Volodymyr Kreidenko, Ukrainian MP, deputy chairman of the Committee on Transport and Infrastructure, and Chair of the cross-party parliamentary group ‘Dobrobat – Volunteer Construction Battalion’
An air raid alert in Kharkiv, Kyiv, Zaporizhzhia, Lviv or Uzhhorod formally means the same thing. Yet the reality on the ground is fundamentally different in each of these cities. Missile approach times vary, as do the frequency and duration of alerts, the structure of public transport networks, the availability of shelters, the presence of metro systems, bridges and critical infrastructure, and ultimately a city’s ability to function for hours without public transport.
That is why a seemingly simple question, whether public transport should stop during an air raid alert, does not have a single correct answer for all of Ukraine.
Over the years of the full-scale war, Ukrainian cities have effectively developed their own models. In some places, public transport stops. In others, it continues to operate. In some cities, passengers are given the opportunity to leave the vehicle near a shelter, after which the bus or trolleybus continues along its route. Separate restrictions may also apply to bridges, above-ground sections of metro lines or individual routes.
Kyiv is perhaps the most illustrative example.
Beginning in 2022, surface public transport in the capital stopped during air raid alerts. Passengers were asked to leave the vehicle and proceed to the nearest shelter. Over time, however, it became clear that frequent and prolonged alerts created another serious problem. Vehicles fell behind schedule, long service gaps appeared after the all-clear, and people could find themselves unable to move around the city normally for hours.
Kyiv therefore changed its approach in March 2025. Following consultations with the military, law enforcement agencies and the State Emergency Service, the Kyiv Defence Council decided that surface public transport should stop near the nearest shelter during an alert. Passengers who wish to leave may do so, after which the vehicle can continue along its route. Importantly, this rule was applied both to municipal operators and private carriers.
The importance of this example is not that Kyiv has found a universal model that should simply be copied throughout the country. Quite the opposite. It demonstrates that even one city may need to revise its rules during the course of a war as experience accumulates and circumstances change.
Kharkiv operates in completely different conditions. At one point, the regional military administration introduced an algorithm under which a driver, after receiving an air raid alert, should stop the vehicle in a safe location, inform passengers and ensure that they can leave. People with reduced mobility should also be assisted during evacuation.
Yet Kharkiv itself demonstrates the weakness of any universal rule. If a city faces a constant threat and air raid alerts occupy a significant part of the day, an automatic shutdown of the entire public transport system every time an alert is announced may effectively paralyse the city.
Zaporizhzhia and other frontline communities face this challenge even more acutely. Public transport there cannot be viewed merely as a matter of convenience. It enables medical workers to reach hospitals, employees to get to their workplaces, municipal workers to maintain critical infrastructure and people without private cars simply to move around the city.
At the same time, the opposite extreme, allowing transport to continue operating under any circumstances, would be equally wrong. A route may cross a bridge, pass critical infrastructure or run through an area where stopping or a concentration of people creates an additional risk. Conversely, forcing dozens of passengers to leave a vehicle in an open area where no proper shelter is available does not automatically make them safer.
This is where we encounter a problem that the state has still not regulated clearly enough.
Ukrainian legislation already gives local government significant powers in the field of public transport. Executive bodies of local councils approve routes, timetables and rules governing the use of urban passenger transport. Legislation on urban electric transport also allows transport services to be restricted or suspended under a state of emergency or martial law.
However, there is still no sufficiently clear special provision answering a basic question: who has the authority to establish a mandatory procedure for all carriers operating in a particular community during an air raid alert?
As a result, cities have been filling this gap through decisions of defence councils, executive committees, transport operators and local instructions.
During the first months of the full-scale invasion, this approach was understandable because decisions had to be made immediately. Today, however, air raid alerts are unfortunately no longer a temporary or exceptional phenomenon. They have become a systemic factor in the everyday functioning of Ukrainian cities.
It is therefore time for a systemic legislative solution.
At the same time, we should avoid another mistake: trying to determine from the Verkhovna Rada exactly where every bus in every Ukrainian city must stop during an air raid alert.
Ukraine does not need one public transport algorithm for every community.
Kharkiv and Uzhhorod have very different response times. Kyiv has a metro system, bridges across the Dnipro and a highly complex transport network. Zaporizhzhia operates under the constant pressure of proximity to the frontline. Lviv has a different route configuration and a different pattern of aerial threats. Every community has a different number of accessible shelters, different urban density and a different degree of dependence on public transport.
The correct principle should therefore be different: not identical rules for everyone, but a single legislative framework defining who has the authority to set those rules.
In my view, the relevant executive bodies of local self-government should receive an explicit statutory power to determine how public transport operates during an air raid alert.
Each community should be able, taking into account assessments by the military, the State Emergency Service and law enforcement agencies, to decide when transport may continue to operate, when it should temporarily stop and when an individual route or section of a route should be closed.
Local authorities should also be able to determine specific operating rules for buses, trams, trolleybuses and metro systems, identify safe stopping points, regulate boarding and disembarking, establish procedures for passenger information, provide for the needs of persons with disabilities and other people with reduced mobility, and determine how services resume after the all-clear.
These rules must apply equally to municipal and private carriers. There cannot be a situation in which, on the same street, a municipal bus follows a city safety decision while a private carrier acts according to its own interpretation of what is safe.
Kyiv already applies this principle in practice. The city’s adopted procedure covers both municipal public transport and private carriers.
There is also another fundamental issue: responsibility.
When there is no clearly established procedure, a driver, dispatcher or transport company manager is effectively forced to assess the risk independently. Should the vehicle continue? Where should it stop? Should passengers be asked to leave? What happens if the nearest shelter is far away or closed?
Such decisions should not be improvised after an alert has already begun. The procedure must be established in advance, communicated to carriers and understood by passengers.
We should also stop treating safety and mobility as mutually exclusive.
Public transport during wartime is part of a city’s essential life-support system. It is used by medical workers, military personnel, energy and municipal workers, employees of businesses, students, elderly people and hundreds of thousands of citizens who do not own a car.
Paralysing the transport system of a city with a population of one million for several hours means affecting hospitals, businesses, critical infrastructure and the entire urban economy.
At the same time, the need for mobility can never justify ignoring a genuine threat to human life.
That is precisely why decisions should be made as close as possible to the territory they affect.
The state should establish the legislative framework. The military, the State Emergency Service and law enforcement agencies should provide risk assessments. Local authorities, which know their city’s transport network, shelter locations, dangerous infrastructure, and the actual frequency and duration of air raid alerts, should determine the specific operating regime for public transport.
The experience of Kyiv and other major Ukrainian cities has already shown that there is no single correct algorithm for the whole country.
But there should be one clear rule: every community must have a right defined by law to adopt its own safety procedure, and every carrier must be obliged to comply with it.
This is the balance between safety, responsibility and mobility that Ukrainian cities need today.
