FRANK GREMAUX CITY OF LEWiSTOWN AIJSSA BERRY 

First Ward Commissioners JIM DANIELS 

Park and Recreation Director 

PAITYTURK 

DIANAHEWITI' 

MONTE BOBITGBR 

City Attorney 

Second Ward Commissioners COllY BIRDWBU. 

Police Chief ELIZABETH PU1NAM GAYLE DONEY 

Third Ward Commissioners 

JASON MANLEY 

Fire Chief 

LARRY PHILLIPS 

At-Large Commissioner 

ROGER KRUCKENBERG 

DirectorofPublic Works 

KEVIN MYHRE 

City Manager 

NlKKI BRUMMOND 

Finance Officer/City Clerk 

Aprilll, 2013 

305 W. WatSon, Lewistown, Montana 59457 

(406) 535-1760 Fax (406) 535-3323 

U.S. Department of Operations 

Docket Operations M-30 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington D.C. 20590 

(.f''l 

(/"1 

RE: Docket DOT-OST-1997-2605 Order to Show Cause Proposing Terminatiorl:::of 

Essential Air Service Eligibility 

Secretary of Transportation, 

KELLY ANNE TERRY Library Director 

DUANE FERDINAND 

Planning Director 

The City of Lewistown recently received notice of pending termination of the Essential 

Air Service Eligibility of our community. The Order to Show Cause explains that the 

proposed termination of eligibility is caused by the amount of the average subsidy rate 

per passenger utilizing the service. Currently that rate is $2,009 for the Lewistown 

service. 

While it is evident that the current usage of the service has declined since Silver Airways 

was selected to provide the service in 2011, the ability to reduce the subsidy and 

encourage ridership is highly dependent on the service provider. When Lewistown's 

previous air service provider connected to the regionalhub in Denver, ridership was 

much higher and the subsidy well under the $1,000 threshold identified in the FAA 

Modernization and Reform Act of2012. In addition to providing service routes that 

were more useful to Central Montana residents, the previous provider also actively 

advertised their service and marketed the flights to local residents. 

The current provider, Silver Airways, changed the flight service to a Billings Airport 

connection which created numerous difficulties when trying to make connections to fly 

out of Montana. Silver Airways does not advertise their service with the local media 

outlets and are not even listed in the phone book white or yellow pages. Aside from the 

obvious lack of commitment to the Lewistown Air Service, Silver Airways has struggled 

to meet their flight schedule. I have been told by the Lewistown Airport Manager that 

they have missed flights due to a shortage of pilots as well as equipment problems. 

During the winter months they are often unable to land because they do not have the 

technology in their aircraft to utilize our airport's low visibility landing systems. 
Cancelled flights and missed schedules create problems for most air passengers. If 

passengers cannot depend on the air provider to regularly meet the provider's own 

schedules, customers stop utilizing the service. 

The city understands the limits on the subsidy and the rationale of setting the limits. 

However, the factor that does not appear to be included in the analysis is that of the 

dependability and commitment of the awarded provider. Essentially, each EAS program 

is only as successful as the carrier awarded the contract. When the EAS provider 

chooses to not advertise its service and then, in addition, provides unpredictable service 

with under-equipped planes, eventually that provider will see so little ridership that 

subsidies have to be raised to the point that trigger an elimination of the service 

Lewistown, Montana is a very isolated community located in the middle of Montana. 

The nearest larger community is over one hundred miles away as is the nearest interstate 

highway. There is no regional bus service to Lewistown and no rail service. Without the 

Essential Air Service program, there is no public transportation into or out of our 

community. 

The Lewistown community is asking for consideration of the circumstances that brought 

our subsidy to where it is today. Prior to 2011, and after many years of struggling with a 

Lewistown to Billings route, Great Lakes Aviation was able to increase ridership greatly 

by changing to a Lewistown to Denver route. By doing so, ridership and interest in the 

program increased and the subsidy per passenger correspondingly decreased. In 2011 

however, when Silver Airways was awarded the contract, service regressed to the 

Lewistown- Billings connection and local marketing of the program ceased, causing the 

subsidy to increase to an unacceptable rate. The community requests to be included in 

the upcoming requests for proposal for Essential Air Service with a route from 

Lewistown to Denver. Both Miles City and Lewistown are supportive of this route and 

believe that it would bring the subsidy well within the parameters of the Modernization 

and Reform Act of2012. Additional provisions could be added to. require that the 

carrier's aircraft be capable of utilizing the low visibility technology available at the 

airports. The future of the entire Unites State airline industry is highly dependent on 

consistency and predictability. Connections to hub airports and their multiple carriers is 

critical for any successful program. 

Please reconsider the proposed termination of service to the Lewistown Community and 

work with us to make the adjustments necessary to provide this critical service. 

Kevin L. Myhre 

City Manager 

City of Lewistown, MT