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BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, DC

Ninety Day Notice of 

MESABA AVIATION, INC., and Docket OST-2011-0137 

PINNACLE AIRLINES, INC.

of termination of service

at Aberdeen, SD 

Pursuant to 14 CFR Part 323

OBJECTION TO PROPOSED TERMINATION, SUSPENSION, OR REDUCTION OF

AIR TRANSPORTATION

Filed by: Absolutely!Aberdeen, Inc.

Julie M. Johnson, Executive Director

416 Production Street North

Aberdeen, SD 57401

605-725-5070

juliem.johnson@absolutelyaberdeen.com 

Dated: August 4, 2011
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OBJECTION TO PROPOSED TERMINATION, SUSPENSION OR REDUCTION OF AIR TRANSPORTATION

Pursuant to the requirements for objections in 14 C.F.R. section 323.9, I hereby file and register the 

following objections to the Notice of Termination of Service dated July 15, 2011:

1) This objection is filed on behalf of Absolutely!Aberdeen, Inc., an economic development organization 

representing the business and other economic interests of Aberdeen and North East South Dakota. My 

name is: Julie M. Johnson, Executive Director, Absolutely!Aberdeen, 416 Production Street North, 

Aberdeen, SD 57401. 605-725-5070 is our office phone number. I am also licensed to practice law in 

South Dakota.

2) Our request is that DOT:

a) Hold-in Delta/Pinnacle/Mesaba, by immediately issuing an order prohibiting termination of 

air transportation, as authorized and provided by 14 CFR 323.13; 

b) Evaluate any carrier/carriers proposing to continue unsubsidized “EAS” (Essential Air Service) 

to Aberdeen, SD, by determining their financial, as well as operational, fitness to provide such service;

c) Solicit proposals for subsidized service, IF no carrier proposes to continue unsubsidized 

service to Aberdeen. Should such proposals be submitted, consider and defer to the preference of the

community, including this Objector, when evaluating such proposals.

d) NOTE: This objection is filed relying in significant part on the representations of 

Pinnacle/Mesaba/Delta in their Notice of Termination of Service, that they “intend to submit a bid to 

provide continued service under the EAS program at subsidy rates that will enable us to cover the cost 

of the operation and a reasonable return on investment”. Therefore, should Mesaba/Pinnacle/Delta 

not submit a bid, as represented in the Notice, this Objector will need to make additional submissions 

and filings in this process, and request permission to so at this time should that become necessary.

3) Schedules—are stated in full by Mesaba/Pinnacle/Delta in their Notice, and will not be restated here, 

but will be referred to by reference to the Notice.

4) Suggested Reasonable Level of Service—Objector represents that a reasonable level of service to 

Aberdeen, SD, would be

a) three inbound and three outbound flights a day, seven days per week, twelve months a year;

b) And objector points out that there is a definite need for an additional flight per day during a 

unique time of the year in North East South Dakota, pheasant hunting season. Mesaba/Pinnacle/Delta 

have worked with the community to ensure additional flights are provided during pheasant season 

every year for the past many years, as there is definite ridership justification for such additional service. 

Objector also represents that the air carrier selected to provide this service needs to work with the 

community at least 9 months in advance of pheasant season to commit to that increased level of 

service, and increase in flights during that season, to allow those using the service to have appropriate 

access to that service and using that service; 

c) service should be to and from the Minneapolis/St. Paul International Airport, the nearest 

large hub airport; 
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d) Objector urges that the airline selected be willing to work with the community, and this 

organization, to arrange flight times that work and are effective for those using the service from the 

Aberdeen market.

5) (Reserved in 14 CFR 323.9)

6) Justification of level of service—Objector submits that it has a thorough understanding of the 

economy, as well as new developments in the economy of this entire trade territory, and knows that 

this economy is growing, including, but not limited to:

a) Aberdeen, SD, is growing. This is evidenced in part by the 2010 Census, as well as sales tax, 

and other key economic indicators. Workforce is also growing significantly. Aberdeen’s growth defies 

the trend in much of the rest of the country. Much of Aberdeen’s growth isn’t yet reflected in the 2010 

Census, but will show up in near future numbers. National news, including NPR, has highlighted this 

unique economic position of Aberdeen and this market; 

b) The first state-of-the-art beef processing facility built in this region in 50 years is preparing to 

open later this year, owned by international investors, and adding 560 employees to the workforce. A 

comprehensive economic impact statement regarding the facility was recently issued, by an 

independent consultant, which can be made available in whole to any air line looking at providing 

service;

c) Aberdeen is one of the few places in the country where an additional hospital is being built at 

this very moment. By May of 2012, Aberdeen will have two hospitals fully staffed and operational, 

