2611 CabelRoad PO Box80303 Billings, MT5910S.o3o3 4062455499 kQeng.com



## 9 April11, 2013
Docket Operations M-30 West Building Ground Floor W12-140 1200 New Jersey Avenue SE Washington, DC 20590;3
United States ofAmerica Department ofTransportation Office ofSecretary Washington, DC
Re: Docket DOX-OST-1997-2605 

# 53

This letter is in response tothe Order to Show Cause Proposing Termination of Essential Air Service (EAS) Eligibility ofthe Miles City and Lewistown, Montana airports.
Itwould be extremely unfortunate ifeitherofthese communities were to lose their EAS eligibility. Both communities have met EAS eligibility requirements in the past. White it's recognized that Miles City and Lewistown did not meetthe eligibility requirements for 2012, it needs to be noted that passenger enplanements have been substantiallymore in previous years. A summary ofthe Miles City and Lewistown enplanement data for the past 1

0-years is summarized in the table below:
Year Miles City
2003 1056 2004 1092 2005 1234 2006 1161 2007 1138 2008 252 ( 6 months) 2009 891 2010 1029 2011 602 2012 360
Source: Bureau ofTransportation StatisticsT-100 MarketData Note: SilverAirwaysbeganproviding serviceInMayof2011 Lewistown Airline
783 Big Sky 780 Big Sky 828 Big Sky 699 Big Sky 667 Big Sky 578 (7 months) Big Sky 1036 Great Lakes 700 Great Lakes 358 ., Silver 337 Silver

As can be from the data, passenger enplanements for both Mites City and Lewistown are down considerably since Silver Airways took over the Montana EAS program in 2011. Service and schedule are the primary·reasons enplanements are down. Both Big Sky Airlines and Great Lakes Airlines offered schedules and routes more desirable to

NATIONAL PERSPECTIVE REGIONAL EXPERTIS! TRUSTEDADVISOR

# ((~L)

passengers than the schedules and routes offered by Silver Airways. Based on the enplanement data above, demand exists ifservice isdesirable.
Eastern Montana is experiencing significant growth in energy development and itis anticipated this development will continue for the foreseeable future. 

### As energy development grows the need for reliable and convenient air transportation service will increase. 

### As an engineering company working in many communities in easternMontana, KLJ has used Big Sky Airlines, Great Lakes Airlines and SilverAirways many times. KLJ regularly uses Silver Airways for projectwork in Sidney. KLJ also works in Miles City on a regular basis; however, the service provided by SilverAirways is not convenient making it more efficientfor our employees to drive to Miles City to conduct business.
We are.also concerned ifservice to Miles City and Lewistown is terminated, itwould have a detrimental effecton Glendive and Havre. While passenger demand from Glendive and Havre may not be impacted, the subsidy per passenger would increase significantly because the cost sharing benefits with Miles City and Lewistown would be lost.
It has also been suggested once eliminated from the EAS program, a community cannot reapply. Considering past demand, this would be a severe penalty each ofthese communities would have to pay ifterminated from the EAS program. KLJ believes these comments provide sufficient cause as towhy the Department of Transportation should notterminate the EAS eligibility ofMiles City and Lewistown. It is · requested the order in Docket DOT-OST-1997-2605 not be enforced and allow the communities sufficient time to develop a plan to increase enplanements and preserve their eligibility in the EAS program.
Sincerely, ' KU Engineering /**.~** r-**/~** ./**,,.--'<'~**... <VV> //" ..,.....,,: / Craig 

### C. C nfield, P.E.

Page 2 of2 NATIONAL PERSPECTIVE RECIONAL I!XPERTISE TRUSTED ADVISOR