Federation of Transport Trade Unions notes that the draft Air Transport Act contains a number of positive elements aimed at systematizing the regulation, clearer planning and regulation of public passenger transport, as well as at compliance with the European legal framework. Within the framework of public consultations, some of the proposals made by FTTU were formally reflected, including with regard to the admissibility of direct award and the possibility of transport on demand to be performed by an internal operator.

Nevertheless, the Federation has criticisms, which were reflected in a number of proposals and opinions to the Ministry of Transport and Communications, including and to the National Assembly, as in its current form the bill contains substantial deficits, which call into question the sustainability and social legitimacy of the proposed reform.

• Risks in the award of public transport:
  Although direct award is formally permitted, the bill continues to treat it as an exception rather than an equal mechanism to the procedures under the Public Procurement Act and the Concession Act. This creates legal uncertainty and a real risk of municipalities being pushed towards market and concession models, even when they have their own municipal operators. Such an approach contradicts the philosophy of Regulation (EC) No 1370/2007 and threatens the sustainability of municipal public transport.

  
  

• On-demand transport – social service or market model:
  FTTU expresses serious concerns that the regulation of transport on demand may open the door for the entry of private platforms and fragmentation of the system, instead of serving as a social tool to ensure access to transport. On-demand transport should be clearly regulated as a social service, targeted at settlements without transport connectivity, and not as a business opportunity at the expense of municipal operators.

  
  

• Transport poverty remains outside the focus of the law
  A conceptual approach to the problem of the so-called "transport poverty" is completely absent from the draft. The law does not contain clear objectives, criteria or commitments to guarantee a minimum transport service for residents of small and remote settlements, the elderly, people with disabilities and socially vulnerable groups. This is a serious omission, as public transport is a service of general economic interest and a key factor for social inclusion, access to work, education and healthcare.

  
  

• Lack of real social dialogue and excessive centralization
  The bill was drafted in the wake of a serious deficit of social dialogue, and the planned expanded powers of the Minister are not accompanied by sufficient guarantees for the participation of social partners and municipalities in the development of standards and model contracts.

FTTU's position is clear: The Public Transport Act must be further developed after a real social dialogue, within the National Council for Tripartite Cooperation – format industry council "Transport", with clearly written social guarantees, equal models of award and explicit recognition of the social function of public transport.

Federation of Transport Trade Unions will continue to actively defend the rights of workers in the sector and the public interest of citizens, because there is no sustainable transport without social responsibility.