Opinion of the European Economic and Social Committee on the Communication from the Commission to the Council and the European Parliament: Sustainable power generation from fossil fuels: aiming for near-zero emissions from coal after 2020 COM(2006) 843 final
Date: 2007-09-27
Institutions: European Economic and Social Committee
Subjects: coal, electrical energy, energy production, environmental protection, fossil fuel, pollution, power plant, reduction of gas emissions, research and development

15.1.2008

EN

Official Journal of the European Union

C 10/39

Opinion of the European Economic and Social Committee on the ‘Communication from the
Commission to the Council and the European Parliament: Sustainable power generation from fossil
fuels: aiming for near-zero emissions from coal after 2020’

COM(2006) 843 final

(2008/C 10/10)

On 10 January 2007 the European Commission decided to consult the European Economic and Social
Committee, under Article 262 of the Treaty establishing the European Community, on the abovementioned
proposal.

The Section for Transport, Energy, Infrastructure and the Information Society, which was responsible for
preparing the Committee's work on the subject, adopted its opinion on 5 September 2007. The rapporteur
was Mr Zboril.

At its 438th plenary session held on 26 and 27 September 2007 (meeting of 27 September 2007), the
European Economic and Social Committee adopted the following opinion by 135 votes to 1 with 4 absten-
tions.

1. Conclusions and recommendations

1.1
The EESC welcomes the Commission's communication
and agrees with the analysis and description presented in the
Commission document. Responding effectively to the risks of
global climate change while continuing to meet the high energy
demands is a significant international challenge.

Emissions of CO2 from coal fired power plants in the EU
1.2
make 24 % of overall (EU) CO2 emissions. Thus, such power
plants are the most suitable sites for installation of CCS facilities.
It means implementation of systems of capture and permanent
storage of CO2.

1.3 Most probably, coal would remain in the European
energy mix in the decades to come. Coal's particular attributes
— its availability, affordability and role in stabilising energy
it continues to be a primary
markets — will ensure that
source of fuel for the economic generation of electricity. The
coal reserves distribution is uneven in the world and in the EU.
Coal-based technology has the potential to make significant CO2
emissions reductions (1).
this
requires market and regulatory frameworks that encourages
investments in the latest technologies that will improve the effi-
ciency of coal-fired electricity generation and thus
reduce
specific CO2 emissions.

In the short to medium term,

practical and commercial potential. The transition to sustainable
energy has a major role for coal, other fossil fuels, and nuclear
as well as renewable technologies and energy conservation, with
each contributing at a time and to an extent dictated by tech-
nical feasibility and affordability.

1.6
The EESC appreciates that in the long term, after 2020,
CO2 capture and storage would offer the potential for near-zero
CO2 emissions from coal-based power plants. There is a need
for about 350 GW of new electricity generating capacity coal
fired by 2020 and about 500 GW by 2030, the estimated
investment costs amount EUR 600-800 billion. Delivery of this
option requires coordinated research, development and demon-
stration (RD&D) now.

1.7 With continued efficiency enhancements in the power
plant field and the development of near-zero emission technolo-
gies, coal will contribute to meeting the requirements of preven-
tive climate protection. However the promising experiences CCS
it must not lead to the effect that already now energy
gives,
policy strategies and targets are adopted as ‘a binding measure’
on the basis of broad presence of the CCS technologies.

1.4
Proven cost-effective commercial means for removing
and sequestering most of the CO2 emissions from coal-based
power plants do not currently exist; it is still an emerging tech-
nology. However, the prospects for developing and commercia-
lising such near-zero emission coal technologies (ZETs) over the
next two decades are promising.

Simplification of

1.8
licensing procedures as well as their
gradual harmonisation through cooperation between national
regulatory authorities is needed in order to cut down as far as
possible the long lead times for construction projects, without
compromising the observation of the highest safety standards.

The EESC confirms its opinion that the scale of the emis-
1.5
sions limitation challenge means that all potentially viable
energy sources and technologies need to be developed to their

(1) IPCC, 2005: IPCC Special Report on Carbon Dioxide Capture and
Storage. Prepared by Working Group III of the Intergovernmental Panel
on Climate Change (Metz, B., O. Davidson, H. C. de Coninck, M. Loos,
and L. A. Meyer (eds.)). Cambridge University Press, Cambridge, United
Kingdom and New York, NY, USA, 442 pp.

