From a FAA Chief Legal Counsel letter of interpretation, stating that simulator instruction CAN be provided by the holder of a Ground Instructor certificate:
FEB. 28, 1980
MRS. M. J. RUTH
Dear Mrs. Ruth:
This is in response to your letter in which you ask what are the appropriate instructor ratings required by the Federal Aviation Regulations for flight instruction in a simulator.
The following regulations provide for the crediting of flight instruction in a simulator toward required flight instruction.
Section 61.65 requires an applicant for an instrument rating to have at least 40 hours of simulated or actual instrument time, of which not more than 20 hours may be instrument instruction by an authorized instructor in an instrument ground trainer acceptable to the Administrator. These 20 hours may be given by ground instructor with an instrument ground instructor rating or by an instrument flight instructor.
Section 61.129(b)(2)(i) requires an applicant for a commercial pilot certificate with an airplane rating to have at least 10 hours of instrument instruction, of which 5 hours must be in flight in airplanes. The 5 hours which may be given in a simulator may only be given by a ground instructor with an instrument ground instructor rating or by an instrument flight instructor.
The appendices of Part 141, Schools and Other Certificated Agencies, allow certain flight training and instruction to be given in a pilot ground trainer that meets the requirements of section 141.41(a)(1) or (2). Section 141.33(a)(3) requires that instructors used for this instruction must hold a flight or ground instructor certificate as appropriate. The appropriate certificates and ratings for instruction in a ground trainer are as follows:
1. For a private pilot certification course (airplanes) [section 3(a) of Appendix A], a ground instructor certificate with any rating or a flight instructor certificate with an airplane rating.
2. For an instrument rating course (airplanes) [section 3 of Appendix C], a ground instructor certificate with an instrument ground instructor rating or a flight instructor certificate with an instrument rating.
3. For a commercial pilot certification course (airplanes) or a commercial test course (airplanes) [section 3 of Appendix D and section 4 of Appendix E], a ground instructor certificate with an advanced ground instructor rating or an instrument ground instructor rating, or a flight instructor certificate with an airplane rating.
We hope this information will be helpful to you.
Sincerely,
EDWARD P. FABERMAN
Acting Assistant Chief Counsel
Regulations and Enforcement Division