To: Dock Operations M-30 West Building Ground Floor W-12-140 1200 NewJersey Avenue SE .Washington DC 20590-3

United States ofAmerica Department ofTransportation Office ofSecretary Washington DC

Susan 

### L. Kurland Assistant Secretary for Aviation and International Affairs

From: William Krutzfeldt P.O. Box 1265 Miles City, MT 59301
April 9, 2013

Re: Docket DOS-OST-1997-2605 Essential Air Service for Eastern Montana

Dear Ms. Kurland

This letter responds to the Orderto Show Cause Proposing Termination ofEssential Air Service Eligibility directed to Lewistown and Miles City, Montanaissued March 28, 2013. I am a businessman and an attorney. Subsidy eligibility ofLewistown and Miles Cityunder the EAS program should not be terminated because:



## 1. "Community" includes the rural "community' ofall ofEastern Montana and "community" and "eligibleplace" under Public Law 112-951 should not arbitrarily be defined asjustthe small towns ofLewistown and Miles City, Montana. Termination of EAS based on defining an "eligibleplace" as a place with concentrated population is unfair and not good public policy. Obviously, concentrated population using air services results in a lower costperpassenger.

Itis important to understand ourrural community is an area and it is not within the city limits ofMiles City or Lewistown. Therefor, the "eligible place" is EasternMontana. I do not think the FAA Modernization and Reform Act of2012 defines orrequires "eligibleplace" tojustbe in defined city limits.

Miles City and Lewistown are "hubs" for the rural community ofEastern Montana. A family located 500 feet or 100 miles out ofthe City limits ofthese towns is a member ofthe "community" served by these towns.



### 12. Calculation ofsubsidy cost perpassenger should be calculated by using the historical method that used passenger data from Miles City,·Lewistown, Havre, Glasgow, Wolf Point, Sidney, Glendive. These are all communities serving the rural "community" of Eastern Montana. Miles City also serves other small towns and villages in the area including Colstrip, Lame Deer(native americans), Ashland, Birney, Broadus, Ekalaka, Baker, Plevna, Forsyth, Kinsey, Terry, Fallon, Mildred, Wibaux, Cohagen, Jordan, Grass Range, Winnett, Brockwayto name a few. All ofthese small towns are part ofour community. Eastern Montanapopulation is say 100,000 and the entire area needs air services. These people shouldnot have to drive an additional 200 to 300 miles to board an airplane.**~** Effect ofdenying the subsidy is to deprive air service to the elderly, Veterans, Native Americans, rural families, and disabled people from access to air services. At this time, bus services from Miles City, Montana has beenterminated leaving onlyprivate vehicles
to transport to airlines located at Billings, Montana. The effect oftermination ofEAS is
to deny those least able to help themselves. 4. Passenger use decline at Miles City, Montana is due to airline scheduling. A better solution to termination is boarding timing. The present carrier does not have a boarding schedule making it attractive to use the airline. This is proved by 2010 usage of 1029 hoardings whereas 2012 usage was 360. This has occurred at a time ofincreasing area population and more travel by vehicle in and out ofthe ciil rich Bakken area in Montana and North Dakota. Rather than terminating subsidyeligibility, a better solution is the DOTrequiring better scheduling timing for boarding. At a recentpublicmeeting, businessmen clearly stated they previously used the Miles City airline butnow the flights do notmake for easy connections. Forexample, in orderto travel by airto Denver, Colorado from Miles City, Montana, a passenger gets onat Miles City inthe late afternoon, and then must stay overnight in Billings, Montana and then get onto another airline to get to Denver. Or if they want to travel to Williston, they go inthe wrong direction to Billings and then onto another airline to getto Williston which is the center ofthe oil development. A better boarding time that was previously available would be boarding ay say 7 A.M. in Miles City and catching a connecting flight to Denver at say 9 A.M. in Billings thus eliminating the overnight in Billings.**~** Travel safety is a factor in Eastern Montana. There are times ,when vehicle travel is not safe due to road ice and snow. Forexample, vehicle driving for an elderly person, businessman, employee, disabled veteran orcollege student may not be feasible.


### Any one ofthe above reasons shows cause why the subsidy eligibility ofLewistown and Miles City under the EAS program should notbe terminated. The effect ofterminationdeprives ourrural community ofa method oftransportation that continues to be needed and essential to our area.

Best regards,

William Krutzfeldt

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