Barriers to the implementation og biogas production and bio-waste management solutions

Report 2024/29

Sarah Eidsmo, Leif Grandum, Anna Bojaniwicz-Bablok, Natalia Horak, Izabela Potapowicz og Agnieszka Kuśmierz

Barriers to the implementation og biogas production and bio-waste management solutions

Category	Reports
Sub-Categories	Power and energy Climate change and the green transformation
Year	2024
Report Number	29
Author(s)	Sarah Eidsmo Leif Grandum Anna Bojaniwicz-Bablok Natalia Horak Izabela Potapowicz Agnieszka Kuśmierz
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Warsaw	, 2024	 	
 	
 	
 
 
 
Barriers to the implementation of biogas 	
production and bio	-waste 	
management	 solutions	 	
Re	port

1 	
The document 	was produced as part of the project “Green transition in practice: Demonstrating 	 	
and disseminating the benefits of producing biogas from bio	-waste”, implemented by the Institute 	 	
of Environmental Protection	-National Research Institute and Vista Analyse, fun	ded by the Bilateral 	
Cooperation Fund, the European Economic Area Financial Mechanism 2014	-2021 and the Norwegian 	
Financial Mechanism 2014	-2021	 (Norwegian and EEA 	Funds)	. 	
 	
Authors	 (in alphabetical order):	 	
The Institute of Environmental Protection 	– National Research Institute	: Anna Bojanowicz	-Bablok, 	
Małgorzata Hajto, Natalia Horak, Agnieszka Kuśmierz, Izabela Potapowicz, Agnieszka Sobol	 	
Vista Analyse	: Sarah Eidsmo	, Leif Grandum	 	
 
 	
ISBN 	978	-83	-972509	-4-9 	
 	
Publisher:	 	
Institute of Environmental Protecti	on 	- National Research Institute,	 	
02-170 Warszawa, Słowicza Street 32	 	
 	
Publication available under license: 	CC BY	 	
Authors' affiliation	: Institute of Environmental Protection	-National Research 	Institute

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Table of contents	 	
INTRODUCTION	................................	................................	................................	...................	 4 	
BARRIERS TO THE DEVELOPMENT OF BIOGAS PRODUCTION	 ................................	................	 5 	
BARRIERS TO THE DEVELOPMENT OF BIOGAS PRODUCTION IN POLAND	 ................................	 6 	
BARRIERS TO THE DEVELOPMENT OF BIOGAS PRODUCTION IN NORWAY	 ............................	 11	 	
BARRIERS TO BIO	-WASTE	 MANAGEMENT	 ................................	................................	..........	 15	 	
SUMMARY	 ................................	................................	................................	........................	 19	 	
SOURCES	 ................................	................................	................................	..........................	 21

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INTRODUCTION	 	
The biogas market in European countries is at	 varying levels of development. Despite the benefits 	
of biogas production for the environment, a closed loop economy or energy security, there are still 	 	
a number of barriers that significantly limit the possibilities for biogas and biomethane market 
develo	pment in Poland and Norway. These barriers can be divided into organisational and legal, 	
technical, economic, environmental, spatial and social.	 	
Strongly linked to the issue of biogas production is also the management of bio	-waste. 	 	
This is because biogas p	lants enable changes to be made to the management of waste from the food 	
industry and the biodegradable part of municipal waste. 	 	
The current insufficient level of selective collection of bio	-waste	 in Poland	, as well as the limited 	
possibilities for its pr	ocessing in the existing installations designed for this purpose, contribute 	 	
to the still negligible exploitation of its potential.	 One of the main documents in Poland concerning 	
waste management is the National Waste Management Plan until 2028. Among the 	targets set 	 	
in the document for municipal waste, including biodegradable waste, it is indicated, inter alia, 	 	
to increase organic recycling by promoting composting of bio	-waste ‘at source’ by inhabitants, to limit 	
landfilling of bio	-waste to a maximum of 35	% calculated on the basis of the amount of bio	-waste 	
generated in 1995. The document furthermore explicitly mentions the management of bio	-waste 	 	
in biogas plants (including agricultural biogas plants) as one way of dealing with municipal waste, 	 	
but points 	to a significant problem of insufficient number and capacity of existing biogas plants for bio	-	
waste management.	 	
Norway has for many years been one of the countries with a very high level of separate waste 	
collection. Norway's Waste Management Plan 2020	-20	25 indicates that the national goal is to aim 	 	
for waste growth to be significantly lower than economic growth and for the resources contained 	 	
in waste to be used in the best possible way through material recycling and energy use. It also noted 
the need to 	introduce and develop good solutions for the collection of bio	-waste, 	 	
both 	from households and businesses. 	 	
This 	report	 presents a set of identified barriers facing investments in municipal biogas plants 	 	
(and biomethane plants) and the bio	-waste management	 system in Poland and Norway. Identifying 	
the problems is the first step in seeking and developing appropriate solutions to reduce or remove 
them altogether.

