To: Dock Operations M-30 

West Building Ground Floor W-12-140 

1200 New Jersey Avenue SE 

.Washington DC 20590-3 

United States of America 

Department of Transportation 

Office of Secretary 

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 Order to Show Cause Proposing Termination of Essential Air Service 

Eligibility directed to Lewistown and Miles City, Montana issued March 28, 2013. I am a 

businessman and an attorney. 

Subsidy eligibility of Lewistown and Miles City under the EAS program should not be 

terminated because: 

1. "Community" includes the rural "community' of all of Eastern Montana and 

"community" and "eligible place" under Public Law 112-951 should not arbitrarily be 

defined as just the small towns of Lewistown and Miles City, Montana. Termination of 

EAS based on defining an "eligible place" as a place with concentrated population is 

unfair and not good public policy. Obviously, concentrated population using air services 

results in a lower cost per passenger. 

It is important to understand our rural community is an area and it is not within the city 

limits of Miles City or Lewistown. Therefor, the "eligible place" is Eastern Montana. I 

do not think the FAA Modernization and Reform Act of 20 12 defines or requires 

"eligible place" to just be in defined city limits. 

Miles City and Lewistown are "hubs" for the rural community of Eastern Montana. 

A family located 500 feet or 100 miles out of the City limits of these towns is a member 

of the "community" served by these towns. 

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2. Calculation of subsidy cost per passenger 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, 

Brockway to name a few. All of these small towns are part of our community. 

Eastern Montana population is say 100,000 and the entire area needs air services. These 

people should not have to drive an additional 200 to 300 miles to board an airplane. 

~ Effect of denying 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 been terminated leaving only private vehicles 

to transport to airlines located at Billings, Montana. The effect of termination of EAS 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 of increasing area 

population and more travel by vehicle in and out of the ciil rich Bakken area in Montana 

and North Dakota. 

Rather than terminating subsidy eligibility, a better solution is the DOT requiring better 

scheduling timing for boarding. At a recent public meeting, businessmen clearly stated 

they previously used the Miles City airline but now the flights do not make for easy 

connections. For example, in order to travel by air to Denver, Colorado from Miles City, 

Montana, a passenger gets on at Miles City in the 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 in the wrong direction to Billings and then onto 

another airline to get to Williston which is the center of the 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. For example, vehicle driving for an elderly person, 

businessman, employee, disabled veteran or college student may not be feasible. 

Any one of the above reasons shows cause why the subsidy eligibility of Lewistown and 

Miles City under the EAS program should not be terminated. 

The effect oftermination deprives our rural community of a method of transportation that 

continues to be needed and essential to our area. 

Best regards, 

William Krutzfeldt 

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