Avera St. Luke’s, as well as Sanford. Hiring for the brand new hospital is happening in this calendar year 

to staff the new hospital, and to get their staff trained to open the doors of the new hospital. This new 

hospital did not exist before in this community, and requires the addition of nearly every kind of health 

professional to staff it effectively, and added to our community. In order to keep those health 

professionals fully skilled and able to serve their patients, they will need a high-quality commercial air 

carrier with 3 or more flights per day every day; 

d) Aberdeen is conducting a “1000+ Jobs” campaign at this moment, putting a face on all of the 

very significant job creation going on in the region during this year and next, which is lead by this 

Objector. Additional information can be made available to any applicant;

e) Molded Fiber Glass Companies of South Dakota has located in Aberdeen for the last 2 years, 

and is continuing its ramp-up in employment to 500-700 employees, as we speak. They manufacture 

wind turbine blades, and are a part of a family-owned company that does business all over the world, 

providing its wind turbine blade products exclusively to GE;

f) Aberdeen is the home of the headquarters of Dacotah Bank, owning 35 branches in North and 

South Dakota. This requires effective commercial air service, the kind suggested in this Objection;

g) Aberdeen is the headquarters of several regional federal agencies, including the IRS, BIA, and 

Indian Health Service, requiring high-quality commercial air service in order to do their jobs;

h) Aberdeen is the home of many headquarters operations spawned from the birth and growth 

of Super 8 n Aberdeen, SD, now owned by Wyndham World Wide, which also has a significant presence 

in Aberdeen. These headquarters operations do business all over the world from Aberdeen, SD;
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i) Aberdeen has a growing financial services sector, all of which needs high-quality commercial 

air service, many of which located here due to access to three or more flights a day;

j) Aberdeen is the home of two growing institutions of higher education, Northern State 

University and Presentation College. Northern State University also is the home to South Dakota’s 

thriving International Business program, which attracts 200+ international students to its campus in 

Aberdeen every semester, all of which fly to and from their homes to study at NSU. Both of these 

colleges have a high need for high-quality commercial air service to facilitate the growth of their 

institutions, the work of their faculty and administration, as well as consultants and others who do 

significant business with both institutions; 

k) Aberdeen is home of the country's largest cooperative doing business globally, as well as 

other very significant agribusiness headquarters.

l) Objector has developed a thorough marketing campaign, and has implemented some of its 

components as of this writing, which would attract additional interest in flying from Aberdeen, 

especially should those giving this Notice be successful in terminating service to Watertown, Pierre, and 

Jamestown. Objector has been in communication with the Delta marketing team on several occasions in 

the past requesting permission to use Delta logos, as well as to engage in joint marketing efforts, or to at 

least share marketing opportunities and information sufficient for the community to deploy effective 

marketing around them;

m) Objector, and its investors, represent the depth and breadth of the economic engines of 

North East South Dakota, and South East North Dakota. By virtue of this in depth knowledge and 

familiarity, Objector represents that ridership will increase in and out of Aberdeen, SD, into the 

immediate future; 

n) Objector, and its investors, together with the City, have engaged in significant research in 

recent years to understand the ridership “leakage’ being experienced earlier in and out of Aberdeen, as 

well as the pricing strategies that were being used for tickets to and from Aberdeen. Those bodies of 

research were shared with Delta and Delta agreed to make some pricing changes to be more reflective; 

o) Objector, through its daily work, has access to other highly confidential and proprietary 

business information which leads objector to additional reasons to believe that Aberdeen should have 3 

flights a day, 7 days a week, 12 months a year, plus additional flights during pheasant season.

p) Objector remains available to provide additional detail as may be appropriate and useful 

about the growth of Aberdeen and the region, at the contact information stated above.

7) Proof of Service:

Objector hereby certifies that it has served this Objection by first class US Mail, postage prepaid, 

addressed to the following at the addresses listed below, the same as listed in the Notice of 

Termination, as well as by electronic communication, to the following:

Megan Rae Rosia

Vice President, Government Affairs

Pinnacle Airlines Corp.

1689 Nonconnah Blvd., Suite 111
5

Memphis, TN 38132

(202) 965-4889

mrosia@pncl.com

Maximillian T. Shemesh

General Counsel

Mesaba Airlines, Inc.

1000 Blue Gentian Road, Suite 200

Eagan, MN 55121

(651) 637-5218

Max.Shemesh@mesaba.com

The Honorable Mike Levsen

Mayor

123 South Lincoln Street

Aberdeen, SD 57401

Michael Wilson

Transportation Director

Aberdeen Regional Airport

123 South Lincoln Street

Aberdeen, SD 57401

South Dakota Department of Transportation

Bruce Lindholm

Local Transportation Program Manager

Division of Finance and Management

700 E. Broadway Ave.

Becker-Hansen Building

Pierre, SD 57501

U.S. Postal Service

475 L’Enfant Plaza S.W.

Washington, D.C. 20260

ATTN: Assistant General Counsel-Transportation 

 

Respectfully submitted,

Julie M. Johnson

Executive Director

Absolutely!Aberdeen, Inc., 

And Attorney at Law