (which are available on the project website) constituted the main source of

information for the preparation of the SWOT analysis. This information was further completed with data taken

from SWOT-surveys.

Moreover a search in the literature data and consultation of energy and waste experts and companies were

the additional means used to uncovering attitudes. These actions, in particular, provided figures about the

perceived costs and the benefits of grass appliance over other alternatives, the state of knowledge of

consumers and agents about grass for AD, and the characteristics of the companies which processes and uses

green wastes. The local workshops also contributed to discussion and NTBs identification.

After collecting all this information a specific framework for each country has been done, containing positive

(Strengths and opportunities) and negative features (Weaknesses and Threats, referred to as ”Non-Technical

Barriers” (NTBs). This methodology enabled to identify and evaluate the factors which hinder or promote

investments, providing data suitable for planning appropriate measures.

The processed SWOT analysis indicates that Anaerobic Digestion is well developed and mature technology in

Germany, Belgium, Denmark and Veneto, having many digesters which can process the grass together with

others substrates. But the incentives for biogas from AD are declining and not enough to promote collection of

grass for AD, making the investments clearly not feasible. In Portugal AD application is still limited and there is

potential for growth, namely in the area of solid wastes. There are many legislative instruments regulating the

grass a substrate, affecting the use in the digester and the digestate application. Grass from urban area and

roadside is assumed as a waste and has to pay a gate fee to be delivered to the waste regional system and

requires severe analytical control, making complex and risky the management of the cycle of grass

valorisation. Grass management can have chances for application when the environmental classification and

6 IEE/12/046/SI2.645700 – GR3

rules will promote it. This Report provides a highlight of a number of recommendations which would

overcome barriers to the wider use of renewable energy.

2 INTRODUCTION

This report of the GR3 project is dedicated to the determination and analysis of non-technical barriers (NTBs)

hindering the promotion of grass cuttings in biogas plants, based in the participant countries and its

evaluation by using SWOT analysis.

Despite the fact that the green grass cuttings provide a good source of bioenergy and fertilizing potential, at

practically zero cost for cultivation and harvesting, close to the waste collection and management systems, the

use of anaerobic digestion technologies to take profit from these opportunities has been limited.

The aim of this study is to determine the nature and extent of the non-technical barriers that stand in the way

of an increased role for grass use in AD and suggest measures to overcome it. Consequently this study has the

objective of assessing the nature of public and involved agents’ attitudes towards use of the grass cuttings as

substrate in the areas of anaerobic digestion for renewable energy production.

Technical barriers may be defined as the inability of a technology to deliver a desired service at competitive

cost, relative to alternative technologies. This is not the case for AD digesters or grass management, where a

well-established and mature technology is available. Consequently, in this study, the technical factors cannot

be really considered as barriers to grass supply in AD systems. The BAT report carried-out in the framework of

this project considered the availability of a huge market a of AD-digester techniques. The failure of grass to

digesters is due to other reasons, commonly called as “non-technical barrier (NTB)” hindering the investments,

which are not depending from technology or money. They must be detected and evaluated properly.

The non-technical barrier (NTB) to a project is defined as an hindrance, due to human concern, which can be

associated to many factors: attitudes resulting from a lack of information and experience with the technology,

by anxiety or fear; distortions in the market prices of technologies or services; the operation of institutional

factors and government policies discriminating AD Technology or grass wastes in favours of others; Subjects

concerning a biogas project's economy, etc.

These barriers are frequently not easily visible and must be adequately uncovered and identified in order to

define and implement measures which can overcome them.

The participating countries and regions are rather dissimilar. There are great differences in terms of

population, municipal waste, biogas production and greens cuttings potential. In spite of the vast difference in

size, every country produces within ½ - 1 ton of municipal waste per year per capita.

7 IEE/12/046/SI2.645700 – GR3

Table 1: Countries overview1

GERMANY (D)

BELGIUM (B)

PORTUGAL (PT)

DENMARK (DK)

VENETO (IT)

Population [x106] 80.7 10.8 10.5 5.6 4.9

Municipal Waste [x106t/year] 47.7 4,9 4,7 3,7 2,3

Municipal biowaste [x106t/year] 8.11 1.08 1,78 0,72 0.53

Number of digester (N) 9200 119 26 176 20

Biogas production [ m3/year x 106] 4122 126,7 23,8 97,9 25

Grass potential [t/year]2 2,975,000 128000 441000 1,026,917 1,113,0003

Biogas Production from Grass [ m3/year x 106]2 595 35 42 408 779

Anaerobic digestion is today a popular and very disseminated solution in all the participant countries,

excluding Portugal, where biogas projects are not enough promoted and are hindered by specific additional

barriers. In the other countries the potential of green grass cuttings is not fully exploited.

SWOT analysis is a strategic planning tool used to evaluate a number of factors, barriers or criteria that are

related to a business venture or proposition. SWOT analysis, meaning the analysis of “key” or “critical” success

factors. It belongs to the highest ranked set of techniques of strategic analysis in empirical surveys (Glaister

and Falshaw, 1999; Stenfors et. Al. 2007).

In this report chapter 3 discusses the identification of NTB’s and briefly presents the classification of NTB’s into

different classes, based on a geographical criterion. Chapter 4 presents a brief point of view of the SWOT

analysis and describes it shortly. Subsequently, in chapter 5 the SWOT results for each individual country are

presented. Finally, chapter 6 summarizes the findings and concludes the report.

3 IDENTIFICATION AND MAPPING OF POTENTIAL NTB’S

3.1 METHODOLOGY

The literature describes many NTBs and different organized approach to discover them. In this case the main

approach that was used to identify barriers which prevents the transformation of grass into biogas was the

evaluation of the previous reports made by the partners in the context of this project, concerning the legal

frameworks and incentives promoting waste management, the regulations about environmental protection

and the renewable energy generation.

The identification of NTBs in the participating countries by means of the reports, allowed obtaining an

overview concerning the current situation. The analysis of this work can also be used as a basis for face to face

interactions with policy makers on the topic of legal barriers hindering grass residue valorisation, and ways to

address them.

The barriers detected were classified in different topics, according to table 2:

1 data collected from several Internet sources. 2 Estimated in this project (WP2) 3 Evaluation for Italy

8 IEE/12/046/SI2.645700 – GR3

Table 2: Topics selected for SWOT analysis

Topics

Legislative/Administrative issues Market Issues

General Issues Economic Issues

Operational/Logistic Issues Agriculture Issues

Legislative and Administrative issues. These barriers are related to institutional and policy deficits and can

bear a supplementary partition between regulatory and/or administrative barriers. In some cases the

distinction between legislative and administrative barriers is not straightforward.

Permitting and authorization procedures can lead to significant administrative delays that hamper the

development of a project, however, these obstacles could have different origins.

General Issues: This group contains the barriers related with the public information and awareness about

biogas and grass.

Operational/ Logistic Issues: This item gathers the questions related with the logistic and operational barriers

for joining grass to the existing digesters. Grass to digester operation can require changes in grass cutting,

processing and transportation, being likely that grass processing introduce strong barriers making difficult the

operation.