1.9
The EESC also draws attention to the fact that though
the most important fuel for electricity generation and a vital
input into steel production and other industrial processes, coal
will have a major role to play in meeting future energy needs
assisting in transition towards hydrogen economy. Coal liquefac-
tion allows coal to act as a substitute for crude oil; synthetic gas
can also be produced from coal.

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1.10
For extraction of indigenous lignite and hard coal, an
appropriate political and economic framework remains neces-
sary. The extraction of coal and transformation of energy can
significantly contribute to local prosperity and employment.
Maintaining the fossil fuel (coal based) power generation share
at its current level is also extremely important in view of the
social situation in the new Member States: out of 286 500 total
manpower in the EU coal mining industry, the new MS coal
Substantial
mining
improvement of very hard working conditions of miners, their
skills, labour safety and working environment must be in focus
of the mine operators throughout the EU coal industry.

employs 212 100 workers.

industry

2.3
The other parts of the package cover firstly a proposal
for climate change targets of 30 % reductions of greenhouse
gases for the developed countries or in any case 20 % for EU
alone. The package further deals with the internal market of gas
in the electricity and gas
and electricity,
networks,
the
Nuclear Illustrative Programme; a roadmap to promote renew-
ables, notably biofuels for transport, and a future European
Energy Strategic Technology Plan. The European Council on
9 March 2007 supported the targets and the main policy
contents of the package.

future role of nuclear energy in proposal of

interconnections

1.11
The EESC also expresses its thought that the Commis-
sion in this document and its time setting is optimistic on the
CCS time-frame and its lead-in time requirements. The Commis-
sion should now focus on measures to help 10-12 demonstra-
tion plants to be operated in 2015 and to create a framework
for CCS that covers the main risks, is reliable and, at the same
time, not too restrictive. Intermediate stage of higher efficiency
generation is highly desirable and any excessive haste and too
restrictive regulatory framework could seriously damage this
globally important concept.

2.4
the
This Communication presents a global view of
actions needed for the continued contribution of fossil fuels and
particularly coal to the security and diversification of energy
supply for Europe and the world in a way compatible with the
sustainable development strategy and climate change policy
objectives.
It takes account of the work done and opinions
received during 2006 within the Second European Climate
Change Programme (ECCPII), the High-level Group on Competi-
tiveness, Energy and the Environment (HLG), the preparations
for the 7th Framework Programme (FP7) for Research, and the
Zero Emission Fossil Fuel Power Plant Technology Platform.

1.12
The EESC also calls for intensive research and develop-
ment as regards the renewable and alternative energy sources
that should contribute towards a safe EU energy mix. Simulta-
neously,
the integrated EU energy market should be fully
brought into life without any excessive delay.

3. The Commission document

2. Introduction

2.1
The Committee has already dealt with fossil fuels issue in
several of its other opinions, the most recently in the explora-
tory opinion ‘The energy supply of the EU: a strategy for an
optimal energy mix’ (2) which states that the EU should put
serious efforts into clean coal technologies — improved power
plant efficiency and commercial applications of carbon capture
and storage. The use of gas has increased and still increases also
driven by political choices. It is now obvious that the continua-
tion of this trend is problematic. Gas can hardly continue to
substitute coal, nor can gas substitute nuclear for reasons of
emissions since it is a valuable raw material for high added
industrial use, as is also oil.

2.2
The present draft Sustainable power generation from
fossil fuels was published by the Commission in the context of
the energy and climate package, ‘An Energy Policy for Europe —
the need for action’, on 10 January 2007.

(2) OJ C 318, 23.12.2006, p. 185-194.

3.1
The Commission's document reviews the position of
fossil fuels in the energy generation ands states that fossil fuels
represent an important element of
the energy mix in the
European Union as well as in many other economies. They are
of particular importance for the generation of electricity: over
50 % of EU electricity currently comes from fossil fuels (mainly
from coal and natural gas)
in some countries their share
amounts even 80 % (Poland, Greece). Coal is a key contributor
to the EU's security of energy supply and it will remain so. Coal
represents the fossil fuel with by far the largest and most widely
distributed global reserves, estimated to last for some 130 years
for lignite and 200 years for hard coal.