5 	
Barriers to the development of biogas production

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BARRIERS TO THE DEVELOPMENT OF BIOGAS PRODUCTION IN POLAND	 	
Organisational and legal barriers	 	
There are several significant legal barriers to biogas plant development in Poland.	 One of the most 	
important is the lack of consistent regulations governing biogas production, which makes it difficult	 	
for investors to plan and implement biogas projects. The legal separation of agricultural biogas 	 	
from biogas derived from the processing of other substrates can lead to production start	-up problems 	
in the event of an inappropriate choice of substrates.	 	
An	 important problem is the unequal treatment of agricultural biogas plants (usually small scale) 	
and other biogas plants (e.g. municipal) in the legal system. The legal facilitations introduced 	 	
for agricultural biogas plants do not result in an increase in 	biogas production on a sufficient scale. 	 	
Also related to this is the lack of uniform regulations for the use of certain substrates in biogas plants 
(not every substrate is considered waste in different situations). The need to interpret regulations 	 	
is a ma	jor barrier to the development of non	-agricultural biogas plants. For biogas plants using 	
substrates other than those intended for agricultural biogas plants, problems with the use 	 	
of the biodegradable fraction of municipal waste are often pointed out. App	lying for a permit 	 	
to process further waste groups in a biogas plant is a lengthy process, effectively blocking 	 	
the development of the plant.	 	
The process of preparing a project, obtaining decisions and permits for a biogas plant investment 	
is long and dema	nding. Depending on the size of the planned biogas plant and the type of substrates 	
to be used in biogas production, there may be a need to undergo a full procedure 	 	
for the environmental impact assessment of the project, as biogas plants can be classified 	as projects 	
always or potentially significantly affecting the environment.	 	
A barrier which, due to the growing interest in biogas plant investments, is slowly diminishing, 	 	
is the lack of adequate preparation (knowledge) and approach of officials who issue 	decisions 	 	
and permits relating to the specifics of the installation, the technologies used and the processes carried 
out. 	 
A significant problem is the lengthy procedure for obtaining certificates for the biogas plant	-	
generated digestate, which would allow	 its use in agriculture as a soil conditioner or certified fertiliser. 	
If waste is used for biogas production, the digestate is classified as waste, which makes it difficult 	 	
to use. The possibility of using the digestate as a fertiliser or soil conditioner	 may require 	 	
the construction of a new plant, e.g. when treating sewage sludge, it may need to be hygienised 
through t	he use of highly reactive lime	. 	
Planning documents of municipalities, where biogas plants are not included or their location 	 	
is prohibite	d, are also sometimes a barrier to the location of biogas plants. Changing such a planning 	
document is time	-consuming and costly, and often impossible due to the reluctance of officials 	 	
and the local community.	 	
The lack of a stable energy policy and the ab	sence of a long	-term strategy for the development 	 	
of renewable energy is also a problem, which can create uncertainty about the future of the biogas 
sector. Biogas and biomethane are insufficiently appreciated and taken into account in the balancing 
of the	 country's energy or transport system and in the decarbonisation of the economy, 	 	
which is questionable with such a huge estimated biogas production potential.The lack of specific

