RTMENT OF 

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Department of Transportation 

WASHINGTON, B.C. 

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THE CITY OF PIERRE, SOUTH DAKOTA 

PIERRE MUNUCIPAL AIRPORT 

90 Day notice of Mesaba Aviation, Inc. and 

Pinnacle Airlines, Inc. of termination of service 

At Pierre, SD 

Docket OST-2011- OK^'^ 

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COMMENTS OF THE CITY OF PIERRE, SOUTH DAKOTA 

PIERRE MUNICIPAL AIRPORT 

IN RESPONSE TO THE NOTICE OF TERMINATION OF SERVICE 

Communications with respect to this document should be sent to: 

The Honorable Laurie Gill 

Mayor 

Pierre, South Dakota 

222 E. Dakota Avenue 

Pierre, SD 57501 

605-295-7093 

Email: Laurie.qill@ci.pierre.sd.us 

Dated July 31,201: 
On behalf of the City of Pierre, Soutli Dakota, I would like to express our concern and 

objection regarding the loss of Pierre air service by Mesaba Aviation, Inc. and Pinnacle 

Airlines, Inc operating as "Delta Connection' carriers to Minneapolis, Minnesota. 

The notice outlines plans to retire all turboprop aircraft and numerous small jet aircraft 

operated by Mesaba and Pinnacle. In particular, ail Saab 340 aircraft operated by Mesaba 

for Delta Connection will be retired by year end. The notice suggested that Great Lakes 

Airlines intends to submit a bid to replace the Delta Connection service should the 

Department issue a request for proposals to select an EAS carrier. Our understanding is 

that there should be no question that the Department will issue a request for proposals to 

select an EAS carrier. 

The service from Pierre to Minneapolis is a critical eastbound link to the national air 

transportation system just as the current service from Pierre to Denver satisfies the need 

for westbound service. This was last reviewed by the Department and a decision 

provided in Order 2002-3-22. 

Decision 

Our last review of Pierre's essential air service determination was conducted in 19S8 

(Order 88-1-42, January 20,1988) and specified service to both Denver and 

Minneapolis/St. Paul. The Department's policy over the past decade has been to 

terminate subsidy for service to second hubs as the program's resources have been 

stretched thinner and thinner. And we continue to believe that to be a sound 

policy. Many of the dual-hub designations were established two decades ago, well 

before the carriers developed sophisticated hub-and-spoke systems. These welldeveloped hubs provide access to the national air transportation system. However, 

Pierre is unique in a couple of respects. First, of course, it is the state capital of 

South Dakota. As such, the loss of Great Lakes' service between Pierre and Denver 

would add a considerable amount of travel time for time for state government 

employees relying on Great Lakes' nonstop service as a means to and from work at 

the state capital. Second, the distances are very long. For example, the nonstop air 

miles to Denver and Minneapolis are 385 and 350, respectively, while one proves 

eastbound connections and the other westbound. If Denver-bound passengers had 

to travel via Minneapolis, they would first travel 350 miles to Minneapolis, then 680 

miles from Minneapolis to Denver, for a total in excess of 1000 miles for what is a 

385-mile nonstop flight. Put another way, westbound passengers would have to 

travel about 700 extra miles - roughly 350 east to Minneapolis and 350 back west 

just to get back where they started. 

Resources continue to tighten however we believe the Department's assessment of the 

Pierre air service needs continues to be valid. Nonstop air service from Pierre to both 

Denver and Minneapolis is still required due to the unique geography of the state capital 

of South Dakota. 

We understand that Delta Connection carriers intend to continue service from Pierre to 

Minneapolis until a replacement service is in place however this is not clear in the notice 
of termination. The notice acknowledged that the discontinuation of service appeared to 

cause service to drop below the EAS guarantee levels established by the Department but 

left open the question of whether or not the Department would require a hold-in. We 

believe that this should be clear. The current Great Lalces service from Pierre to Denver 

does not satisfy the EAS guarantee level and, as such, we understand that the Department 

will issue a hold-in order requiring a continuation of service until a replacement carrier is 

in place. 

We have met with Great Lakes and welcome their interest in expanding their presence at 

Pierre with service to Minneapolis. It is important to note that flights from Pierre to 

Minneapolis averaged 15.8 passengers per departure for the 12 months ending April, 

2011 or 30.0 passengers per day. This level of demand demonstrates the need for 

nonstop service without upline or downline points that would fiarther limit seats available 

to support the Pierre market. 

Respectftilly submitted, 

Laurie ^ill 

Mayor 

Pierre, South Dakota 

CC: Megan Rae Rosia, Vice President, Government Affairs, Pinnacle Airlines Corp. 

Maximillian T. Shemesh, General Counsel, Mesaba Airlines, Inc. 

CC: South Dakota Governor Dennis Daugaard 

Senator Tim Johnson 

Senator John Thune 

Representative Kristi Noem