3.2
However, coal can continue to make its valuable contri-
bution to the security of energy supply and the economy of
both the EU and the world as a whole only with technologies
allowing for drastic reduction of the carbon footprint of its
combustion. If such technologies are developed on a sufficient
scale, they can also provide solutions for combustion processes
using other fossil fuels,
including gas-fired power generation.
The EU therefore needs to develop technological solutions for
sustainable use of coal not only to retain coal in the European
energy mix but also to ensure that global growth in coal use
will be possible without
irrevocable damage to the global
climate.

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3.3
‘Clean Coal’ technologies have been developed and they
are now widely used in the power generation sector, consider-
ably reducing emissions of SO2, NOx, particulates and dust from
technologies have also
coal-fired power plants. Clean Coal
brought about a steady increase in the energy efficiency of the
conversion of coal into electricity. Such achievements are impor-
tant steps for further progress towards novel technological solu-
technologies incorporating the
tions called ‘Sustainable Coal’
concepts of CO2 capture and storage (CCS) in coal-based power
generation.

3.8
The Commission considers that a clear and predictable
long-term framework is necessary to facilitate a smooth and
rapid transition to a CCS-equipped power generation from coal.
This is necessary to enable power businesses to undertake the
required investments and research in the secure knowledge that
their competitors will be following a similar course. On the
basis of the information currently available, the Commission
believes that from the year 2020 all new coal-fired power plants
should be built with CCS facilities. Existing plants should then
progressively follow the same approach. The Commission will
evaluate what is the optimal retrofitting schedule for fossil fuels
power plants for the period after the commercial viability of
Sustainable Coal technologies is demonstrated.

3.4
The Commission sees a fair chance of achieving the
commercial viability of Sustainable Coal technologies in the
next 10 to 15 years. This will, however, require bold industrial
investments in a series of demonstration plants, both within
and outside the EU, and related policy initiatives for a relatively
extensive period of time, starting practically now and lasting
possibly until 2020 or even beyond.

To facilitate such development

3.5
the Commission will
substantially increase the funding for R&D in the energy area,
introducing the demonstration of Sustainable Fossil Fuels tech-
nologies amongst the priorities for 2007-2013. A European
Strategic Energy Technology Plan will provide a suitable
instrument
the overall coordination of such R&D and
demonstration efforts and for the maximisation of synergies at
level. The Commission will determine,
both EU and national
based on successful results of
the most
the R&D projects,
suitable way to support the design, construction and operation
of up to 12 large-scale demonstration units of Sustainable Fossil
Fuels technologies in commercial power generation by 2015.

for

3.6
The Commission will assess on the basis of recent and
planned investments whether new fossil fuels power plants built
and to be built
in the EU use best available technologies
regarding efficiency and whether, if not equipped with CCS, new
coal- and gas-fired installations are prepared for later addition of
CCS technologies (‘capture ready’). If this turns out not to be the
case, the Commission will consider proposing legally binding
instruments as soon as possible, after a proper impact assess-
ment.

3.9
Cost estimates for CO2 capture from power generation
and subsequent storage at the current level of technology devel-
opment range up to EUR 70 per tonne of CO2, rendering the
large-scale use of these technologies prohibitively costly for the
time being. Available models and studies with a medium- to
long-term perspective thus estimate the costs of CCS by 2020
at about EUR 20-30/t CO2. This translates in the models to
costs of coal-fired power generation with CCS by 2020 or soon
afterwards at just 10 % above or even on the par with the
current levels.

The potential negative environmental

impacts from
3.10
sustained use of fossil fuels and the deployment of CCS stem
mainly from potential leakage from CO2 storage. The leakage
impacts can be both local (on local biosphere) and global (on
climate). However, the International Panel on Climate Change's
report on the issue concludes that, based on existing experience,
the fraction of CO2 retained in well-selected and managed
storage sites is very likely to exceed 99 % over 100 years. Site
selection and management are thus the key factors for mini-
mising risk. The Commission impact assessment for enabling
identify all potential risks and will put
legal framework will
forth appropriate safeguards.

In 2007, the Commission will assess the potential risks
3.7
from CCS and lay down requirements for the licensing of CCS
activities and for adequately managing the risks and impacts
identified. Once a sound management framework is developed,
it can be combined with changes to the existing environmental
regulatory framework at EU level so as to remove any unwar-
ranted barriers to CCS technologies. The Commission will also
assess whether to amend existing instruments (such as the Envir-
onmental Impact Assessment Directive or the Integrated Pollu-
tion Prevention and Control Directive) or propose a free-
standing regulatory framework. It will assess which aspects of
the regulatory framework are preferably addressed at EU level
or, alternatively, at national level.