Market issues. These barriers are connected with alternative technologies available for grass use which can

compete with anaerobic digestion. Also environmental friendly technologies already established like

composting, could pose a “threat”. In most cases these technologies compete for the same supply market,

unless does not provide the same environmental benefit. Biogas technologies can be both environmental

friendly in the sense of GHG emissions reduction, produce energy and offer a complete waste management

option.

Economic issues. This group is related with Economy barriers. This type of barriers can be originated (a) from

issues regarding the wrong use of economic factors like taxes and the imposition of a gate fee, (b) from issues

regarding the feasibility of supply, (c) from issues related to securing a market price for the final biogas plant

product and (d) on the functioning of the product markets.

The introduction of taxes can alter economic conditions making biogas sufficiently competitive or the opposite.

Taxes can provide an economic incentive, especially in cases where environmental unfriendly waste

management techniques are already in place.

Agriculture issues. Ecological considerations and economic diversification in the agriculture sector are

additional drivers for investing in biogas, which can act as an additional supply source for a biogas plant and in

some instances as the main or even single source of raw materials necessary for its operation. Energy crops

can compete with grass. Agriculture can accommodate the digestate, providing a safe disposal.

9 IEE/12/046/SI2.645700 – GR3

3.2 DESCRIPTION OF THE S.W.O.T. ANALYSIS

SWOT is an acronym containing four sections categorizing factors which describe positive or negative, internal

or external characteristics. The “typical” SWOT matrix - shown in figure 1 below - constitutes the main

presentation tool of SWOT analysis results, identifying and ranking the factors in order of importance within

the four innermost matrix cells:

Strengths: A resource or capacity the organization that can be used.

Weaknesses: A limitation, fault, or defect in the organization.

Opportunities: Any favorable situation in the organization’s environment. A trend, a change, or a

need that can be exploited.

Threats: Any unfavorable situation in the organization’s environment. A barrier or a constraint that

might cause problems, damage or injury.

The typical subdivision of factors when conducting SWOT analysis take place along the following perspectives:

the factors which are internal to the technology or to the firm’s environment are classified as strengths (S) or

weaknesses (W), and those external to the technology (and/or in competition with other technologies) are

further classified as opportunities (O) or threats (T).

The two perspectives can be differentiated by the different degree of control attainable within each

environment. Usually, the external environment is considered to be evolving and unrestricted and it can

seriously impede the process of strategic planning, whilst the internal environment is considered to be more

restricted, thus more easily manageable.

The SWOT framework can also organise NTBs; intuitively a barrier is related to weaknesses and threats,

rather than strengths and opportunities.

In the GR3 project this methodology is used to analyze the state of development and the capability of grass

addition to anaerobic digesters pathways and the respective biogas production.

Figure 1- SWOT Analysis matrix cell

Weaknesses

Positive

Internal

Threats

Strengths

Opportunities

External

Negative

SWOT

10 IEE/12/046/SI2.645700 – GR3

SWOT analysis provides an initial assessment of technical and economic risks for biogas production from grass.

The analysis aims to identify as internal issues the strengths and weaknesses of the

collection/processing/production pathways to biogas as well as examining the external opportunities and

threats which can endanger the feasibility of a grass to biogas project.

The list of the non-technological barriers and opportunities for the implementation of grass residue value

chains in the different countries was performed and subsequently transformed into SWOT analysis table.

4 S.W.O.T. ANALYSIS RESULTS FOR EACH COUNTRY

4.1 Germany

In Germany, there are a considerable number (21) of identified barriers (weaknesses (11) + threats (10)). Table

3 summarizes all identified barriers and shows the global SWOT analysis result for this country. In a general

way, the legislative issues dominate the German NTBS (6 in the weaknesses and 7 in the threats) although

there are other barriers related with Economical aspects (3), market (3), operational (2) and Agriculture (3).

Biogas production is playing a major role as a renewable energy source and the context is mature or in

declining expansion concerning the AD. Actually, the incentives to encourage investments are being

progressively removed leaving new biogas plants without any claim and now they are facing more rigorous

times. Attractive promotions for biomethane and incentives of electricity has also been removed or under

removal. Bonus fraction promotions are reduced or cancelled for single biomass, for separate energy crops and

landscaping materials, excepting in small biogas manure plants. Also an extra fee for treating biomass from

nature conservation areas does not exist anymore.

In Germany the list of bio-waste types is more complex than the European definition and every nature

protecting or landscape conservation area (including Natura 2000 areas) has their own regulations and

objectives concerning land use management techniques. On the other hand the environmental legislation is

very exigent, complicating the use of digestate as fertilizer, requiring bureaucratic procedure and specific

analytical controls of grass, which inevitably affects the motivation and the economic feasibility.

Processing grass residues as input substrates can be subjected to the waste legislation and to various

regulations on fertilizing and requirements of digestate, based on organic wastes or a mixture with other non-

wastes input in anaerobic digestion plants making complex the grass management. Greenery cuttings are

obliged to be treated before agricultural appliance (either compost or digestion), preferably by thermophilic

processes, in order to meeting the hygienisation and stabilization criteria defined by legislation. The end

product compost originating from greenery cuttings from private as well as public areas needs to be analyzed

for sanitation parameter, heavy metals, pH value, foreign substances and dry residues, if it has to be used as a

fertilizer, bringing additional costs. In addition, there are several restrictions for the application of digestate on

agricultural land and on water protection areas and the permitted technologies for grass recycling are:

pasteurization, thermophile composting, thermophile fermentation and other sanitation treatments, according

to BioAbfV.

11 IEE/12/046/SI2.645700 – GR3

The use of grass in AD suffers economical and operational competition once grass originated from nature

conservation areas as well as permanent grassland is mainly used as feeding or bedding material. Currently the

grass from roadsides is mulched and remains at the roadsides, saving collection, transportation and treatment

costs. Grass mowed more than twice a year is categorized in input category I tariff class with a lower

remuneration. The payment for grass from agricultural areas is usually calculated in accordance to the material

or energetic utilization value. In accordance to the FFH and bird protection directive there are directions for the

use of fertilizer and pesticides, the date of mowing, prohibition for converting permanent grassland into

cropland, the changing of the water resources especially in wetlands and the maintaining of watersides.

The local maintenance of the Saarland road network is governed by six “road and highway maintenance

bureaus”, as well as two “road maintenance” of the State Office for Road Construction, complicating the

overall planning and management.

Regarding the identified non-technical barriers (21 in total), the most of these statements are directly related

with legislative issues; therefore they are the main obstructions to recovery grass as energy source. In spite of

legislative barriers dominate this pick-list, it should be noted that there are also some barriers related with

market, environmental, operational and agriculture issues, which hinder the implementation of the grass value

chain. For example, it is necessary to modify some of the actual practices concerning the final disposal of

material from roadsides and watercourses, which are currently being composted or in most cases, the material

is being mulched and stays at the area.