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targets for biogas and biomethane in energy policy does not encourage investo	rs to develop 	
production in the sector due to the lack of prospective interest from policy makers.Interest 	 	
in the potential of biogas and biomethane in the energy, district heating or transport system is slowly 
beginning to grow, but a long time is needed 	to create the right legal conditions for market 	
development, which is not facilitated by limited (or sometimes no	) inter	-ministerial cooperation	. 	
Market development should involve both the public and private sectors. Unfortunately, 	 	
a noticeable barrier is 	the poor coordination of cooperation between these sectors, which 	could	 	
support each other in the development of legislation, technology and the improvement of knowledge.	 	
Technical barriers	 	
The technical constraints on the development of the biogas and 	biomethane market are due 	 	
to a number of factors. One of the main factors is the limited availability of technology in Poland. 	 	
The need to import technologies from outside the country is associated with longer lead times 	 	
and increased risks associated with	 potential delays. The lack of domestic technology is also linked 	 	
to the underdeveloped biogas plant servicing industry. There are limited possibilities to service 
installations or replace parts due to a lack of appropriately trained staff and the need to 	import spare 	
parts from outside the country.	 	
Biogas plants most often use biogas to produce combined heat and power (CHP) for the company's 	
own use, to ensure the proper operation of the biogas plant, including heating of the separate 
digesters (PACs) and 	the operation of the entire plant. Any surplus is fed into the grid.	 From the point 	
of view of electricity production, a barrier to the construction of biogas plants is the limited access 	 	
to connection to the electricity grid, as well as the long waiting t	ime for obtaining conditions 	 	
for connection to the grid.	 This barrier is due to the limited capacity of the transmission networks 	 	
to accept energy and the poor state of the electricity infrastructure. 	 	
A number of problems are caused by the utilisation of 	the heat produced in a biogas plant. 	 	
If the heat cannot be utilised within the plant, efficient utilisation of the resulting surplus requires 
access to a distribution network (district heating system). Due to the fact that many biogas plants 	 	
are located in	 areas far away from potential heat consumers, such as housing estates, commercial 	
buildings or industrial plants, and transporting the heat over long distances is inefficient (as it leads 	 	
to significant energy losses) and uneconomic, the heat remains unus	ed and is emitted 	 	
into 	the environment. Another issue affecting the feasibility of heat utilisation is the seasonal 	
variations 	in heat demand of both the company and potential consumers (if a connection can be built). 	 	
The demand for heat varies according t	o the season which affects the possibility of its efficient use. 	 	
In this connection, the lack of heat storage systems and the lack of mobile heat accumulators 	 	
are also important.	 	
Biogas, due to its properties, once treated and converted into biomethane, c	an be injected 	 	
into the existing gas network in the country. However, the possibilities of injecting biomethane 	 	
are limited due to the uneven availability of the network in the country. In addition, the high cost 	 	
of making the connection and the need to ad	apt the parameters of the biogas to those required 	 	
by the grid present technological and financial challenges.	 As in the case of the electricity grid, long 	
waiting times for a decision and the actual implementation of the connection due to the lack 	 	
of form	alised requirements and legislation in this regard can be a barrier to connecting to the gas grid.	 	
The demand for gas in local gas networks, used e.g. for heating purposes, is characterised

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by seasonality. In a situation of fluctuating gas demand, it would	 be a technical problem to store biogas 	
before it is injected, as biogas production is characterised by stability. In areas without a local gas grid, 
liquefaction of biogas/biomethane and transport by special vehicles to collection points could 	 	
be a soluti	on, but again the low level of infrastructure development and high costs are barriers.	 	
The biogas produced in a biogas plant, once it has been upgraded to biomethane, has properties 	
similar to those of natural gas and could therefore be used successfully a	s a propulsion fuel. 	 	
However, the underdeveloped market for natural gas vehicles (NGVs) in Poland and the availability 	 	
of refuelling infrastructure for such vehicles are barriers. A similar barrier related to limited access 	 	
to refuelling facilities is note	d for biomethane, which could be used on a wider scale in the transport 	
sector as bioCNG and bioLNG. In Poland, the first biomethane plant will not be built until 2024.	 	
The limited flexibility of a biogas plant when changing the substrate mix is also a tec	hnical barrier.	 	
The need to change substrates may result, for example, from their variable availability 	 	
(due to seasonality of agricultural production) and substrate cleanliness (e.g. degree of contamination 
of bio	-waste with other waste fractions). A chan	ge in substrate may require an adjustment of plant 	
parameters and a possible change in the process, e.g. an increase in digester temperature. 	 	
Different substrates have different methane contents, which affect the energy efficiency of the entire 
installatio	n. For some substrates, additional technical elements may be required to prepare them 	 	
for the fermentation process, such as grinding or sanitisation, which increases both investment 	 	
and operating costs.	 The lack of adequate technical infrastructure limits 	production flexibility.	 	
Economic barriers	 	
The main economic barrier is the very high investment costs for biogas plants, which increase 	
further if a biomethane plant is built. Significant costs are also those associated with the connection 
to the electrici	ty grid, which is required for the production of electricity within a biogas plant. 	 	
A connection to the gas grid can also generate high additional costs. If biogas is injected into the grid, 
the purchase of additional infrastructure to purify the biogas an	d analyse its composition before 	
feeding it into the grid is necessary. The desire to use the heat produced requires the construction 	 	
of heat distribution infrastructure, including pipelines and heat exchangers, which is also costly.	 	
A barrier to the 	development of the biogas and biomethane sector is also the limited access 	 	
to bank loans with preferential conditions for investors and the low interest in granting investment 
loans. In the absence of funding, e.g. from EU or national programmes, an invest	ment may 	 	
not be feasible. However, the operation of subsidy programmes may not solve the problem due 	 	
to the imposition of specific conditions for installations or substrates, often difficult for investors 	 	
to meet. Due to the high costs and nature of the in	vestment, the problem of insuring the installation 	
may also be a barrier.	 	
A frequent problem when applying for funding for the construction of biogas plants is the sectoral 	
approach of funding institutions. With the great opportunities offered by co	-digest	ion, i.e. the joint 	
digestion of different substrates, e.g. sewage sludge with biodegradable waste from the agri	-food 	
industry, the rules for awarding funding often limit the possibility of using different subs	trate streams 	
in a biogas plant	. 	
A significa	nt constraint for the development of the biogas and biomethane market is also the lack 	
of support for o	perating costs, which are high	. While, in the case of external funds, it is possible

