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January 10, 2011 

Dennis J. DeVany 

Chief Essential Air Service Division, X-52 

Office of Aviation Analysis 

Office W86308 

u. S. Department of Transportation 

1200 New Jersey Avenue SE 

Washington, DC 20596 

Dear Mr. DeVany, 

I understand that Great Lakes Aviation and Gulf Stream International Airlines will be 

competing for the next two-year Essential Air Service Contract for Eastern Montana. While I 

have no experience with Gulf Stream International Airlines, .I would hope that in deciding who 

should receive this contract, you will consider that Great Lakes Aviation, when it assumed the 

Big Sky Airlines contract, in my opinion, breached 'the contract from the very beginning. 

Enclosed is a copy of a letter that I wrote to Great Lakes Aviation and to which I had 

no response. The letter explains my concerns and the concerns of many others in this area, 

especially with the integrity of the company that claims to be assuming an existing contract and 

then immediately deviates from it. . 

In my opinion, Great Lakes Aviation is not interested in serving this area so much as in 

maximizing profits. We need a link between Eastern Montana and Billings and hopefully from 

Billings to Helena. Traffic between Eastern Montana and Denver is not what we need. 

Please consider these concerns before you make any decision. 

RAS/mb 

Enc. 

Very truly yours, 

~/I~ RICH~ A. SIMONTON 

P.O. Box' 1249 

Glendive, Montana 59330 

406-377-2666; . 
Monica Taylor 

Great Lakes Aviation LTD 

1022 Airport Parkway 

Cheyenne, Wyoming 82001-1551 

April 13, 2009 

RE: Eastern Montana Essential Air Service 

Dear Ms. Taylor, 

COpy 

While some in Eastern Montana may be celebrating the resumption of air service between 

Glendive and Billings, including the cities of Glasgow, Havre, Lewistown, Miles City, Sidney, 

and Wolf Point, I am not only disappointed, but also confused. 

Great Lakes Aviation and Big Sky Transportation Co. both submitted proposals to 

provide essential air service to Eastern Montana. By Order dated November 29, 2007 the U.S. 

Department of Transportation selected Big Sky for a two-year period beginning March 1, 2008. 

The Order explains why Big Sky was selected over Great Lakes. That Order notes that Great 

Lakes' proposal included the prospect of changing the hub from Billings to Denver "if such a 

change can be agreed upon with the communities." Can it be presumed that Great Lakes would 

not have submitted a proposal unless it had the aircraft and personnel to service the contract? 

And yet when Big Sky asked for relief from the contract for financial reasons, by an Order dated 

just one month after Big Sky's selection, the U.S. Department of Transportation awarded you 

a contract for replacement service at the subsidized rate you originally quoted with service as 

originally required of Big Sky and proposed by you. You accepted. 

Even though the new contract was to begin March 1, 2008, your first stop in Glendive 

was not made until more than one year later. Nor does it appear that you are willing to provide 

the same service as Big Sky since your schedule of leaving Glendive in late morning and 

returning from Billings in early afternoon makes it so inconvenient that flying is actually 

discouraged. Of course not only does your schedule discourage flying, your rates, which are 

two to three times those charged by Big Sky, make it impractical and uneconomical for the 

average person to fly. 

You recently spoke with a reporter from the Glendive Ranger Review and indicated that 

Great Lakes would do its best to accommodate the communities' needs as it expands its aircraft 

fleet and that while your schedule may not meet everyone's needs right away, your goal is to 

get service started because some service is better than no service. I was especially surprised by 

your quote that "This is the best we can do right now as we continue to acquire addition aircraft 

to cover all of the flying we are obligated to. We will continue to work at adjusting schedules 

as these aircraft come in line." I wonder what occurred with Great Lakes between November 

2007 when you represented you had the aircraft and personnel to be awarded the contract and 

December 2007 when you accepted the contract to provide replacement services but did not have 
April 13, 2009 

Monica Taylor 

Page Two 

the planes and personnel. According to the Department of Transportation Order, you had 

informed it that you were willing to provide replacement service based on your recent proposal. 

Department of Transportation found, interestingly enough, that "Great Lakes continues to have 

available adequate financial and managerial resources to provide quality service at the 

communities at issue here." You were directed to provide essential air service to the towns 

involved according to an attached schedule for a period of 24 months. 

Although not mentioned in either your or Big Sky's proposals, it is my understanding that 

we taxpayers are now paying for three to four part-time TSA employees working 24 to 32 hours 

per week because that is what Great Lakes wanted. Amazing how we were able to do without 

TSA for years but now with fewer flyers from Glendive, we have to pay those employees. 

I again note your original proposal that you would not change the hub from Billings to 

Denver without the consent of the affected communities, and yet your first flights from Sidney 

did not go to Billings, but went to Denver. I don't remember any of the communities involved 

consenting to changing the hub of Billings to Denver. When did that occur? Where is the 

service to Eastern Montana communities and the consideration of its needs? 

Having entered into a contract for an $8.2 million annual subsidy for two years, and 

having set a schedule that is inconvenient at prices that cannot be paid by the typical traveler, 

is your next step to ask for some type of relief from the contract requirements because of low 

usage? 

In summary, you bid on a contract representing that you had the aircraft and personnel 

to service it, but when it was awarded to you, you didn't begin that contract as required claiming 

that you do not have the aircraft and personnel. You set schedules apparently convenient to the 

company and not the communities and at rates that will discourage use rather than encourage it. 

You recently told the Ranger Review that you are happy that the community will no longer be 

without flight service. As a practical matter, we still are. The award of the contract to you will 

undoubtedly give you an advantage in the future - if we can show there is a continuing need for 

essential air services, which may be difficult if the numbers don't support it. 

I will be interested in your responses to my concerns so that I and others may have some 

confidence that you really are interested in Eastern Montana. 

Very truly yours, 

RICHARD A. SIMONTON 

P.O. Box 1249 

Glendive, Montana 59330 

(406) 377-2666