12 IEE/12/046/SI2.645700 – GR3

Table 3 - SWOT result to Germany

Weaknesses Strengths

1. Since August 2014 the prior Bonus and Input category for single biomass fraction promotions are reduced or cancelled; (Legislative issue)

2. Solely a promotion focus via separate tariffs is given for organic residues and small biogas plants with main input of manure. No separate promotion for energy crops and landscaping materials; (Legislative issue)

3. Including grass residues as input substrates, the biogas plant and their digestate can be subjected to the waste legislation, depending on the origin and the intended purpose of the grass; (Legislative issue)

4. New installations do not have any claim for a biomethane bonus; (Legislative issue)

5. If a running biogas plant will be expanded after 2014 the EEG tariff from 2014 will be in place; (Legislative issue)

6. An extra fee for biomass from nature conservation areas is not existing anymore; (Legislative issue)

7. Municipalities are obliged for the collection of greenery materials. The Disposal Association Saar is responsible for the recycling (public waste entity). Greenery cuttings are obliged to be treated before agricultural appliance (either compost or

digestion); (Legislative and Operational issue)

8. Grass originating from nature conservation areas as well as permanent grassland is currently mainly used as feeding or bedding material; (Economical and operational issue)

9. Currently the grass from roadsides is mulched and grass remains at the roadsides; (Economical and operational issue)

10. Within the EEG 2012 landscape materials were remunerated by input category II if the meadows are mowed not more than twice a year, otherwise it is considered to be grass and will be categorized in input category I tariff class with a lower remuneration; (Legislative issue)

11. The end product compost originating from greenery cuttings from private as well as public areas needs to be analyzed for sanitation parameter, heavy metals, PH value, foreign substances and dry residues; (Agriculture)

1. Grass from greenery cutting is sometimes refinanced via direct private payments or waste fees.

2. The payments to maintain landscapes help creating an incentive effect to recover grass from these extensive locations.

3. Municipalities are obliged to collect the greenery materials from private households, unless private households are capable of own home composting.

4. For the purpose of stipulating more concrete regulations for organic waste valorizations, the Organic Waste Ordinance (BioAbfV) was published.

5. Landscaping materials from nature conservation areas, which are mowed and applied (without mixing with other wastes materials) on agricultural site nearby, are exempt of treatment and documentary.

6. The electricity generation from biomass comprises also the valorization of grass as a residue, landscaping material and grass from permanent grass areas.

7. If grass is categorized as waste, the German Biowaste Ordinance is valid for the application of the digestate on agricultural, horticultural or forestry soils.

8. Grass as a residue as well as grass defined under the EEG 2009 landscaping material definition has been promoted with the highest tariffs. (This priority tariffing methodology changed within EEG 2012 but still prioritized grass from nature conservation areas (new closer definition for landscaping materials) with the highest tariff Input Category II. Further grass as energy crops are extra paid in Input Category I).

Threats Opportunities

12. If grass applies under the organic waste regime, there are various regulations (German Federal Law, Federal State Law as well as regulated in the Statutes of Municipal Waste Management Authorities); (Legislative issue)

13. The list of bio-waste is more complex than the European

definition; (Legislative issue)

14. In Germany every nature protecting or landscape conservation

area (including natura 2000 areas) has their own regulations

and objectives concerning land use management techniques;

(Legislative issue)

15. In accordance to the FFH and bird protection directive there

are directions for the use of fertilizer and pesticides, the date

of mowing, prohibition for converting permanent grassland

into cropland, the changing of the water resources especially

in wetlands and the maintaining of watersides; (Agriculture

and Legislative issue)

16. The payment for grass from agricultural areas is usually

calculated in accordance to the material or energetic

utilization value; (Market issue)

17. There is a specific German legislation and regulations on

fertilizing and requirements of digestate appliances, based on

9. The budget for composting greenery cutting can be used for technologies like methanisation

10. The greenery cuttings which are recycled on agricultural, horticultural or forest soils, needs to be treated, analyzed and monitored, defined by organic waste ordinance

11. The German Renewable Energy Act (EEG) is an incentive instrument for the acceleration of all renewable energies to facilitate a sustainable development of energy supply, if it will be adapted the next time, it could be improved again for grasslands.

12. The German Renewable Energy Act (EEG 2012) has promoted the energetic use of grass via different sub instruments.

13. In order to promote the biomethane injection into the public grid, an additional tariff of 1-3 ct/kWh was budgeted by doing methane injection processes in 2012, but not in 2014. Due to the biomethane goals in Germany, the regulations could be improved again in 2016.

14. Grass from designated GR3 sites are generally receiving the Basis fee but can be eligible for Landscaping Bonus in the older EEG.

15. In 2015 a promotion focus via separate tariffs is only given for organic residues and manure.

13 IEE/12/046/SI2.645700 – GR3

organic wastes or a mixture with other non-wastes input in

anaerobic digestion plants; (Legislative issue)

18. There are several restrictions for the application of digestate

on agricultural land and on water protection areas ;

(Agriculture issue)

19. A thermophile composting as well as a thermophile anaerobic digestion is meeting the hygienization and stabilization criteria defined by legislation; (Market issue)

20. The permitted technologies for grass recycling are:

pasteurization, thermophile composting and fermentation and

other sanitation treatments according to BioAbfV; (Market

issue);

21. The local maintenance of the Saarland road network is

governed by six “road and highway maintenance bureaus”, as

well as two “road maintenance” of the State Office for Road

Construction; (Operational issue)

16. Requirement for a proper and safe recovery is a fixed sequence of recovery activities defined, which includes the preparation for reuse, recycling or other recovery.

4.2 Belgium

The main barriers identified in Belgium are reported in Table 4, which shows the results of SWOT analysis for

this country. The global representation of AD in Belgium indicates that this technology already well-known and

at a high expansion rate. At the moment the sector is in a declining phase, due to a change in policy which

limits the support with green power certificates (GPC’s) for existing installations (start date before

01/01/2013) and new installations (start date after 01/01/2013). This change in policy is a significant treat to

the complete sector.

The legislation and the economic features concerning the use of grass in Flanders do not promote adequately

the valorization of grass since there are no available significant incentives for co-digestion of grass and no

additional direct subsidy related to the energetic use of grass residues in biogas plants, to stimulate the

collection, transportation and delivery of this biowaste source.

The owners of biogas-plants are therefore not triggered to the digestion of grass as long as they have enough

other biowaste available. This availability of biowaste is highly dependant on the agricultural wheat harvest,

and can therefore vary greatly within a short period of time : during years with a high wheat harvest biowaste

will not be fed to the livestock and will be available on the market for processing in the digesters. In case of

low wheat harvest, a lot of biowaste (= high quality biowaste) will be consumed by the livestock farming, what

makes high quality scarce and expensive for the digester plants – at this point there will be (more) interest in

digestion of grass waste. At this moment – there is a lot of (low cost) biomass available, due to high wheat

harvest in the passed years. Contrary to that, the wheat harvest and price in 2012 was very high, what

increased the interest for grass as biomass.

On top of that, it is not interesting for the stakeholders that need to dispose of grass waste (either grass from

roadsides or grass from nature conservancies), as adding this waste grass to an anaerobic digester will result in

additional transport costs and a variable gate fee that should be paid to the biogas plant operator, ranging from

10 to 40 €/ton. Due to the high amount, transportation costs and gate fee, a certain fraction of the grass waste

from roadside and natural areas in Flanders is left on site and not collected for composting or digestion.

Despite being prohibited, at the moment there is no – or very limited – control on the handling of the grass.

This non-collected-grass will never end up in a digester for valorization.