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to obtain co	-fina	ncing for capital expenditures	, very often expendit	ures related to the operation 	 	
of the installation, labour costs, maintenance, repair or pre	-processing of the raw material, remain 	
unsupported. It is worth emphasising that the conditions for co	-financing capital expenditures usually 	
differ depending on th	e type of applicant 	- different rules for granting support apply for a public 	
investor, private investor or farmer. In addition, the volatility of electricity, biogas and raw material 
prices can negatively affect the financ	ial viability of a biogas plant	. 	
Biogas and biomethane production can also be affected by the biogas and biomethane guarantee 	
of origin system, which is not sufficiently developed in the country. The extension of the guarantee 	 	
of origin system for biogas and biomethane in Poland did not t	ake place until 1 January 2024. 	
Importantly, guarantees of origin can be sold, which is an additional source of revenue for producers. 
In Poland, there is one voluntary certification system, KZR INiG (Sustainability Criteria System 	 	
of the Oil and Gas Insti	tute). Holding the certificate confirms that a company producing biomethane 	 	
is pursuing a development strategy that takes into account environmental, social and governance 
cri	teria (ESG from: Environmental, Social,	 Governance). Failure to carry out the cer	tification process 	
prevents biomethane from being recognised as environmentally friendly and meeting ESG objectives. 
Being certified supports the building of a company's image as environmentally and socially responsible 
(but is not mandatory).	 	
An economic 	barrier to the development of larger biogas and, in the future, biomethane 	
installations is limited access to support schemes. Poland has a feed	-in tariff (FIT) system for RES 	
installations feeding energy into the electricity grid. The FIT scheme is design	ed for installations 	 	
with a total electrical capacity of less than 500 kW, generating energy from, inter alia, agricultural 
biogas, biogas from landfills or biogas from sewage treatment plants. It guarantees the sale 	 	
of all or part of the energy not used b	y the generator at a fixed price equal to 95% of the reference 	
price to a designated supplier or selected entity. The second system is the feed	-in-premium (FIP) 	
system, dedicated to larger installations (from 500 kW to 1 MW in the case of biomass energy 
production).	 The FIP 	system	 allows electricity from biogas to be sold at a fixed price equal to 90% 	 	
of the reference price only to an entity selected by the generator. The possibility to benefit 	 	
from the indicated support is limited in time to 17 years. The 	reference price varies depending on the 	
specific technology and plant performance and is set by regulation. Currently, the highest reference 
price applies to the smallest installations using agricultural biogas in high	-efficiency cogeneration 	 	
and amounts t	o PLN 1025 per MWh, which is more than two and a half times the market price 	 	
of energy. For a biogas plant with a capacity of less than 500 kW using only biogas obtained 	 	
from a sewage treatment plant, the reference price is PLN 572/MWh. If the energy is pr	oduced in high	-	
efficiency cogeneration, the price is PLN 714/MWh. For biogas plants between 0.5 and 1 MWh, 	 	
the reference prices are 520 and 663 PLN/MWh respectively.	 	
Environmental and spatial barriers	 	
The construction of a biogas plant, whether agricultural or on	-site, involves the occupation 	 	
and transformation of space. Given the technological considerations and storage needs, the availability 
of space for the construction and operation of a biogas pla	nt is crucial. While the lack of space 	 	
is not a problem for large farms, it can be a significant barrier for production and processing facilities 
or other businesses, as they do not always have a suitable area for the construction or expansion 	 	
of a biogas 	plant.

