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CFI qualifications for instrument training

Hi John, got a question, thought the FAR man would be best to ask.
Training instrument to a student pilot the 3 hrs. required 61.109, can a CFI do that, not CFII?
I have found multiple discussions on that, looks like they all say yes, just not the 15 hrs. required in 61.65(d).
What do you think on that.
Thanks Doug

Private instrument training can be done by CFI.

Training for commercial and instrument rating must be by a CFII.

§61.195

(c) Instrument rating. A flight instructor may conduct instrument training for the issuance of an instrument rating, a type rating not limited to VFR, or the instrument training required for commercial pilot and airline transport pilot certificates if the following requirements are met:

(1) Except as provided in paragraph (c)(2) of this section, the flight instructor must hold an instrument rating appropriate to the aircraft used for the instrument training on his or her flight instructor certificate, and—

Same applies to instrument training in a BATD or AATD (Basic or Advanced Aviation Training Device e.g. Redbird, FlyThisSim).

If the Legal Interpretation in Beard is still the most recent, it confirms my reading of the FARs. A CFII is required for the instrument training required for the Instrument Rating and Commercial Certificate.

It has been the FAA’s consistent interpretation of §61.195(b) and (c) that, in order to conduct instrument flight training in an aircraft, a flight instructor must hold on his or her flight instructor certificate (1) aircraft category and class ratings for the aircraft in which the training is conducted, and (2) an instrument rating appropriate to the category of aircraft. Interpretation to Taylor Grayson, January 4, 2010. As § 61.195 was originally written before the rules permitted flight simulators and flight training devices to be used for training, it does not mention conducting instrument flight training in those devices. However, the FAA has interpreted the instructor requirements under this section to apply to instruction in flight simulators and flight training devices, as well, since these devices are designed to replicate flight by category and class of aircraft. The FAA will examine §61.195 to determine whether we need to clarify the regulation.

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