14 IEE/12/046/SI2.645700 – GR3

An additional issue is that grass from roadsides contains a significant amount of waste (plastics etc.) which has

to be removed for application in digestion or co-digestion in wet digesters, requiring an additional pre-

treatment that will increase the process-costs. Dry Anaerobic digestion could be a more suitable technical

option for these materials, but there are very limited (2) dry digesters in Flanders. To implant infrastructures

facilitating grass to AD and new (dry) digester installations there are preconditions in the context of town and

country planning, “corporate bondage”, mobility and environmental conditions, which compromises or hinder

initiatives. Flanders is a densely populated region, resulting in very “scattered” regions where the grass can be

collected. This makes it hard to have enough grass collected to make a difference in the biomass-feedstock of

the digester. Most of the digesters (i.e. the ones within the agricultural areas) are obliged to process a certain

fraction of manure and are located in the region with a significant surplus of manure (i.e. the region of West-

Vlaanderen and Antwerpen). Other regions do count a lower number of digesters, what makes it harder to

have grass digested as the distances that have to be crossed demolish the economic feasibility. The legal status

of grass is not always as clear as it should be (waste vs. energy crop).

Taking into account the unfavorable legislative and remunerative framework which does not promote grass

collection to AD, this substrate does not look like a promissory solution that can bring benefits. Consequently

the stakeholders throughout the grass valorization chain do not know each other, or do not know how to work

together. In addition, when “waste” is processed by anaerobic digestion, the Environmental legislation

VLAREMA has to be respected, imposing specific measures with regard to environment polluting materials on

the input materials for anaerobic digestion and on the digested end products, bringing Important

consequences on the feasibility of grass digestion.

The circular RO/2006/01 fixed a weight proportion from 60 % streams directly coming from agriculture (grass

as a product) and 40 % streams not coming from agriculture (grass as a waste) in anaerobic fermentation.

There are many (eight) articles with regard to roadside management, (cutting, harvesting, transferring and

transportation) regulating specific rigid procedures which does not facilitate the trading of material to waste

managers. The legal rules to the trade and the use of fertilizers, soil improving products, cultivation substrates,

sewage sludge and every other product that improves crop production, may condition the suitability or the

tradability of grass based digestate as fertilizer or for soil amendment. The authorities that are responsible of

the waste management (OVAM) want to imply more thorough heat-treatment and even post-composting of

the digestate in case of co-digestion of grass clippings.

Relatively to the current situation in Belgium and regarding the weaknesses framework, it should be noted

that the most important barriers are encompassed in the economic and legislative fields. Concerning the

threats, these are greater in number than the weaknesses and they are focused in other topics as operational,

market and agriculture issues, although there are also some threats in the legislative field.

15 IEE/12/046/SI2.645700 – GR3

Table 4 - SWOT result to Belgium


1. There is no additional direct subsidy related to the energetic use of grass residues in biogas plants in Flanders; (Legislative issue)

2. There is a high gate fee to deliver grass to a biogas plant (around 40€/ton); (Economic Issue)

3. The available incentives for co-digestion are not sufficiently high to overcome the difficult application of grass residues in AD; (Economic Issue)

4. To implant these infrastructures there are preconditions in the context of town and country planning, “corporate bondage”, mobility and environmental conditions; (Legislative issue)

5. Grass from roadsides contains a significant amount of waste (plastics etc.) which requires an additional pre-treatment and increase the process-costs and also the gate fee; (Economic Issue)

6. The stakeholders throughout the grass valorization chain do not know each other and does not work together.; (General Issue)

7. There is no – or very limited – control on the handling of the grass (both road side and grass from natural areas). A certain fraction of the grass waste in Flanders is left on site and not collected for composting, or digestion, unless it is prohibited; (Operational Issue)

1. There is a minimal guaranteed fee for production of electricity based on renewable sources

2. In case the digester can replace some of the energy-crops by the digestion of grass waste, the higher the amount of green electricity that will serve for obtaining the green certificates

3. In exceptional cases there is a subsidy for the construction of a digestion plant on the farm level from the Flemish Agricultural Investment Fund (VLIF), supporting up to 28 % of the total investment costs for the realization of sustainable agriculture or the farm reconversion, with a broader scope.

4. Due to the surplus of nutrients on soil, farmer pays cost values to treat his digestate. Grass in digester reduces the Nitrogen concentration of digestate and improve digestion control of nitrogen-rich substrate against ammonia toxicity.

5. The use of biocides on roadsides is forbidden


8. When “waste” is processed by anaerobic digestion, the VLAREMA has to be respected. Important consequences of this are that specific measures with regard to environment polluting materials are imposed on the input materials for anaerobic digestion; (Legislative issue)

9. Through VLAREMA specific measures are also imposed for the digested end products; (Legislative issue)

10. According circular RO/2006/01 there has to be a weight proportion from 60 % streams directly coming from agriculture (grass as a product) and 40 % streams not coming from agriculture (grass as a waste) in anaerobic fermentation; (Operational Issue)

11. The support by GSC’s is limited in time for existing installations (start date before 01/01/2013) and new installations (start date from 01/01/2013) ; (Market Issue)

12. There are eight articles with regard to roadside management; (Operational Issue)

13. There are legal rules to the trade and the use of fertilisers, soil improving products, cultivation substrates, sewage sludge and every other product that improves crop production; (Agricultural Issue)

14. Heat-treatment and even post-composting of the digestate in case of co-digestion of grass clippings will be imposed; (Legal Issue)

15. It is hard to have enough grass collected to make a difference in the biomass-feedstock of the digester; (Operational issue)

16. In Flanders most of the digesters are located in the region with a significant surplus of manure (i.e. West-Vlaanderen and Antwerpen). In other regions the lower number of digesters makes harder grass collection at suitable distances; (Oper. Issue)

17. The transport costs and gate fee does not encourage grass collection and valorization in composting installation or digesters. A lot of non-collected-grass will never end up in a digester for valorization; (Economic Issue)

18. The legal status of grass is not always as clear as it should be

(waste vs. energy crop); (Legislative issue)

19. There is a significant impact of the wheat harvest – as this directly influences the availability of high quality biowaste on the market, and therefore also the interest in the digestion of grass. (Market issue)

6. Pre-treatment acting on pollutants level in grass residues will reduce significantly the gate fee cost for digesting grass.

7. There is a Green Energy Certificates system for producing electricity based on renewable sources, but the generated heat must be exploited in a useful way

8. There is an “ecology premium” for investments in biogas plants that produce biogas used for heat-production. Only investments that do not benefit from GSCs or WKCs are eligible for the ecology premium and 80 % of the energy content of the products must be used as a heat source on-site.

9. In spite of support be limited on time, the GSC’s provides a minimum guaranteed support for both installations (old and new).

16 IEE/12/046/SI2.645700 – GR3

4.3 Denmark

Table 5 summarizes the SWOT analysis results resulting from the data obtained for Denmark, evaluating the

NTBS (weaknesses and threats) found during the analysis detailed below.

Today in Denmark there are no specific incentives in place applying for grass. Biogas is subject to extensive

energy, environmental and agricultural regulations and is clearly not a competitive alternative to other

renewable sources for heat production, such as solar heating, wood chip boilers and geothermal heating.