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Another important barrier to investment can be municipality planning documents, 	 	
in which the location of a biogas plant is often not included or is prohibited. Changing such a planning 
document is time	-consuming and costly, and often even impossible due to	 the reluctance of officials 	
and the local community. Until now, the construction of a biogas plant has involved obtaining 	 	
a planning permission (due to the frequent lack of local 	planning documents	). A recent amendment 	 	
to spatial planning regulations has 	strengthened the role of the local spatial plan	ning	. In the case 	 	
of RES installations (and biogas plants are counted among them), additional facilitations in the spatial 
planning process are possible, but they are costly for the investor. It is worth remem	bering 	 	
that the legal facilitation introduced in Poland in 2023 for the realisation of agricultural biogas plants 
in space applies only to small investments.	 	
Local authorities‘ and communities’ concerns about the possible environmental impact of biogas 	
pla	nts are also a barrier, primarily community concerns about odour emissions, as well as greenhouse 	
gas emissions, water consumption. As the substrate in biogas plants is, for example, biodegradable 
waste or manure, they can be perceived as ‘dirty’ facilitie	s that attract unwanted noise and odours, 	
which can make it difficult to obtain appropriate decisions and public acceptance. Improper 
operations, the way substrates are stored or a faulty installation can contribute to environmental 
pollution and thus have	 a negative impact on local wildlife. The impact of biogas installations, 	 	
which are often large in size, on the landscape and the pressure they put on the surrounding nature 
can also be a problem if an adequate buffer of isolating greenery is not provided 	or maintained. 	 	
As well as providing benefits for local ecosystems, including e.g. the continuity of ecological corridors, 
these buffers can also act as insulation for odour and noise, which is a key issue for neighbouring 
residential areas. The size of th	e biogas plant itself, in particular the digesters, affects the local 	
landscape and, in a legal context due to urban planning standards defining the maximum height 	 	
of buildings in the areas concerned, and in a social context in situations of visual polluti	on 	 	
or the introduction of disharmony in the landscape, can cause problems in o	btaining the relevant 	
decisions	. 	
The location of biogas plants can also raise public concerns about their perception as noise 	 	
and odour nuisance facilities. As the substrate in b	iogas plants is, for example, biodegradable waste 	 	
or manure, they can be perceived as 'dirty' facilities that attract unwanted noise and odours, 	 	
which can make it difficult to obtain the relevant decisions and public acceptance. 	 	
However, 	any irregularities	 and environmental hazards can be caught in the course of obtaining 	
permits and decisions, including the environmental decision, which aims to achieve a state 	 	
in which the biogas plant has no negative impact on the environment and meets all the required le	gal 	
standards	. 	
Social barriers	 	
Public resistance to the construction of biogas plants may be the most difficult barrier to overcome 	
in the entire investment process at any stage. For many years, the so	-called NIMBY (Not In My Back 	
Yard) syndrome has been e	ncountered in the case of various projects with the potential to cause 	
various nuisances. Recently in Poland, as a result of increased investor interest in biogas plant 
construction, there has been a noticeable increase in the negative perception of biogas	 plants 	 	
by residents in the vicinity of potential investment locations. Despite the possible benefits 	 	
of the project, people do not agree to the construction of an investment in their neighbourhood 	 	
due to fear of nuisance, especially smell. It is important	 to note here that in Poland,

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despite the discussion that has been going on for many years, there are still no regulations in place 	 	
to regulate odour air quality standards. In the absence of appropriate regulations, the fear 	 	
of worsening living conditions 	in the immediate surroundings is compounded.	 	
A significant problem for the development of the biogas and biomethane market in Poland 	 	
is the low level of environmental education among the public regarding biogas plants and waste 
management. The local commun	ity is often unaware of the benefits of the investment. Among them, 	
apart from generating energy from biogas (electricity and heat), it is worth remembering the reduction 
of energy purchase costs, as well as waste management. A persistent problem in the fi	eld of waste 	
management is the still insufficient level of knowledge regarding the proper segregation of bio	-waste, 	
which can be a suitable substrate for biogas plants. Experts point to serious deficiencies in systemic 
and widespread waste education in the	 public space, including in schools and the public media.	 	
Another problem is the lack of adequate education and knowledge among decision makers 	 	
who are involved in the investment process and have a significant influence on the success 	 	
of the process from t	he very beginning. The ‘harsh’ treatment of biogas plants in spatial planning 	
throughout Poland to date can be traced back, among other things, to a low level of awareness among 
decision	-makers about the aforementioned benefits of building a biogas or biom	ethane plant 	 	
for the local community and economy. This lack of awareness translates into a lack of understanding 
of the need for the project. This is why it is so important to spread knowledge of new technologies 	 	
and good biogas practices that can meet leg	al requirements, exp	ectations and public prejudices	. 	
Open communication and cooperation with stakeholders are key steps in convincing the public 	 	
to build a biogas plant. A very important factor is the reliability and transparency of the decision	-	
making and	 permitting process for biogas plants, which must include public participation. An important 	
role in the environmental education of the public (including officials) is played by information 	 	
and education campaigns addressed to various stakeholder groups, a	imed at broadening 	 	
the knowledge of biogas plant operation and raising the level of social acceptance for this type 	 	
of investment. Increasingly, as part of raising the level of knowledge and acceptance of local 
communities for biogas plants, study visits t	o existing installations are also organised, 	 	
which are attended not only by decision	-makers and technologists, but also the local community. 	
Allowing people to see similar investments and talking to people who had similar objections 	 	
to the investment can b	e a very good way to convince the public to invest. In turn, education on waste 	
management can bring tangible economic and environmental benefits to residents and investors	. 	
BARRIERS TO THE DEVELOPMENT OF BIOGAS PRODUCTION IN NORWAY	 	
Legal barriers	 	
The existing support systems in Norway to promote biogas production are quite unclear and it can 	
be difficult to get a complete overview. There are different support schemes for biogas use 	 	
and production, which are managed by different entities that do not	 necessarily formally cooperate 	
with each other. 	 	
Enova is the main source of government investment support for biogas installations. The support 	
programme is aimed at those who wish to start or develop existing biogas production. The Enova 
programme only 	provides investment support and there are currently no operational support 	
programmes. Both Sweden and Denmark, which have much higher biogas production than Norway,