3.11
Sustainable Fossil Fuels technologies, and particularly
CCS, are expected to deliver significant positive results. They can
effectively eliminate up to 90 % of the carbon emissions from
fossil fuels power plants. This could translate into an overall
reduction in EU-27 CO2 emissions of 25-30 % by 2030
compared to 2000. An early involvement of third countries in
the development and deployment of Sustainable Coal technolo-
gies and particularly the CCS component is essential for sustain-
able global economic development and for tackling climate
change in a scenario with increasing global use of coal
resources. The success of Sustainable Coal and particularly the
commercialisation of CCS on a large scale will also offer better
access to energy in the poorest parts of the world still deprived
from the chance to use energy.

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4. General remarks

4.1
The EESC welcomes the Commission's communication
and agrees with the analysis and description presented in the
Commission document. Responding effectively to the risks of
global climate change while continuing to meet the high energy
demands of mature economies and the rapidly increasing energy
demands of developing economies, is a significant international
challenge.

4.2
Emissions of CO2 from coal fired power plants in the EU
make 24 % of overall (EU) CO2 emissions. The emissions from
power generation in plants fired by fossil
fuels are highly
concentrated due high consumption of fuels in large combus-
tion units and thus, such power plants are the most suitable
ones for installation of CCS facilities. It means implementation
of systems of capture and permanent storage of CO2. Such
systems consist of three relative independent stages:

a. Capture and separation of CO2 from flue gas in the place of

occurrence (behind a boiler mostly)

b. Transport of CO2 to the locality of its permanent storage

(mostly by pipelines)

c. Final and permanent storage of CO2 (in suitable geological
formations or in seas observing the most stringent safety
storage requirements).

fuel

4.3 Most probably, coal would remain in the European
energy mix in the decades to come. Coal's particular attributes
— its availability, affordability and role in stabilising energy
markets — will ensure that it continues to be a primary source
of
for the economic generation of electricity. The coal
reserves distribution is uneven in the world and in the EU.
Globally,
it is encouraging that the largest coal reserves are
found in the economically advanced and politically stabile coun-
tries. The reserves in developed EU countries have been largely
depleted by long time mining activities in the recent period of
time and several EU countries opted for gradual reduction and
even cease of coal mining.

4.5
Coal-based technology has the potential to make signifi-
cant CO2 emissions reductions (3). In the short to medium term,
this requires market and regulatory frameworks that encourage
investments in the latest technologies that will improve the effi-
ciency of coal-fired electricity generation and thus
reduce
specific CO2 emissions. Collaborative action by the Commission,
MS governments and industry is also required now to encourage
worldwide coordinated research, development and demonstra-
tion of clean coal technologies such as carbon capture and
storage, which will
in the longer term deliver near-zero CO2
emissions from the use of coal.

it

4.6
Proven cost-effective means for removing and seques-
tering most of the CO2 emissions from coal-based power plants
is still an emerging technology.
do not currently exist;
However,
the prospects for developing and commercialising
such near-zero emission coal technologies (ZETs) over the next
two decades are promising. CCS installations in power plants
are assumed to reduce the power generation efficiency because
in their intrinsic power consumption. The overall efficiency
differs by the used technology, the preferred OXYFUEL tech-
nology needs 8 to 10 % of the generated power and the other
technologies require even more power by themselves. It means
that more fuel would be required per MWh of power supply in
the grid and higher generating efficiency is essential. Future CCS
retrofits would show even larger
intrinsic consumption of
power for their operation.

4.7
In the interim, improving the efficiency of existing and
new coal-fired power plants is a cost-effective way to limit the
growth of CO2 emissions. The installation of best available
commercial technology should be a focus of planners for the
significant amount of new coal-fired capacity that must be built
in the near term. Where practical,
it is highly desirable that
these power units are designed to enable cost-effective CCS
for
retrofitting when that
commercial application.

technology becomes

available

4.8
The EESC confirms its opinion that the scale of the emis-
sions limitation challenge means that all potentially viable
energy sources and technologies need to be developed to their
practical and commercial potential. The transition to sustainable
energy has a major role for coal, other fossil fuels, and nuclear
as well as renewable technologies and energy conservation, with
each contributing at a time and to an extent dictated by tech-
nical feasibility and affordability.