Upgrading costs to get a biomethane meeting all quality requirements for the natural gas grid are prohibitive

and cogeneration is only feasible when a special tariff is offered. Anaerobic digestion was a process highly

financed in Denmark in 90 decade, when several large scale collective biogas plants have been set-up, making

this country one of the leading countries in Europe regarding biogas technologies. This, on the other hand,

reflects that Denmark is a country with a high agricultural density per capita; as a consequence, there is a large

availability of manure and other easily degradable substrates. This may explains why grass is pushed down on

the priority list and the production of biogas through grass is not yet widespread. Actually, banks and financial

institutions are often reluctant to lend money for biogas projects, these being frequently judged as risky. The

payback period should be less than half of the lifetime, which is difficult to achieve.

Today biogas producers have to bear the cost for the establishment of all needed gas and district heating

pipes, which are also pointed out as a major barrier. In the side of digestate valorization, when planning a new

biogas plant, there are various legislations to take into consideration, and the digested slurry is thereby

subject to several rules that govern its delivery and use, including the Law on agricultural use of fertilizers and

plant cover. If the land has not previously received manure applications, it must be examined and approved by

the municipality prior to the time of receiving the digestate. The use of digestate (as would the use of

manure), obliges the farmer to have catch crops on 10 – 14 % of the area, depending on the amount of

digestate/manure applied. Upon receipt of digested manure instead of mineral fertilizers the farmer will have

to follow the harmony rules, which makes the preparation of fertilizer accounts more tedious, thus increasing

the administrative load. The Danish national legislation concerning the spread of fertilization is very exigent

and exceeds the requirements of EU Nitrate Directive. There are too many (98) individual local waste

regulations Denmark, defining the detailed rules that apply for the handling of waste in the municipality,

complicating the use of this substrate. According to Danish law, biogas plants are defined as a “potentially

threatening groundwater activity” and will not be permitted in Nitrate Sensitive Catchments (NFI)

(groundwater). Many crop farmers find these procedures too costly and too lengthy and thus choose to use

mineral fertilizers instead of the digestate from biogas plants, “in the endeavor to lower the regulation

burden”. Long-term evidence of financial viability and operating experience are still missing for new substrates

like deep litter and straw and may be difficult to find an avenue for using the digestate as a fertilizer source.

The new Danish Resource Strategy for Waste Management has been criticized in a recent report from The

Environmental Economic Council (2014), which claims that from an economic point of view, it is preferable to

send the organic waste to the Danish waste incineration plants (producing heat and power) rather than sorting

the waste and sending the organic waste to biogas plants. It is possible to conclude from this picture that the

next most rated weaknesses are mainly related to technical shortcomings about infrastructures and market

issues. On the other hand the all threats are almost related to the legislative topic.

17 IEE/12/046/SI2.645700 – GR3

Table 5 - SWOT result to Denmark


1. There are no specific incentives in place in Denmark applying for grass. (Legislative issue)

2. When targeting combined heat and power market, biogas producers have a hard time to compete with cheaper alternatives to natural gas such as wood chip boilers and is clearly not a competitive alternative to other renewable sources heat production for such as solar and geothermal heating. (Market issue)

3. The need to bear the cost for the establishment of all needed gas and district heating pipes is also pointed out as a major barrier. (Logistic/Market issue)

4. It may be difficult to find an avenue for using the digestate as a fertilizer source; many cash crop farmers prefer to use mineral fertilizers in the endeavor to lower the regulation burden. often resulting in a negative price for the digestate (Logistic/Market issue)

5. Long-term evidence of financial viability and operating experience are still missing for new substrates like deep litter and straw. (Operacional issue)

6. The use of digested slurry (and other organic fertilizers) is subject to significant regulation. (Agriculture issue)

7. The land receiving the digestate should be examined and approved by the municipality prior to the time of application, if the land has not previously received manure applications. Many crop farmers find this procedure too costly and too lengthy and thus choose to use mineral fertilisers instead of the digestate from biogas plants”. (Administrative/Market issue)

8. The use of digestate (as would the use of manure), obliges the farmer to have catch crops on 10 – 14 % of the area, depending on the amount of digestate/manure applied. (Agriculture issue)

9. Upon receipt of digested manure instead of mineral fertilizers the farmer will have to follow the harmony rules, which makes the preparation of fertilizer accounts more tedious, thus increasing the administrative load. (Administrative/Market issue)

1. There is a subsidy equality so that biogas sold to the natural gas grid receives the same subsidy as biogas used at CHP plants

2. When biogas is used in industrial processes or as a fuel for transport, there is an introduction of a new subsidy

3. Biomass like deep litter and straw can potentially replace energy crops and industrial waste as a basis for biogas development

4. There has been a ban against deposit of organic waste in landfills from January 1997.

5. Composted as well as non-composted waste from gardens and parks can used for agricultural purposes without prior approval

6. Grass from gardens and parks can be used in manure-based biogas plants without prior analysis for environmentally harmful substances.

7. All uses of the biogas are supported (and not only electricity). There are incentives for biomethane in the natural gas grid


10. Upgrading costs to get a biomethane meeting all quality requirements for the natural gas grid are prohibitive. (Economic issue)

11. Bank and financial institutions are often reluctant to lend money for biogas projects, these being frequently judged as risky. (General issue)

12. Biogas is also subject to extensive energy, environmental and agricultural regulations. (Legislative issue)

13. Each of the 98 individual local councils in Denmark has their own waste regulations, defining the detailed rules that apply for the handling of waste in the municipality. (Legislative issue)

14. The Danish Resource Strategy for Waste Management is rather new, and that it has been criticized in a recent report from the Chairmen of The Environmental Economic Council (2014). The EEC claims that from an economic point of view, it is preferable to keep on as today, i.e. to send the organic waste to the Danish waste incineration plants (producing heat and power) rather than sorting the waste and sending the organic waste to biogas plants. (Legislative issue)

15. The Danish national legislation concerning the spread of fertilization exceeds the requirements of EU Nitrate Directive. (Legislative issue)

16. The digested slurry is thereby subject to several rules that govern the delivery and use of digestate, including the Law on agricultural use of fertilizers and plant cover. (Legislative issue)

17. When planning a new biogas plant, there are various legislation to take into consideration. (Legislative issue)

18. According to Danish law, biogas plants are defined as a “potentially threatening groundwater activity and will not be permitted in Nitrate Sensitive Catchments (NFI) (groundwater). (Legislative issue)

8. There is a Funding of biogas for CHP 9. The start-up aid for new biogas projects has been

increased from 20 % to 30 % 10. If manure from livestock accounts for at least 75 % of the

biomass used for the production of biogas, there are funding incentives. This is seen as an indirect incentive for using “new” residual biomasses such as grass.

11. In the Danish 2012 Energy Agreement, the Government has set ambitious goals for Danish energy supply, aiming at being independent of fossil fuels by 2050. Biogas is seen as a key fuel for long-distance (or heavy) transport in the future renewable energy system.

12. The Danish Energy Agreement 2012 comprises a variety of initiatives (like new subsidies), which some of this covering biogas and a plan for its expansion.

13. Grass for biogas production will be mixed with manure –serving as a co-substrate rather than the main substrate

14. Sand: because of the increase of sand bedding for cows, it is acknowledged among biogas stakeholders that sand is there to stay. Therefore, it can be expected that more and more biogas plants will integrate technologies to deal with sand in the future, being an opportunity for grass.

