Pueblo Removes Proposed 100-Hour CFI Cap

City says revised minimum standards draft will go to council July 13.

Pueblo Removes Proposed 100-Hour CFI Cap From Airport Standards
[Credit: Max Delitsyn | Shutterstock]
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Key Takeaways:

  • Pueblo Memorial Airport initially proposed a draft update to its minimum standards that included a 100-hour annual limit on flight instruction for individual instructors.
  • This proposed limit, which would have been measured by Hobbs meter readings and allowed logbook inspections, drew significant public attention and comment.
  • In response to feedback, Pueblo has revised the draft, removing the controversial 100-hour annual limit on permitted flight instruction and related logbook inspection provisions.
  • The revisions aim to align the standards with FAA obligations regarding economic nondiscrimination and the prohibition of exclusive rights for aeronautical activities.
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Pueblo, Colorado, has removed language from a draft update to Pueblo Memorial Airport’s minimum standards that would have limited permitted flight instructors to 100 hours of flight instruction per year. The proposed cap, which would have been measured by Hobbs meter reading, was part of a broader draft addressing commercial aeronautical activities at the airport.

City Revises Draft

“The Minimum Standards for Commercial Aeronautical Activities are a proposal in draft form and remain under active public review,” the city said in a statement provided to AVweb. “They have not been adopted. The City invited public comment on the proposal and received comments from airport users, including on Section 12.02. In response, the City has revised the draft.”

The earlier June 22 draft included a section allowing individual flight instructors to obtain commercial aeronautical service provider permits at the airport, but limited the amount of instruction they would be able to provide. It also would have allowed the airport manager to inspect instructor logbooks periodically to verify compliance with the proposed limit.

100-Hour Limit Removed

“The revised draft removes the proposed 100-hour annual limit on permitted flight instruction, together with the related provisions that measured activity by Hobbs meter reading and that called for periodic inspection of instructor logbooks,” the city said. “Because the limit is being removed, the questions about how it would have applied are no longer part of the proposal.”

The earlier proposal drew attention among pilots after an excerpt from Section 12.02 was posted to Reddit’s r/flying forum. 

The new version of the draft without the CFI cap language has not yet been made public. Even so, an airport representative said there will still be a mechanism to help track and register itinerant instruction based at the field, with the aim of ensuring standards around things like proper credentialing and insurance.

The FAA’s 2025 Airport Sponsor Assurances require federally obligated airports to make airport facilities available for public use on reasonable terms and without unjust discrimination to aeronautical activities, and also prohibit exclusive rights for aeronautical service providers. The city said it reviews its airport standards for consistency with those obligations.

Council Review Scheduled

“The City develops and reviews its airport standards to be consistent with its obligations as a federally obligated airport sponsor, including economic nondiscrimination and the prohibition on exclusive rights,” the city said. “The revisions reflect that review.”

The revised draft is scheduled to go before the Pueblo City Council on July 13.

Matt Ryan

Matt is AVweb's lead editor. His eyes have been turned to the sky for as long as he can remember. Now a fixed-wing pilot, instructor and aviation writer, Matt also leads and teaches a high school aviation program in the Dallas area. Beyond his lifelong obsession with aviation, Matt loves to travel and has lived in Greece, Czechia and Germany for studies and for work.

13 thoughts on “Pueblo Removes Proposed 100-Hour CFI Cap

  1. Should read the rest of the documents that were proposed for the airport for city council approval the 100hr flight instructor thing is only the surface

  2. What actually NEEDS regulation for community safety is : post-solo student flights with passengers; informal instruction being given by non-instructors; and de facto part 135 operations by noncommercial pilots …but how are they gonna detect and punish THAT ?

  3. Where is the FAA? Another instance where local or state entities try to regulate what is a function of the federal government and the FAA as the government’s responsible agency. Whether it’s this, airports restricting the sale of leaded fuels, restricting access to airports that have received federal AIP funds… It’s time for the FAA to ‘man up.’ They’ve let local and state governments chip at their authority. Maybe this all goes back to the FAA and the federal government letting Chicago close Meigs in the middle of the night, with no consequences. Each and everyone of these actions embolding the next local government to pull another ‘stunt’

  4. The city of Pueblo only removed this after a public outcry from the Pueblo Airport Users Association. There are numerous other draconian requirements in the proposed ordinance. Example, An A&P with IA is not allowed to do maintenance in his owned hangar. We are still working to educate city council

  5. Our local airport (Torrance, CXA) prohibits go-arounds and missed instrument approaches on weekends, evenings and holidays! The FAA has been silent.

  6. I ‘might’ understand the missed approaches (if training not actual IMC)

    But go-arounds? A normal safety procedure? WTF

    So what are they going to say when someone slides off the end when they should’ve gone around, but were afraid of the local authorities???

  7. The stated purpose of the Minimum Standards is to promote aeronautical activity. How does limiting an instructor to 100 hrs a year do that? Where is that questioned asked in this article?

  8. When I was an active CFI 100 hours of dual instruction in a month was not unusual. Who came up with 100 hours per year? My guess is no one that knows anything about GA.

  9. The 100 hours a year thing is bonkers. But I imagine CFI’s would just have their “Pueblo” logbook where they forgot to log all their CFI time and their real logbook back at home where that they use when it’s time to apply for another job.

    But since it’s removed, the city probably is hiding even worse rules that they hope people don’t see thinking they “won”. Usually how it goes, they “conceded” and remove one rule to hide even more restrictions.

  10. Although removed for instructors I was not removed for A&
    Ps and IAsAlso retained for all were draconian insurance requirements.

  11. All FBOs need to keep and update the latest info from their CFIs and not let anyone fly with passengers unless they have at least a private pilot license!!!! And have a check out in the aircraft by a CFI they want to take passengers. This should be a no brainer. And has been the way it has been for at least 50 years!

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