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ACEA position paper Infrastructurerequirements ofurban buses,interurbanbusesandcoaches EXECUTIVE SUMMARY Withthe2030 CO2reductiontargetsforheavy-duty vehicles, includingbuses and coaches,approaching swiftly,vehicle manufacturers’ability to meet them dependsontherapiddeployment ofsuitablechargingand refuellinginfrastructure.Itmust focus onlocationswhere these vehiclesregularly operate, along major highways but most importantlyalso atdepots, bus stationsandhubs, and tourist destinations. ACEA estimates that nearly 30,000 daily charging“opportunities”are needed by 2030 forinterurbanbusesandcoaches, with roughly 98% of themhappeningaway from the maincorridors. To ensure that interurban buses and coaches can meet theirCO2 targets, ACEArecommends the following: •Createtargeted EU and national fundingspecifically for interurban/coach‑suitable charginginfrastructure, improvevisibility and access to existing schemes,and streamlinepermits and documentation,so projects move faster. •Work with the industryand prioritisea long‑term, market‑ledrollout in partnershipwith manufacturers and operators.ACEA’s bus and coach manufacturers standready to cooperate closely with industry and value chain stakeholders, institutionsand policymakers on all levels to ensure the ambitious CO2reduction targets can bemet. •Harmonisebuilding and safety rulesacross member states on fire‑safetymeasures (eg partition walls, quarantine areas) and other civil‑engineeringconstraints so these do not unnecessarily shrink usable charging space or slowdeployment across countries. •Even withan acceleratingZEV uptake in urban buses, there must be acontinuedexpansion of depot chargingto meet the 90% ZEV sales target by 2030. Thismustensure urbanbusfleets do not compete with interurban/coach needs forlimited infrastructure and grid capacity. •UpdateAFIR and related EU/national rulesto include coach/interurban‑specificsite requirements. Additional provisions such as temporary accommodation of largepassenger groups, toilets,and catering, safe alighting and pedestrian flows arecrucial to ensure public and semi‑public charginginfrastructureare truly usable forpassenger operations. •Consistent and periodic EU‑wide monitoring(bi-annual) of key enablingconditions (infrastructure rollout pace, grid readiness, permittingetc.) with theEuropeanCommission,MemberStates,and industry must be put in place.Feedback from these monitoring exercises must be used as a basis for reviewingCO2 targets to ensure they are aligned withthe rollout of charginginfrastructureandother key enabling conditions. BACKGROUND LEGISLATIVE BACKGROUND Currently all urban buses, interurban buses, and coaches with a gross vehicle weight above7.5 tonneshave been added to the scope of the CO2emission performance standards fornew heavy-duty vehicles (EU) 2019/1242. While urban buses are regulated through a salesshare target for zero-emission vehicles (ZEV), coaches andinterurban buses are regulatedthrough a CO2 emission reduction target. This target refers to a common baseline for allmanufacturers, which includes all vehicles sold by all manufacturers in the baseline year2025. For interurban buses and coaches, reduction targets of 43% for 2030, 64% for 2035,and 90% for 2040 apply on thisbasis. While for urban buses a 90% ZEV share applies in2030 and 100% in 2035. CURRENT STATE OF THE ZERO-EMISSION BUS MARKET In recent years, city buses have led the way in the introduction of ZEVs in the heavycommercial vehicle segment, paving the way for the adoption of these vehicles in otherareas.City buses account for almost all ofthe zero-emission bus registrations;only a fewzero-emission coaches arecurrentlyavailable on the market1.Toaccelerate the transition ofthe sector, the availability of suitable charging infrastructure isessential alongsideothercriticalenabling factors.Such acharging infrastructure is currently not available to an extentthat would allow the zero-emission vehicle salesfigures required to meet the CO2reductiontargets in 2030. Currently, the specific infrastructure requirements for interurban buses and coaches, meaningthenumberof charging opportunities and their configuration, are not considered in current EUlegislation such as the Alternative Fuels Infrastructure Regulation (AFIR)2. National legislation,such as Germany's Charging Infrastructure Masterplan II3, also only mention coaches inrelation to public charging infrastructure at central bus stations/ hubs.In particular destination 1European Commission. (2025).COMMUNICATION FROM THE COMMISSION TO THEEUROPEAN PARLIAMENT AND THE COUNCIL on the technological and market readiness of heavy-duty road transport vehicles charging(i.e. charging at tourist attractions, amusement parks, museums, and other points ofinterest)has not yet been considered despite representing an important charging scenario forinterurban buses and coaches. Another important charging scenario is en-route charging,which refers to charging while vehicles