15. New upgrading technologies (biological; physicochemical) allowing to convert the CO2 of the biogas to CH4 (instead of separating it) are developing and receiving attention

16. New technologies for harvesting natural grass in a cheaper and more effective way (also in wet areas) are currently developing

17. The demand for organic biogas is increasing, which can be seen as an opportunity for residual grass.

18 IEE/12/046/SI2.645700 – GR3

4.4 Italy

Table 6 summarizes the SWOT analysis outcome for Italy. The identified threats are mainly related to external

factors and are less manageable than weaknesses.

The Italian normative defines important details in favor of a correct grass management, classifying and

specifying the role of agriculture digesters, which can accept only agriculture products or by-product deriving

from agro-industrial not classified like waste, from civil digesters, which are habilitated to process any kind of

organic waste and sludge from waste-water treatment plants. According to this classification grass substrates

from roadside and urban area are expected to be like a waste, meanwhile the cultivated grass or collected from

landscape management is a by-product or crop, suitable for feeding agriculture digesters. Unfortunately the

normative frame does not identify adequately borderline situations, and plant managers do not accept grass, in

order to avoid penalties.

Grass is seen like a complicated substrate requiring adequate pre-treatment (cleaning and grinding) before

applying in anaerobic digestion. Consequently relevant amounts of mowed grass are usually left in place and

used like fertilizer or sent to composting plants or dried. Composting plant receives at present the most part of

the mowed and collected grass to be used like bulking agent. Sending grass to anaerobic digester plants

reduces feedstock availability and threats composters marked and the digestate runs the risk of being

considered can be as a waste or not depending on the organic matrices entering the biogas plant

The biomethane directive has been approved but the specific legislation, defining the technical rules and the

tariff for upgrade to biomethane and its injection in network or in transportation, up to date, is still missing,

making the biogas market stationary, without motivation to introduce new substrates. The incentives for

remuneration of electric energy from biogas, which were particularly high in the years 2009-2012, suffered

great cuts and only few AD plants were put into operation since 2013. Grass has a relatively low SGP (specific

biogas potential) so incentives seem the only way for collect this material to AD plants.

19 IEE/12/046/SI2.645700 – GR3

Table 6 - SWOT result to Italy


1. The normative recognizes agriculture digesters (in which agriculture products or by-product deriving from agro-industrial not classified like waste can be used as feedstock) and civil digesters (in which are processed waste and sludge from waste-water treatment plants). The normative recognize roadside and urban grass like waste, cultivated grass like crop and grass from landscape management like a by-product but a normative frame identifying borderline situations is not defined so a lot of plant managers do not accept grass in order to avoid penalties. (Legislative/Administrative Issue)

2. Mowed grass is usually left in place and used like fertilizer or dried in place and sent to composting plants. (Operational Issue)

3. From 2013 there is a specific legislation for biogas upgrade to biomethane, but up to date, the "technical rules" and the tariff of the incentive are not defined (so biomethane is not a reality). (Legislative Issue)

4. From 2013 only few AD plants were built due to market saturation and incentives reduction. (Operational Issue)

5. Grass is see like a complicated substrate due to pre-treatment (cleaning and grinding) (Operational Issue)

1. Grass collected along roadsides contain heavy metals so it is treated like a waste and sent to civil AD plants.

2. There is a “green certificates” system for companies managing anaerobic digestion plants for waste

3. There are Incentives of 0.28€cent/kWh for 15 years yet for AD plants using agricultural feedstock

4. There is a difference in tariffs depending on the origin of biomass feedstock: the difference is between waste and residues/by-products (like manure) or products (crops) from agriculture

5. Separate collection is strongly encouraged and there has been a ban against deposit of organic waste in landfills from January 1999 so organic waste are separately collected

6. Organic wastes are typically composted or anaerobically digested and composted

7. In case of small size AD plants (i.e., < 100 kW) only a communication to the local authorities is requested.


6. The anaerobic digestate produced from waste is considered a waste and should be composted while digestate produced from agricultural feedstock can be used as bio-fertilisers. (Operational/Legislative issue)

7. Incentives, which were particularly high in the years 2009-2012, then slow down and the number of new plants was then very limited. (Market issue)

8. Composting plant receives now the most part of the mowed and collected grass and uses it like bulking agent. Sending grass to anaerobic digester plants threaten composters’ work because of the loose of feedstock.(Operational issue)

9. Grass has a relatively low SGP (specific biogas potential) so incentives seem the only way for collect this material to AD plants. (Market issue)

8. New AD plant > 100 kW should be authorized considering incentive schemes on renewable energies

9. There is an extra-tariff (bonus) related to heat recovery and nitrogen removal/recovery

10. AD plants are used both for civil and agricultural contests so they are spread on the territory

11. These grass wastes (greeneries) are composted to meet the "end of waste" definition and to be reused.

12. The market needs time to be able to deal and overcome various circumstances currently present.

13. Grass can be a strategic feedstock as it can be used as a substitute of energy crops..

20 IEE/12/046/SI2.645700 – GR3

4.5 Portugal

Table 7 summarizes the SWOT analysis results for Portugal. From this country 9 “weaknesses” and 4 “threats”

were identified, resulting in 13 barriers on total.

From a global point of view it can be appointed that biogas is still not a recognized energetic vector in Portugal

and its application is mainly driven by Anaerobic Digestion, which offers a portfolio of proven, practical and

cost effective waste problem solutions, being the biogas an interesting by-product, which can alleviate

treatment and disposal costs.

The grass cuttings from urban areas and roadside are classified as biowaste in national legislation and

consequently its collection, treatment and disposal is covered by the solid waste regulatory legislation and

relative promotional measures, but they do not contain harmful contaminants and pollutants, compared to

the urban solid food waste. The organic content is not highly putrescible, being possible to treat and dispose

them in place without creating offensive problems. They can also be transformed locally into valuable

fertilizers. Its application for anaerobic digestion is highly dependent from the local waste management

strategy. The classification of this green material as a waste is subjected to transportation and gate fee costs

for delivery that the operators cannot bear, in the competitive market price. The gate fee established by the

regional system operator is high and variable case-by-case, depending on financial needs of the operators.

This cost does not encourage the official delivery of greeneries. The biogas potential of green wastes and its

economic return is not subtracted from the gate fee tariff. The exploitation of grass potential for biogas

production involves additional costs, for grass transportation and pre-treatment, making this substrate

completely unattractive for codigestion. The tariff for energy produced from wastes is not capable to provide

adequate payback in Portugal.

The production of electrical power or biomethane by grass is not promoted by any specific feed-in tariff. Grass

wastes are incorporated in municipal solid waste regime, which does not have attractive measure stimulating

biogas production and valorization, once the investment was co-financed by cohesion funds and citizens pays

for the system exploitation. The governments try to invest the less possible amount in renewable tariffs due to

the difficult economic context. This picture may change when the government will decide to accelerate the

fulfillment of the renewable biofuel quote established for Portugal in 2020, where the biomethane can play a

relevant role. The use of biomethane as a primary source of energy is not still allowed and properly regulated in

Portugal, being an additional relevant barrier. The government agreed to the renewable directive but did not

prepared plans and the necessary regulatory framework to make feasible biomethane production. At the

moment the biomethane roadmap, which will establish tangible target and measures, has been recently

prepared by LNEG, creating the baseline for investments, but this issue is in an early stage.

