In VGB PowerTech 6, 2013 Yves Ryckmans from Laborelec wrote in the foreword that he estimated that 70 % of the renewable fuel in some of the EU member states would come from wood or similar forest products by 2020. This was a goal set by the EU as a common goal to combat climate changes. His remark was related to the fact that increased consumption would lead to in-creased import of wood for energy purposes to the EU countries.

Now 5 years after, the EU has set a new target 32 % of renewable energy to be reached by 2030 in the hope to further reduce carbon dioxide emissions. The EU Commission has also issued recommendations on sustainability criteria for biomass. These recommendations are meant to apply to energy installations of at least 1 MW thermal heat or electrical power. They:

forbid the use of biomass from land converted from forest, and other high carbon stock areas, as well as highly biodiverse areas

ensure that biofuels emit at least 35 % less greenhouse gases over their lifecycle (cultivation, processing, transport, etc.) when compared to fossil fuels. For new installations this amount rises to 50 % in 2017 and 60 % in 2018

• favour national biofuels support schemes for highly efficient installations
• encourage the monitoring of the origin of all biomass consumed in the EU to ensure their sustainability
• In the rush for increasing the use of biomass, the necessary considerations of the utilization of the concurrent production of Bio Mass Ash ( BMA ) has somehow been forgotten.

Since 2013 there have been a European Working Group Bio Mass Ash organised by the VGB organisation based on a previous working group of interested parties. The purpose is to bring together available information on BMA in the EU countries. There have been several meetings with extensive exchange of valuable information. The idea was to present a report outlining legisla-tion, economics, taxes, development and research, produced volumes, quality of products etc. The group have managed so far to provide a paper with a briefing of the main topics, and at the same time indicating that there are massive differences between the EU member states as to the use of BMA. It should not be forgotten that the longstanding success of utilization of hard coal ash cannot be copied to the use of BMA. The differences are all to prevalent. BMA cannot just replace hard coal ash.

Since 2013 there have been realised a substantial growth in the use of Bio Mass in some of the member states as it was already foreseen in 2013. We can notice that the development of new ideas for the utilization of BMA has not failed. At the same time, it is now also clear that future solutions now seem to favour the use of BMA as fertiliser and for soil improvement in order not to deplete the soil of potentially necessary nutrients, more than any other use.

The IEA is preparing a major report with more knowledge on the BMA situation in most OECD countries. This edition of VGB Power Tech will provide insight to some of the utilizations of BMA that have been investigated or in use since 2013. Unfor-tunately, we must also realise, that the optimal way forward may not yet have been found. Not so much from a technical point of view but rather from taxation/economic, legislative and perceptive points of view.

Taxation of the use of waste and by-products seems to be a never-ending challenge. One could argue that a high tax on products destined for landfilling for whatever reason ( like e.g. legislative or perceptive ) will urge the development of suitable processes to use products rather than waste a potentially valuable material. So true this may be, and at the same time it imposes a sub-stantial economic risk for these companies, institutions, universities etc who invest money or effort for the greater good and may finally realise that the investment was lost due to external reasons. The devil in this context is the fact that member count-ries of the EU does not share common taxation practices. In some countries the cost of landfilling waste is massive and in some other countries it is non-existent. As a natural consequence parties in some countries may want to develop with the potential of earning the investment whereas in other countries there is no possible profit to be made to omit landfilling and promote the utilization or recirculation that is a mantra for the EU these years. There is also a taste of uneven conditions for competitions linked to this observation.

The legal framework for utilization of BMA is important. BMA may be produced in one country but finds a better use in another country. This also fits well with the notion from 2013 that some countries may need to import wood while others may find a business of using natural given resources and export wood products for energy purposes. So, when a BMA needs to find its home there should be made a reference to a fertiliser regulation. On the EU level such a regulation exists since 2003 but only covers chemically produced fertilisers. Luckily – however there is a massive scientific works in progress initiated by the EU Commission, the so called Strubias project with the aim of providing a solid platform for including BMA as part of future fertili-ser regulation. The intention is to implement a fully harmonised regulation with the same consequences in all EU countries. Once the project is finalised there needs to be a long decision route via the Commission, the Parliament and other units of the EU. So, these procedures could last years. The EU legislation also hit on a different level – transportation. When wishing to transport BMA from one EU country to another ( let alone the hassle of exporting beyond the EU borders which may be the case provided import of wood from outside EU ) the exporter will be faced with the trans frontier regulation. This calls for a massive paper work. Since BMA is not listed in the old OECD/Basel list of waste it is considered NON-LISTED and therefore the troublesome procedure with notification starts to apply with all that it requires, although not-dangerous. Also, if a company wants to sell the BMA for all the good it can do then it requires a REACH registration with ECHA to bring the product to the market. The present indications from the Strubias project seems to offer a way around this obstacle. What remains is the fact that the environmental legislation is interpreted different in all EU countries. In some countries there is a trend to go for the most rest-rictive interpretations.

Perception is very important – yet often forgotten. When large users of bio mass for fuel ( like the members of VGB ) purchase biomass they need to comply with the rulings laid out by, say Forest Stewardship Council ( FSC ) in order to ensure sustainable growth and use of the forests. At the same time FSC and similar organisations are reluctant to consider the fact that bringing BMA back to the forests may be a justified idea insofar a forest needs some of the nutrients collected in the BMA. So, unless organisations like FSC actively supports recirculation of BMA forest owners may not want to consider that option at all since it could potentially conflict with rulings of sustainability as laid out by the sustainability organisations. Scientific proof and mas-sive information may be needed and should be addressed by e.g. VGB in close cooperation with involved, international organisations.

Important information from universities have recently shown that phosphorous present in BMA may be more readily useful for plants and trees than perceived until now. This may call for widening the scope of utilization to farmland and at the same time also promote ideas to develop mixed products based on different ash sources to better satisfy the utilization of BMA.

It is the hope that not only privately and publicly funded utilization projects will continue but certainly that legislation and taxation will pave the way for an improved possibility to utilise BMA in the future, Therefore the wish from the VGB Working Group Bio Mass Ash is also that this edition of VGB Power Tech may give inspiration to facilitate future use of BMA. In the me-antime, we will need to wait for a harmonised fertiliser regulation within the EU.