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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 ofAmerica Department ofTransportation Office ofthe Secretary Docket Operations, M-30 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

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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 ofTransportation to not only consider current passenger totals, but also the level of previous year passenger enplanements and the potential causes ofthe 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 ofthe cause, can affect the success ofan 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 briefperiod 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 theinformation provided before making your final eligibility decision. Sincerely,

Thomas H. Binford, A.A.E. Director ofAviation and Transit THB:mdb Enclosure

cc: EAS File Chrono T. Binford

### LEWISTOWN**YE~R** 2005 2006

Great Lakes GreatLakes Operations in Lewistown Began September2008 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,,,,,,,,,,_""""'"'"'''"'''''"''''~-"''"'" '"''~""'"""--------"-----!**  GreatLakes CeasedService to Lewistown End of April2011 Gulfstream/Silver CommencedService on May 1, 2011 Closed for Construction August2011 2012 337 319 656 Gulfstream/Silver



### YEAR 2005 2006 2007 

### MILES CITY**P~SSENGERS** 

### ON OFF

Great Lakes**~=~'~L-~~~-~-~,--~-L~--~~~--** 

### ---- GreatLakes Operations**~'2"!!![es** City Began October2008

__**~~-** 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 CeasedService to Miles CityEnd of April2011 Gulfstream/Silver CommencedService on May 15, 2011 2012 360 353 713 Gulfstream/Silver

Source: Montana Department ofTransportation Aeronautics Division Airport Boardings Study http://www.mdt.mt.gov /aviation/studies-research .shtml