4.4
One third of the EU countries only can relay on indi-
genous coal deposits while the remaining two thirds of coun-
tries depend on imported hard coal mostly. Mining of hard coal
in 2006 while
in EU amounted 161,6 million tonnes
235,3 million tonnes was imported. Consumption of
lignite
reached 373,8 million tonnes in the same year and it was
resources. Therefore, viable
entirely covered by indigenous
means for substantially reducing specific CO2 emissions from
coal-fired power generation need to be developed and widely
adopted.

4.9
However promising the reasonable expectations CCS
it must not lead to the effect that already now energy
gives,
policy strategies and targets are adopted as ‘a binding measure’,
as if on the basis of broad presence of the CCS technologies.

(3) IPCC, 2005: IPCC Special Report on Carbon Dioxide Capture and
Storage. Prepared by Working Group III of the Intergovernmental Panel
on Climate Change (Metz, B., O. Davidson, H. C. de Coninck, M. Loos,
and L. A. Meyer (eds.)). Cambridge University Press, Cambridge, United
Kingdom and New York, NY, USA, 442 pp.

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5. Specific comments

5.1
Coal plays a very important role in European electricity
generation, but 70 % of coal-fired electricity is generated in
plants that are over 20 years old. Slight increases in power
consumption and much of the existing power plant capacity
reaching the end of its technical/economic life will create the
need for about 350 GW of new electricity generating capacity
by 2020 and about 500 GW by 2030. Calculating costs of the
coal fired power plants with CCS in the EU is based on opti-
mistic cost structure of a new, 300 MW rated, power plant
amounting EUR 500 million (about EUR 1,7 million per MW
installed). Retrofitting of a modern power plant built from now
on until 2020) needs EUR 0,5-0,7 million per MW installed and
cost of retrofitting of existing facilities reaches even higher sum
of EUR 1 million per MW installed. If, by the year of 2030,
500 GW of generating capacity would be brought about to the
most advanced state of technology with CCS, the estimated
investment costs amount EUR 600-800 billion.

5.2
The EESC appreciates that in the long term, after 2020,
CO2 capture and storage would offer the potential for near-zero
CO2 emissions from coal-based power plants. Delivery of this
option requires coordinated research, development and demon-
stration (RD&D) now.

5.2.1
In the next decade, cost-effective CO2 emissions reduc-
tions can result from increased coal combustion efficiencies
achieved through the more widespread use of state-of-the-art
coal- fired power plant technology.

These strategies are complementary based on technical
5.2.2
solutions that need to be proven: deployment of modern, effi-
cient coal-fired electrical generation technologies in the short to
medium term can enable carbon capture for less cost in the
longer term, if those power units are designed to enable cost-
effective carbon capture retrofitting when such technology
becomes available for commercial application.

5.2.3
The Seventh Framework Programme foresees that radi-
cally transforming the energy system into a less- or non-CO2-
emitting, reliable, competitive and sustainable energy system
requires new technologies and new materials with risks that are
too high and profits too uncertain for private firms to provide
all the investment needed for research, development, demonstra-
tion and deployment. CCS and Clean Coal are amongst the
7FP Energy budget amounting EUR 2350 million from 2007
till 2013.

‘Capture-ready’ concept needs to be properly defined.
5.2.4
Successful implementation demands that regulators and industry
work together — commercial markets will not deliver without
appropriate and stable policy frameworks.

5.2.5
The EESC sees an urgent need for power plant capacity
increase and modernisation. In view of a projected increase in
reliance on imported energy which rises to 69 % by 2030, a
broadly diversified energy mix is indispensable for energy
supply security reasons. Stabilising coal input to power genera-
tion can make a substantial contribution to securing the energy
supply in the EU.

5.2.6 With continued efficiency enhancements in the power
plant field and the development of near-zero emission technolo-
gies, coal will contribute to meeting the requirements of preven-
tive climate protection. In setting rules for emissions trading in
each EU Member State, the focus should be upon improving
efficiency to achieve GHG reductions.

5.2.7
Simplification of licensing procedures as well as their
gradual harmonisation through cooperation between national
regulatory authorities is needed in order to cut down as far as
possible the long lead times for construction projects, without
compromising the observation of the highest safety standards.

