# CITY OF LEWiSTOWN FRANKGREMAUX AIJSSA BERRY FirstWard Commissioners JIM DANIELS Park and Recreation Director
PAITYTURK DIANAHEWITI' MONTE BOBITGBR CityAttorney 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

KEVINMYHRE CityManager
NlKKI BRUMMOND Finance Officer/City Clerk

Aprilll, 2013 305 W. WatSon, Lewistown, Montana 59457 (406) 535-1760 Fax (406) 535-3323

U.S. Department ofOperations Docket Operations M-30 West Building Ground Floor, Room W12-140 1200 NewJersey Avenue, SE Washington D.C. 20590 (.f''l

(/"1 RE: Docket DOT-OST-1997-2605 Orderto Show Cause Proposing Terminatiorl:::of Essential Air Service Eligibility Secretary ofTransportation, KELLYANNE TERRY Library Director DUANE FERDINAND Planning Director

The City ofLewistownrecentlyreceived notice ofpending termination ofthe Essential Air Service Eligibility ofour community. The Order to Show Cause explains that the proposed termination ofeligibility is caused bythe amount ofthe average subsidyrate perpassenger utilizing the service. Currently that rate is $2,009 for the Lewistown service.

While it is evident that the current usage ofthe 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 onthe service provider. When Lewistown's previous air service provider connected to the regionalhub in Denver, ridership was much higher and the subsidywell under the $1,000 threshold identified inthe FAA Modernization and Reform Act of2012. 

### In addition to providing service routes that
were more useful to Central Montanaresidents, 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 ofMontana. 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 ofcommitmentto the Lewistown Air Service, Silver Airways has struggled to meettheir flight schedule. I havebeen told bythe Lewistown Airport Manager that they have missed flights due to a shortage ofpilots as well as equipment problems. During the winter months they are often unable to landbecause 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 onthe airprovider to regularly meet the provider's own schedules, customers stop utilizing the service.

The cityunderstands the limits onthe subsidy and the rationale ofsetting the limits. However, the factor that does not appear to be included in the analysis is that ofthe dependability and commitment ofthe awarded provider. Essentially, eachEAS 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 providerwill see so little ridership that subsidies have to be raised to the point that trigger an elimination ofthe service
Lewistown, Montana is a very isolated community located inthe middle ofMontana. The nearest larger communityis 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 ofour community.

The Lewistown communityis asking for consideration ofthe circumstances that brought
our subsidy to where it is today. Prior to 2011, and after many years ofstruggling with a Lewistown to Billings route, Great Lakes Aviation was able to increase ridership greatly by changing to a Lewistown to Denverroute. Bydoing so, ridership and interest in the program increased and the subsidyperpassenger correspondingly decreased. In 2011 however, when Silver Airways was awarded the contract, service regressed to the Lewistown- Billings connection and local marketing ofthe program ceased, causing the subsidyto increase to anunacceptable rate. The communityrequests to be included in the upcoming requests for proposal for Essential Air Service with a route from Lewistown to Denver. BothMiles City and Lewistown are supportive ofthis route and believe that itwouldbring the subsidywell within the parameters ofthe Modernization and Reform Act of2012. Additional provisions could be added to. require that the carrier's aircraft be capable ofutilizing the low visibilitytechnology available at the airports. The future ofthe 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 ofservice to the Lewistown Community and work withus to make the adjustments necessaryto provide this critical service.

Kevin 

### L. Myhre CityManager City ofLewistown, MT