12	 	
have production support programmes that run for a longer period . The lack of production s	upport 	
may make biogas investment too uncertain for those potentially interested in building a biogas plant. 
Enova's funding for biogas vehicles was stopped in May 2023.	 	
Market barriers	 	
Norway does not have a well	-developed gas network, unlike Denmark, so 	biogas will have 	 	
to be used in other ways. One option is to use biogas to produce electricity and heat. 	 	
However, electricity prices in Norway are relatively low due to the availability of hydropower, 	 	
which may make it difficult for biogas producers to make	 electricity production economically viable. 	
The biogas market should therefore be based on demand from other sectors. The transport sector 
could be a major customer for biogas, however, its high degree of electrification and the preference 
of large cities	, such as Oslo, for electric buses over gas buses is a significant barrier. Biogas vehicles are 	
currently uneconomic, the investment cost is 20 to 50 per cent higher and the operating costs are only 
marginally lower. The additional costs limit the market t	o those who are willing to accept the extra 	
expense to reduce greenhouse gas emissions.	 	
Uncertainty in the Norwegian biogas market is becoming a barrier to the investment process. 	
Before investing in a biogas plant, the producer should conclude a sales con	tract to be sure that his 	
product will be sold. Concluding an agreement before the investment decision makes the profitability 
of the plant more predictable. The lifetime of a biogas plant is about 20 years and the duration 	 	
of a sales contract is usually n	o more than five to ten years. In a premature market such as the biogas 	
market, this creates uncertainty about the viability of the plant and reduces the likelihood 	 	
of investment. 	 	
A barrier for biogas producers is the market and use of the digestate. At 	present, the digestate 	 	
is a cost for biogas producers and can be a barrier to potentially increasing production if they do not 
find a way to further utilise it. There is currently limited willingness to pay for the d	igestate from biogas 	
production	. 	
Barrier	s to substrate availability	 	
Uncertainty regarding access to substrates is a barrier to increased biogas production in Norway. 	
There seems to be a lack of incentives for owners of substrates that could be used for biogas 
production, recycling or energy. Fro	m January 2023, all municipalities are obliged to ensure that food 	
and garden waste from private households is sorted at source. This should have a positive impact 	 	
on access to substrates for biogas plants, but there are no regulations that require food wa	ste to be 	
used for biogas production, and composting is still a common method of processing organic waste. 	 	
At the same time, given the requirements to minimise food waste generation, there is uncertainty 
about the organic waste content of municipal waste i	n the future. 	 	
In many regions in Norway, substrate sources are widely dispersed, with some regions having low 	
populations of livestock whose faeces provide a good substrate for biogas production. 	 	
Despite the existence of subsidies given to those who suppl	y livestock manure to biogas plants, biogas 	
production from livestock manur	e is low and often unprofitable	.

13	 	
Economic barriers	 	
As in Poland, the main economic barrier to biogas production in Norway is the high investment 	
cost. In addition, due to the low 	cost of electricity in Norway, the price of biogas energy 	 	
is not competitive, so investment in a biogas plant requires investment in a biomethane plant 	 	
at the same time, which increases costs. Agricultural facilities face significant barriers in terms 	 	
of h	igh production costs, more unstable processes and varying energy demand. The economic benefits 	
of replacing electricity, natural gas or solid biofuels with biogas are minimal, as these are relatively 
inexpensive energy carriers.	 	
The profitability of biogas	 production is significantly influenced by the possibility to source 	
substrates locally. Agriculture in Norway, strongly influenced by the country's geography and natural 
conditions, is characterised by the existence of relatively small areas that are suit	able for agricultural 	
production. This makes it difficult for smaller farms to obtain enough substrate to make the investment 
in a biogas plant profitable, and the high cost of transporting substrate from longer distances reduces 
the profitabi	lity of large	r, regional plants	. 	
Small farms cannot exploit the potential for economies of scale in biogas production. Unlike larger 	
agricultural regions, where biogas plants can collect waste and other biomass from multiple sources, 
Norway's fragmented agricultural l	andscape makes it difficult to achieve the same level of efficiency 	
and profitability. Smaller biogas plants face higher unit costs, which reduces their overall profitability.

