2611 Cabel Road 

PO Box80303 

Billings, MT 5910S.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 of America 

Department of Transportation 

Office of Secretary 

Washington, DC 

Re: Docket DOX-OST-1997-2605 

53 

This letter is in response to the Order to Show Cause Proposing Termination of Essential 

Air Service (EAS) Eligibility of the Miles City and Lewistown, Montana airports. 

It would be extremely unfortunate if either of these 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 meet the eligibility requirements for 

2012, it needs to be noted that passenger enplanements have been substantially more in 

previous years. A summary of the 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 of Transportation Statistics T-100 Market Data 

Note: Silver Airways began providing service In May of 2011 

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! 

TRUSTED ADVISOR 
((~L) 

passengers than the schedules and routes offered by Silver Airways. Based on the 

enplanement data above, demand exists if service is desirable. 

Eastern Montana is experiencing significant growth in energy development and it is 

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 eastern Montana, 

KLJ has used Big Sky Airlines, Great Lakes Airlines and Silver Airways many times. KLJ 

regularly uses Silver Airways for project work in Sidney. KLJ also works in Miles City on a 

regular basis; however, the service provided by Silver Airways is not convenient making it 

more efficient for our employees to drive to Miles City to conduct business. 

We are .also concerned if service to Miles City and Lewistown is terminated, it would have 

a detrimental effect on 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 of these 

communities would have to pay if terminated from the EAS program. 

KLJ believes these comments provide sufficient cause as to why the Department of 

Transportation should not terminate the EAS eligibility of Miles 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 of 2 

NATIONAL PERSPECTIVE 

RECIONAL I!XPERTISE 

TRUSTED ADVISOR