5.3
The EESC also draws attention to the fact that though
the most important fuel for electricity generation and a vital
input into steel production and other industrial processes, coal
will have a major role to play in meeting future energy needs
assisting in transition towards hydrogen economy. Coal liquefac-
tion allows coal to act as a substitute for crude oil; synthetic gas
can also be produced from coal. Such technologies and applica-
tions would eventually play also a vital role in the sustainable
energy mix. The Commission draft does not cover these impor-
tant segments of coal present and future use.

5.4
The current intense discussion of the potential for coal
utilisation in the next decades has led to the issues concerning
coal extraction being driven to the background. However, for
the extraction of indigenous lignite and hard coal, an appro-
priate political and economic framework remains necessary. The
extraction and transformation of energy can significantly contri-
bute to local prosperity and employment. When burning indi-
genous coal, the added value of extraction, transformation and
distribution remains within the EU. If oil or gas are used, about
75 % of the price are needed to cover import costs.

5.5 Maintaining the fossil fuel (coal based) power generation
share at its current level is also extremely important in view of
social situation in the new Member States: out of 286 500 total
manpower in the EU coal mining industry, the new MS coal
mining industry employs 212 100 workers. Responsible care
must be paid to very hard working conditions of miners
throughout the EU.

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5.6
Reductions of coal mining areas in the context of
regional planning as well as over burdening by the environment
protection regulations have in the past often resulted in unne-
cessary delays and additional burdens for the mines. The loca-
tion of reserves and the mobility of the mining operation when
extracting raw materials
in
comparison with other industrial sectors. This special situation
is to be taken into account especially when creating the legal
framework on environmental issues, for instance waste legisla-
tion, soil protection legislation and water legislation.

in particular challenges

result

5.7
The EESC also expresses a thought that the Commission
in this document and its time setting is optimistic on the CCS
time-frame and its lead-in time requirements. Although princi-
ples are known, a technology solution would require fairly

Brussels, 27 September 2007.

longer time and no breakthrough achievement can be expected
to offset steady and intensive work on the implementation of
this concept. The Commission should now focus on measures
to help 10-12 demonstration plants to be operated in 2015 and
to create a framework for CCS that covers the main risks, is reli-
able and, at the same time, not too restrictive. Intermediate
stage of higher efficiency generation is highly desirable and any
excessive haste and too restrictive regulatory framework could
seriously damage this important concept.

5.8
The EESC also calls for intensive research and develop-
ment as regards the renewable and alternative energy sources
that should contribute towards a safe EU energy mix. Simulta-
the integrated EU energy market should be fully
neously,
brought into life without any excessive delay.

The President

of the European Economic and Social Committee

Dimitris DIMITRIADIS

Opinion of the European Economic and Social Committee on the ‘Proposal for a regulation of the
European Parliament and of the Council on common rules for access to the market for coach and
bus services (Recast)’

COM(2007) 264 final — 2007/0097 (COD)

(2008/C 10/11)

On 16 July 2007, the Council decided to consult the European Economic and Social Committee, under
Article 175(1) of the Treaty establishing the European Community, on the abovementioned proposal.

The Section for Transport, Energy, Infrastructure and the Information Society, which was responsible for
preparing the Committee's work on the subject, adopted its opinion on 5 September 2007. The rapporteur
was Mr Allen.

At its 438th plenary session, held on 26 and 27 September 2007 (meeting of 26 September 2007), the
European Economic and Social Committee adopted the following opinion by 150 votes to 1 with 3 absten-
tions.

1. Conclusions and Recommendations

1.4
The committee commends this proposal as it comes
under the ‘Better Regulation’ programme and is in conformity
with the commitment to simplify and update the acquis.

1.1
The committee welcomes the proposed new regulation.
The adoption of this proposal will lead to the repeal of Regu-
lation No 684/92 and Regulation No 12/98.

1.5

The EESC recommends that:

1.2
The safety of passengers must be the absolute priority,
also in the case of Bus and Coach services. All other matters
must be considered as of lesser importance.

1.5.1
Further clarification be given to the statement ‘serious
infringement or repeated minor infringements of community
road transport legislation’. What constitutes a minor infringe-
ment? How many minor infringements will lead to an adminis-
trative penalty?

1.3
The new regulation should contribute to road safety due
to a stricter monitoring of international bus and coach services
which operate in several Member States.

1.5.2
serious infringements.

It is also necessary to make a list of what constitutes