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CITY OF BILLINGS 

AVIATION AND TRANSIT DEPARTMENT 

1901 Terminal Circle, Room 216 

Billings Logan International Airport 

Billings, Montana 59105-1996 

(406) 657-8495 

(406) 657-8438 FAX 

www.flybillings.com 

United States of America 

Department of Transportation 

Office of the Secretary 

Docket Operations, M-3 0 

April16, 2013 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, D.C. 20590 

Dear Sir or Madam: 

RE: Docket DOT-OST-1997-2605 

Thomas H. Binford, A.A.E. 

Director of Aviation and Transit 

Kevin Ploehn 

Assistant Director of Aviation and Transit 

····-;··-·····' 

;·.: ... ) 

Prior to finalizing Show Cause Order 2013-3-13 and terminating Essential Air Service (EAS) 

eligibility for Lewistown and Miles City we would encourage the Department of Transportation 

to not only consider current passenger totals, but also the level of previous year passenger 

enplanements and the potential causes of the current passenger decline. 

Having worked in the aviation industry for over 30 years, I understand the benefits and 

challenges of securing and retaining air service. Regardless of the location and size of a 

community, two factors are critical to successfully building a route or supporting airline service, 

time and senrice consistency. Airlines must have the time to develop a market and the 

community must have time to adjust to the service they provide. During this period, disruptions 

in service, regardless of the cause, can affect the success of an airline or route. 

Service consistency has impacted the Montana EAS system since Big Sky Airlines abruptly 

suspended operations in 2007. Attached are the passenger totals for Lewistown and Miles City 

for the years 2005-2012, as reported by the Montana Aeronautics Division. You will observe 

that when Big Sky Airlines was the service provider (2005 - 2007) Lewistown and Miles City 

reported passenger counts that were two and in some cases three times higher than the 2012 

totals. After service was restored in 2008, passenger loads rebounded for a brief period until the 

next carrier transitional period began. Considering that these communities have been served by 

three different airlines in six years, it is not surprising that passenger levels have temporarily 

dropped off. 
The historical enplanement data demonstrates that Miles City and Lewistown can support greater 

passenger totals. We would encourage the Department of Transportation to permit Miles City 

and Lewistown to remain in the program for an additional contract period to allow additional 

time for the communities to work with their EAS provider to rebuild their passenger bases. 

Thank you for the opportunity to offer input and for considering the information provided before 

making your final eligibility decision. 

Sincerely, 

Thomas H. Binford, A.A.E. 

Director of Aviation and Transit 

THB:mdb 

Enclosure 

cc: EAS File 

Chrono 

T. Binford 
LEWISTOWN 

YE~R 

2005 

2006 

Great Lakes 

Great Lakes Operations in Lewistown Began September 2008 

2009 : l,o36l~"~To26 2 ---==-re_a_t_L_a:-ke-s-----1 ""~-~" "f"~~""""~""~4~"~~"""J~-~"~"i"~"~~~= 

2010 : 700 ! 651 1 351 , Great Lakes m~~~'~'"'~'''"'r~~·~- ~~-+~=«~~~"'""'""w'~"l ~~'"*""m~-"'~""':-~,~,~~-~~,~=~=~'~"~~~~~~~mw>~• 

2011 1 349 ' 325 : 674 1 Great Lakes/Gulfstream !=~----'"~ "" "~""~""-"-""""""""'L,,,,,,,,,,_""""'"'"'''"'''''"''''~-"''"'" '"''~""'"""--------"-----! 

Great Lakes Ceased Service to Lewistown End of April 2011 

Gulfstream/Silver Commenced Service on May 1, 2011 

Closed for Construction August 2011 

2012 337 319 656 Gulfstream/Silver 

YEAR 

2005 

2006 

2007 

MILES CITY 

P~SSENGERS 

ON OFF 

Great Lakes ~=~'~L-~~~-~-~,--~-L~--~~~-- ---- Great Lakes Operations ~'2"!!![es City Began October 2008 __ ~~-

2009 887 893 1 h780 .L Great L(l~es 

2010 1,029 1 012 ' 2 041 ; Great Lakes '' "'" "' ""''"'''''"'"'''~-'~"'"' •• '":L:'"'"""-'"'" _" ____ ,, """---" --"''"' 

2011 ~------~5.-~-L --- ?Zli_~ - 1, 13.11_ Gr~~~~-~s/~J~~~~Cl!!l, Great Lakes Ceased Service to Miles City End of April 2011 

Gulfstream/Silver Commenced Service on May 15, 2011 

2012 360 353 713 Gulfstream/Silver 

Source: Montana Department of Transportation 

Aeronautics Division 

Airport Boardings Study 

http://www. mdt. mt.gov /aviation/studies-research .shtml