The tariff of electricity from biogas digesters is too low to make feasible private investments from wastes or

any others sources. Private digesters acting on other wastes and manures are few and inappropriate. The only

investment on AD in Portugal is directed to solid wastes systems due to fulfillment of national regulation on

wastes landfilling.

The majority of operator companies for green area maintenance declared that does not have any grass wastes

available to dispose for AD. Green wastes pulverization, composting in place, burying or mulching is the

21 IEE/12/046/SI2.645700 – GR3

preferred advantageous options, as confirmed by enquires conducted by LNEG to national green wastes

operators. So a large portion of the green wastes, even the ones collected by public entities, are deviated for

the waste circuit. Some of the waste regional companies declared to receive insignificant amounts of green

trigging. Composting of green waste is a valuable alternative option to AD and It is frequently used once is

applicable locally, at small scale. If the grass does not contains pathogens produces a good quality and

appreciated saleable compost.

The costs driven by Incentives for the production of renewable energy from biogas are not inputted to the final

consumer as energetic tariff. They are assumed by the government which can remove it anytime, according to

economic context, making uncertain and risky the plans for investments from private stakeholders.

The Decree- Law n. º 73/2011 of 17 June stipulates that the operations of storage, treatment, recovery and

disposal of waste are subject to prior authorization, and must obtain an appropriate license as certified

operator, following complex and long bureaucratic procedures. The installation of AD plants in protected areas

must be approved by the Institute for Nature Conservation and Forestry (ICNF) for the granting of the license

by the CCDR, and the procedures for licensing must obey to very restrictive norm, making difficulty its

implementation.

There is not a favorable background to implement co-digestion with urban or landscape green wastes. There is

a lack of information regarding biogas potential from grass and the achievable benefits from codigestion with

other wastes. Globally solid waste AD operators have not still a clear view about the benefits from adding grass

in their digesters. This context, summed to the lack of legislative, economic and market incentives are serious

obstacles that inhibit the growth of the grass value chain. So the major barriers about biogas potential from

grass in Portuguese context are reported in table 7.

22 IEE/12/046/SI2.645700 – GR3

Table 7 - SWOT result to Portugal


1. Waste collection and transportation of Greeneries is an expensive task, not compensated in the competitive market. (Legislative Issue)

2. Companies prefers to apply local treatment/disposal solutions (composting, mulching etc..) of G.W.. (Economic Issue).

3. Green wastes are classified in the same category of biowaste in municipal solid wastes regulatory legislation. (Operational /Market Issue)

4. There is a gate fee for delivering in solid waste system. (Operational /Market Issue)

5. The biogas potential of Green wastes and economic return is not subtracted from the gate fee tariff. (legislative/Economic Issue)

6. The production of electrical power or biomethane from grass has not too a specific promotional feed-in tariff. (Legislative Issue)

7. The use of biomethane as a primary source of energy is not regulated in Portugal. (Economic Issue).

8. Composting of green waste is cost-effective solution to A.D.. (Operational Issue)

9. The location of AD plant infrastructures is far from green areas. (Operational Issue)

1. There is a feed-in tariff for the energy produced by biogas from fermentation of municipal solid waste, which includes grass.

2. Any grass producing farmer that receives subsides has to respect the Legal Management Requirements as well as the Minimal Requirements for Good Agricultural and Environmental Conditions.

3. Digestate application is a form of disposal which can improve soil fertilization, various uses in agriculture, forestry, horticulture, erosion control and restoration of degraded soils.

4. Digestate from grass waste subjected to the AD process, separately from municipal solid waste, is not contaminated and does not need to be submitted to composting or hygienisation.

5. PRODER national program for rural development offers opportunity of funding digestate valorization in the production of agricultural crops.

6. The Decree-Law n. º 73/2011 of 17 June establishes rules for waste management, including collection, transportation, storage, treatment, recovery and disposal.

7. The collection and transportation of small quantities (< 110 l) of green wastes is guaranteed by the municipal system, without additional fees. Citizens pay a fixed yearly amount for solid waste management.


10. It is difficult to implement co-digestion with green wastes. (General Issue)

11. Costs of incentives for the production of electricity through renewable sources are assumed by the government not and not transferred to the final consumer. (legislative/Economic Issue)

12. The installation of digesters in protected areas should be approved by the Institute for Nature Conservation and Forestry (ICNF) for the granting of the license by the CCDR. (Legislative Issue)

13. The storage, treatment, recovery and disposal of waste are subject to prior authorization. (Legislative Issue)

8. National program and legislation established the progressive reduction of organic matter land filling.

9. The Rural Development Program PRODER, offers financial incentives for the sustainability of rural areas which includes a “greening payment” for the sustainable management of natural resources.

10. The DL nº 237/2013 simplified licensing electricity self-consumption from biogas.

11. The production and use of electricity in decentralized facilities is today easily authorized, especially in public company facilities.

12. The transport of green waste for valorization is exempt from monitoring guideline.

23 IEE/12/046/SI2.645700 – GR3

5 CONCLUSIONS

Urban and suburban areas are rich in green areas already planted for recreational, aesthetic, leisure etc.

reasons, generating a green waste (GW) that can feed anaerobic digestion and contributes to provide fertilizing

residue resulting from digestion. Its production cost is zero, once it is supported by the beneficiaries of green

areas, presenting a favorable situation with regard to energy crops, which must be specifically cultivated and

harvested. The GW is generated within the areas served by the collection of municipal solid wastes (MSW),

another potentially favorable circumstance, if well managed. A significant percentage of GW is forwarded to

the regional MSW treatment system and eventually is converted into biogas, if any anaerobic digester is

available.

Thus, although there are many and obvious potential advantages, the digestion of grass and its energy

potential is still underutilized. In practice, this value chain suited to valorization of residual grass in biogas

plants is mostly missing in partner countries. There are several technical, not technical and economic barriers

that lead to this occurrence. Among them, the lack of awareness regarding technologies for cutting, storage

and anaerobic digestion of grass waste, beyond the scarce cooperation between value chain actors and

obstacles of a legal nature.

This work allowed uncovering the NTBs in the five countries, based on the previous report and its classification

in a SWOT analysis Matrix, obtaining a visualization of barriers and status. At final this SWOT analysis

uncovered the main advantages and disadvantages, the drivers and barriers of grass use in anaerobic

digestion for biogas production, identifying the NTBs listed in table 8 in each country. It contains a pick-list of

80 potential non-technical barriers for use of grass waste into a biogas plant across all five participating

countries.

The list of topics was based in partners’ reports and can be assumed as a good prototype of the actual status.

This list can be actualized and improved continually according to the change of the context (New regulations,

legislations, economy, policies etc.). The list of weaknesses, strengths, opportunities and threats should be

assumed as a dynamic repository that can grow with time, and thus help to more precisely identify and

overcome the local non-technical barriers.

This work of GR3 project, uncovering factors affecting the Grass use in AD, establishes a good basis for

providing guidelines, measures and policies capable to eliminate the main barriers. In this way it can enhance

Grass to AD and can be a suitable tool, not just for statistical surveys, but as an aid for discussion and

involvement of experts, politics and stakeholders.