15	 	
BARRIERS TO BIO	-WASTE MANAGEMENT	 	
Bio	-waste, which is defined as biodegradable waste from gardens and parks, food and kitchen 	
waste from households, catering, including restaurants, canteens and caterers, offices, wholesalers 
and retail units, and similar waste from establishments producin	g or marketing food, is one of the 	
groups of substrates that are used in municipal biogas plants. They are characterised by a relatively 
high biogas production capacity. However, the lack of proper bio	-waste management limits the biogas 	
production potentia	l from this stream. Selectively collected waste (of all fractions) in 2022 accounted 	
for about 40% of the total collected municipal waste in Poland (for comparison 	- in Norway over 80%). 	
Bio	-waste collected selectively in Poland in the same year accounted 	for 14.3% of the total waste 	
collected. However, in the stream of mixed (non	-segregated) waste collected, bio	-waste constitutes 	
about 30% of its content.	 	
Despite the steadily increasing level of separate collection of municipal waste, including bio	-waste, 	
municipalities responsible for waste management in their area face a number of barriers to effective 
waste management. Barriers of a legal nature are very important, especially the multiplicity of legal 
acts relating to bio	-waste management and their frequ	ent amendment. In both Poland and Norway, 	
waste management issues are regulated in several legal acts. The lack of comprehensive legislation 
may effectively hinder the organisation of an efficient waste collection, collection and treatment 
system. At the E	uropean level, the lack of an effectively binding policy or legal obligations to achieve 	
minimum standards for separate waste collection is cited as a significant barrier. It is stressed 	 	
that current policies that focus on recycling and landfill targets ar	e not effective enough to lead 	 	
to the implementation of the envisaged changes in waste collection. The differing approaches of local 
authorities in interpreting and enforcing legislation is also a significant legal problem.	 	
Moreover, the targets set in leg	al documents and policies for the level of waste segregation 	 	
are sometimes difficult to achieve due to the lack of prior adaptation of the infrastructure for waste 
management. In 2022, nearly 26% of selectively collected bio	-waste in Poland was sent to lan	dfill 	 	
after stabilisation, instead of being subjected to an appropriate comp	osting or fermentation process	. 	
In order to start a comprehensive, selective collection of bio	-waste and subsequent treatment, 	
facilities for bio	-waste treatment must first be avai	lable. This is one of the main obstacles to be solved 	
in many European countries, which requires a long lead time and legal/administrative resources.	 	
A frequently indicated barrier is the low level of environmental awareness, regardless of the level 	
of eco	nomic development of the country. Waste management education, which is part 	 	
of environmental education, is a very important element affecting the lives of all inhabitants. 	 	
Experts point out significant deficiencies in systemic and widespread waste manageme	nt education 	 	
in public spaces, including schools and public media. Conducting various information campaigns should 
support the public education system from the youngest grades, but it is important to reach all age 
groups with knowledge. It is very importan	t to educate and inform residents on a continuous basis. 	
This is because residents are part of the whole organisational structure and waste management 
system, as they are key actors in terms of separate collection and participation in the system 	 	
(and its f	inancing). Different municipalities may have slightly different guidelines for segregation, 	
especially for bio	-waste, which may cause problems for proper segregation in the case of people 	
changing their place of residence temporarily or permanently. Notice	able differences can also be seen 	
between countries 	- in Norway, unlike in Poland, meat leftovers, bones, fish, leftover soiled paper 	 	
or tea bags and coffee filters are disposed of as bio	-waste.

