January I 6, 20 I 4 

The Hon. Susan Kurland 

Assistant Secretary for Policy and International Affairs 

Department of Transportation 

on the river ~ • on the move 

1200 New Jersey Ave., S.E. 

Washington, DC 20590 

Re: Essential Air Service·for Pierre. South Dakota 

Dear Ms. Kurland: 

I am writing to urge your action with respect to the failure of Great Lakes Aviation ("G[~at 

Lakes") to provide an adequate level of essential air service to Pierre, the capital of South 

Dakota. Even at the low frequency the carrier is now operating, its service is so unreliable that, 

quite simply, it is killing the air service market at our city. I am asking for your assistance to 

remedy this situation. which may include a new commercial air carrier and eligibility for the 

essential air service funding in Pierre. 

Two years ago, the Department took decisive action to keep Delta Air Lines from 

withdrawing its service at Pierre. By Orders 2011-11-4 and 2012-1-7, the Department held in 

Delta's Pierre-Minneapolis service until Great Lakes was able to initiate its own service 

(subsidy-free) on that route in February 2012. This supplemented the carrier's existing service 

to Denver. The Department required the carrier to provide two daily round trips to MSP. 

Great Lakes got off to a slow start in 2012, as reflected in the monthly and annual 

passenger numbers at PIR. The announced pullout of Delta and its irregular service in the last 

few months before its termination cut deeply into passenger bookings, and Great Lakes was not 

able to build traffic even close to previous levels until 2013. Prior to last August, Great Lakes 

was offering eight daily roundtrip flights at PIR; this was reduced to six, and then December 1, 

to four (two each to Denver and Minneapolis). It is our understanding that these reductions 

were not driven primarily by a drop in traffic demand, but resulted from the difficulties the carrier 

has had with implementing the new FAA rules on minimum qualifications for co-pilots, which has 

resulted in layoff of a large proportion of the carrier's crews. This has led to an enormous 

cutback in the carrier's capacity -- a reduction of 38.1% in December 2012 v. 2013. (PR 

Newswire, January 7, 2013.) 

More serious than the infrequency of the service, however, is its extreme unreliability. In 

November and December of 2013, Great Lakes' cancellation rate was 21% and 20%, 

respectively. In other words, one out of five flights didn't show up. This was a substantial 

increase from the already-poor levels of 9% in August ahd October, and 7% in September. 

While winter weather always increases flight cancellations somewhat, the weather was not the 

primary factor in this dramatic increase; indeed, my conversations with Great Lakes 

management and other communities confirms that th~se statistics reflect a system-wide 

problem. And the problem is not limited to cancellations; of the 100 flights (out of 124 

scheduled) that operated in December, only 53 were on time (using the Department's standard 

15-minute window for determining flight d~lays). Combined with the cancellations, this means 

that we are experiencing an unacceptable 43% on-time departure rate: 

LEGAL\18032247\1 Finance Office 

(605) 773-7407 

222 East Dakota • PO Box 1253 

Pierre, South Dakota 57501-1253 

http://ci.pierre.sd.us 

Fax (605) 773-7406 

Public Works 

(605) 773-7341 

, .. ,.• 
Air service unr~liability is now the number-one complaint that I receive as Mayor of 

Pierre; business leaders, government officials, lodge owners and private travelers tell me that 

they would rather drive hours to Rapid City or Sioux Falls than take such a substantial risk that 

their flight will not even operate. And with such a reduced schedule, each flight becomes more 

critical, and its cancellation more damaging. 

The Department has always recognized the great importance to the EAS program of 

maintaining reliable, timely service. It assumes a 98% completion factor in calculating subsidy 

payme.nts. It is a standard condition of EAS subsidy orders that "the carrier must complete all 

flights that can be safely operated." The Statute itself requires that in awarding EAS to a 

particular carrier, the Department consider, as the first criterion, "the demonstrated reliability of 

the applicant in providing scheduled air service." (49 U.S.C. § 41733(c)(1)(A). The reason is 

obvious: passenger boardings at an airport will decline as soon as the flying public realizes that 

it can't depend on the schedules offered. This undercuts the stated goal of the program, to help 

communities develop their air service markets so as to avoid the necessity of requiring subsidy 

to maintain the statutorily guaranteed air service. 

While Pierre has thus far not required subsidy, the last two months have seen such a 

shrinkage in its air service market that it will be difficult to rebuild sufficient confidence in air 

service to ensure a self-sufficient air service market. 

We have reluctantly concluded that the only thing that will salvage our air service market 

is for the Department to declare that the service being provided by Great Lakes does not meet 

the requirements of Essential Air Service, and open a proceeding for bids to provide this 

service. If this can be done without subsidy, all the better; however, given the rapidity of the. 

market's deterioration, quick action must be taken or the Department will not be able to avoid 

paying subsidy for service to Pierre. 

Our city is anxious to work with the Department to bring about the kind of air service to 

which Pierre is entitled. We hope to speak with you and your staff in the near future. 

Sincerely, 

~uZ~;:ayor 

'//,w~~· . (. ~ 

City of Pierre 

Cc: Sen. Tim Johnson 

Sen. John Thune 

Rep. Kristi Noem 

Kevin Schlemmer 

Dennis DeVany 

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