All of the countries presented barriers in different topics, but one field is commonly highlighted by almost all:

the Legislative issues. In addition to the legal barriers identified, the second important barrier is related with

the operational and logistic of grass mowing collection to the waste system. There is an insufficient awareness

and acceptance of suitable technologies for the mowing of grass residues, storage and delivery to an

anaerobic digester, as well as the absence of cooperation between stakeholders along the value chain.

Another barrier widely identified is that grass materials from roadsides and watercourses is left on the ground

24 IEE/12/046/SI2.645700 – GR3

or spread in place, rarely transported to a composting plant due the costs of transportation and his logistic

process.

Table 8 - NTBs detected

Country Legislative/ economic

Administrat./ market

General Operational

/logistic Market Economic Agriculture Total

Germany 12 0 1 1 3 2 2 21 Belgium 6 0 1 5 1 5 1 19 Denmark 8 2 1 3 1 1 2 18

Italy 2 0 0 5 2 0 0 9 Portugal 6 0 1 2 2 2 0 13

In Europe most experiences of AD application are dedicated to the treatment of solid wastes, manures,

industrial organic wastes and energetic crops. Since the wastes have been planned to be digested, for

environmental reasons, energetic crops were coupled to waste in AD systems, thus contributing to close the

nutrient cycle. Land can accommodate adequately the digestate and, as well, provide more substrate for

biogas. For implementing these systems, favorable promotional measures have been proposed in each country,

excluding Portugal, creating high number of active units. Anaerobic digestion consolidated its role as a

favorable tool for sustainable waste management.

In countries like Germany, Belgium, Denmark and Veneto, where the anaerobic digestion is a fully mature and

well developed practice, the promotions and bonus for AD are today limited, impairing the use of grass as

feedstock. Biomethane is a good option for transport applications or to feed into the natural gas grid, but need

favorable policies to promote it. The legislation which allows gas grid injection can boost market and the

demand for more biogas and more feedstock. But Italy and Portugal did not prepare yet the necessary

regulation for application. This is under preparation. Denmark considers biomethane as an expensive

technology and Germany accept to finance only biomethane injection in the gas network, but not for

transportation.

In contrast, far less experience exists for grass use in anaerobic digestion which has not a wide application as an

organic substrate for AD. Grass could be regarded as energetic crop and take benefits from the bonus existing

in some countries (Germany). But the environmental classification attributed them the category of organic

waste, being subjected to the waste operators management and consequently to the payment of a gate fee

and transportation costs, which not encourage its valorization in AD. That classification also affects the

environmental control of this substrate, before and after AD, and before disposal or reuse, increasing analytical

determination and processing for contamination control.

However unless classified as waste, the grass properties are not so harmful or offensive as manures or the

organic fraction of solid wastes. They degrade slowly, can be left on soil, can be mulched or composted locally,

being a frequent used solution. The greatest barriers are due to the rules guiding the interface between the

municipalities and the multi-municipal or regional system of waste management and grass producers. An

established gate fee, variable from case to case (Belgium, Portugal), discourages the delivery of the GW, that

are not forwarded to the central system are buried locally or subjected to an appropriate treatment such as

grinding, composting, etc., resulting in a cost reduction.

25 IEE/12/046/SI2.645700 – GR3

It is necessary to introduce measures that stimulate interest and cooperation among all stakeholders

(producers of waste, companies which collect the grass, waste management companies, farmers, etc.), which

should dialogue to each other.

This SWOT analysis objectively demonstrates the advantages and disadvantages of Grass to AD and represents

an objective base for discussing the best options for the future of grass to AD.

6 BIBLIOGRAPHY

Glaister, K.W., Falshaw, R.J., (1999).“Strategic planning: still going strong?”. Long Range Planning, 32, (1), 107–116

Stenfors, S., Tanner, L., Syrjanen, M., Seppala, T., Haapalinna, I., (2007). “Executive views concerning decision support tools”. European Journal of Operational Research, 181, 929–938

Additional bibliography resources

BIG>EAST project EIE/07/214, deliverable 3.2,. Barriers for biogas implementation. www.big-east.eu/

Bioprom: www.bio-prom.net/

Dealtry, T.R., (1992). Dynamic SWOT Analysis. Dynamic SWOT Associates, Birmingham, UK.

Hill, T., Westbrook, R., (1997), “SWOT Analysis: It’s Time for a Product Recall”. Long Range Planning, 30, No.1, 46-52

Johnson, G., Scholes, K., Sexty, R.W., (1989). Exploring Strategic Management. Prentice Hall, Scarborough, Ontario

Karppi, I., Kokkonen, M., Lähteenmäki-Smith, K., (2001). “SWOT-analysis as a basis for regional strategies”. Nordic Centre for Spatial Development, Working Paper 2001:4, www.nordregio.se

Kaya, D., (2006). “Renewable energy policies in Turkey”. Renewable and Sustainable Energy Reviews, Vol. 10, Issue 2, 152-163 Report on the results of SWOT analysis in the selected islands

Lantz, M., Svensson, M., Björnsson, L., Börjesson, P., (2007). “The prospects for an expansion of biogas systems in Sweden—Incentives, barriers and potentials”. Energy Policy, Vol. 35, Issue 3, 1830-1843

Markovska N., Taseska, V.J, Pop-Jordanov (2009). “SWOT analyses of the national energy sector for sustainable energy development”. Energy 34 (2009) 752–756

McCormick, K., Kåberger, T., (2007). “Key barriers for bioenergy in Europe: Economic conditions, know-how and institutional capacity, and supply chain co-ordination”. Biomass and Bioenergy, Vol. 31, Issue 7, 443-452

Mintzberg, H., (1994). The Rise and Fall of Strategic Planning. Prentice Hall, Hemel Hempstead.

Mirza, U.K., Ahmad, N., Harijan, K., Majeed, T., (2009). “Identifying and addressing barriers to renewable energy development in Pakistan”. Renewable and Sustainable Energy Reviews, 13 (4) pp 927-931

Owen, D.A., (2006). “Renewable energy: Externality costs as market barriers”. Energy Policy. Vol. 34, Issue 5,

632-642

Painuly, J.P., (2001). “Barriers to renewable energy penetration; a framework for analysis”. Renewable Energy,

Vol. 24, Issue 1, 73-89

http://www.big-east.eu/

26 IEE/12/046/SI2.645700 – GR3

Prasertsan, S., and Sajjakulnukit, B., (2006). Biomass and biogas energy in Thailand: Potential, opportunity and

barriers. Renewable Energy 31 (2006) 599-610.

Probiogas. www.probiogas.es/

Rutz, D., Janssen, R., (2007). “Biofuel SWOT - Analysis”. WIP renewable Energies (published report for the project: Biofuel Market Place) www.biofuelmarketplace.com Terrados, J., Almonacid, G., Hontoria, L., (2007). “Regional energy planning through SWOT analysis and strategic planning tools. Impact on renewables development”. Renewable and Sustainable Energy Reviews, 11, 1275–1287 Weihrich, H., (1982). “The TOWS matrix – A tool for situational analysis”. Long Range Planning, 15, (2), 54–6

GR3 SWOT analysis

Documents

Transcript of GR3 SWOT analysis