16	 	
A major problem is the level of qualification of municipal em	ployees and companies. 	 	
Education and training is needed for the employees of municipalities and businesses due to changing 
legislation and the development and modification of the waste collection system. The government's 
interaction with municipalities, as	 organisers of the waste collection system and thus the most 	
important link in the entire system, cannot end with communicating the rules and setting targets 	 	
to be achieved without appropriate educational activities. The different conditions found 	 	
in the i	ndividual municipalities, as well as the changes that occur over time, mean that waste 	
management systems must be monitored, adapted and updated on an ongoing basis to fit local 
conditions. Overcoming this barrier requires skilled people and knowledge deve	lopment. 	 	
In smaller towns or rural municipalities, where the number of inhabitants and households is smaller 	
and more dispersed than in large urban centres and agglomerations, a major problem is to adapt the 
frequency of waste collection, including bio	-wa	ste, which requires more frequent collection due to its 	
characteristics to the expectations of the inhabitants. Bio	-waste, especially during higher temperatures 	
(spring and summer seasons), generates odours, tends to rot and attract insects and rodents, 	 	
wh	ich is problematic in both single	-family households and in multi	-family housing. In addition, the high 	
variability in the amount of waste generated at different times of the year (greater production of bio	-	
waste, including green waste from gardens during t	he growing season) translates into the need to vary 	
the frequency of	 collection throughout the year	. 	
A popular solution used by municipalities with smaller populations across Europe is to encourage 	
the composting of biodegradable waste (kitchen and green w	aste) in home composters, 	 	
e.g. by introducing fee reductions. This reduces the extent to which waste management is carried out 
in the municipality and the costs incurred, and thus the fee for household waste collection. The home 
composting solution, howeve	r, limits the availability of bio	-waste to the collection company and thus 	
limits the supply of potential substrate for the biogas plant. Furthermore, from a financial point 	 	
of view, the amount of relief for individual composting is perceived by residents 	as very low in relation 	
to the monthly fee for bio	-waste generation and is judged to be disproportionate to the mass 	 	
of the bio	-waste stream and the costs of collection and tre	atment in industrial facilities	. 	
A significant problem is also the lack of suffi	ciently effective tools to control the quality of separate 	
collection of bio	-waste, especially in multi	-family housing. A sense of anonymity among residents often 	
leads to inappropriate segregation of municipal waste. Due to staff shortages in companies, 	 	
as well as the increasing costs of the waste management system, companies and municipalities are not 
able to carry out sufficiently effective control, including control of backyard composters. 	 	
However, ideas are emerging for solutions to increase the effect	iveness of quality control of selective 	
collection, such as a system of red warning cards and the imposition of financial penalties (increased 
fee), as well as a system of individual barcodes for wa	ste bags (e.g. in Mszana Dolna)	. 	
The economic barrier is t	he overhead, investment and operating costs associated with ensuring 	
the operation of the waste management system. As in the case of biogas investments, 	 	
also in the construction of other waste treatment facilities, investment costs may determine 	 	
the non	-im	plementation of investments and the development of the system. Due to the organisation 	 	
of the system and the need for the waste management system to be self	-financed from residents' fees, 	
raising funds for investment is very difficult. External funds, e.g.	 from the EU and various types 	 	
of subsidies as available, can help here. In the case of limited financial resources and the possibility 	 	
to increase them, municipalities do not take steps to modernise or modify the bio	-waste management

17	 	
system. The possibili	ty of agreements/contracts between municipalities for joint waste collection 	
services (including bio	-waste) or operation of treatment facilities (economic scale efficiency) is helpful 	
in reducing costs as well as increasing the efficiency of waste manageme	nt. Such inter	-municipal 	
associations are relatively popular in Norway, while they are less common in Poland and usually	 involve 	
smaller municipalities	.

19 	
SUMMARY	 	
This report identifies a number of barriers to biogas production and improved bio	-waste 	
management in Poland and Norway, some of which are similar in both countries, while others depend 
on country specifics and internal conditions. 	 	
In Poland, legal, techn	ical and economic barriers prevail. The lack of domestic technology 	
contributes to higher investment costs. Social barriers are also important, pointing to the need 	 	
for continuous education. Many of the legal and economic barriers have their sources indire	ctly 	 	
in the still present lack of knowledge of Polish society and authorities about the benefits of biogas 
production. Vagueness or misinformation resulting from lack of knowledge consequently leads 	 	
to a mostly reluctant attitude of the general public. 	 	
In Norway, on the other hand, social and technological barriers are less important, and economic 	
barriers are more important, as the need to treat biogas to biomethane and transporting it significantly 
increases investment costs.	 	
In terms of bio	-waste manage	ment, the underdevelopment of bio	-waste management facilities 	
(including an insufficient number of biogas plants) can be highlighted among the barriers. 	 	
Complicated regulations, the number of legal acts and their frequent updates introduce uncertainty 
abou	t the future functioning of the waste management system and the biogas market. 	 	
The Norwegian and Polish achievements to date are the results of very good cooperation between 	
the municipal and private sectors. In view of the new objectives facing waste man	agement, 	 	
support is needed for local governments in implementing activities related to green transformation 
and the closed loop economy. As part of this support, there is a need to increase communication, 
education and public awareness, and to build and ex	pand networks of expert stakehold	ers at all levels 	
of governance	.

21	 	
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