SWOT ANALYSIS. Project website: Date of publication: June 2015

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1 SWOT ANALYSIS Date of publication: June 2015 Author(s): Santino Di Berardino, Luis Silva, João Bidarra LNEG, Portugal IEE project : Project website:

2 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. 2

3 Table of Contents Table of Contents... 3 Table Index... 4 Figure Index Summary Introduction Identification and mapping of potential NTB s Methodology Description of the S.W.O.T. Analysis S.W.O.T. analysis results for each country Germany Belgium Denmark Italy Portugal Conclusions Bibliography

4 Table Index Table 1: Countries overview... 7 Table 2: Topics selected for SWOT analysis... 8 Table 3 - SWOT result to Germany Table 4 - SWOT result to Belgium Table 5 - SWOT result to Denmark Table 6 - SWOT result to Italy Table 7 - SWOT result to Portugal Table 8 - NTBs detected... Fout! Bladwijzer niet gedefinieerd. Figure Index Figure 1- SWOT Analysis matrix cell

5 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 5

6 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. 6

7 Table 1: Countries overview 1 GERMANY (D) BELGIUM (B) PORTUGAL (PT) DENMARK (DK) Population [x10 6 ] Municipal Waste [x10 6 t/year] ,9 4,7 3,7 2,3 VENETO (IT) Municipal biowaste [x10 6 t/year] ,78 0, Number of digester (N) Biogas production [ m 3 /year x 10 6 ] ,7 23,8 97,9 25 Grass potential [t/year] 2 2,975, ,026,917 1,113,000 3 Biogas Production from Grass [ m 3 /year x 10 6 ] 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 7

8 Table 2: Topics selected for SWOT analysis Topics Legislative/Administrative issues General Issues Operational/Logistic Issues Market Issues Economic 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. 8

9 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. Negative Positive Internal Weaknesses Strengths External Threats SWOT Opportunities Figure 1- SWOT Analysis matrix cell 9

10 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 nonwastes 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. 10

11 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. 11

12 Table 3 - SWOT result to Germany Weaknesses 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) Threats 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 Strengths 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). Opportunities 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 Due to the biomethane goals in Germany, the regulations could be improved again in 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. 12

13 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. 13

14 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 pretreatment 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. 14

15 Table 4 - SWOT result to Belgium Weaknesses 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) Threats Strengths 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 Opportunities 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 onsite. 9. In spite of support be limited on time, the GSC s provides a minimum guaranteed support for both installations (old and new). 15

16 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 % 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. 16

17 Weaknesses 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 % 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) Threats 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) Strengths 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 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 manurebased 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 Opportunities 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 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. 17

18 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 , suffered great cuts and only few AD plants were put into operation since Grass has a relatively low SGP (specific biogas potential) so incentives seem the only way for collect this material to AD plants. 18