Also references:
See Legal Interpretation to Taylor Grayson (Jan. 4, 201 0).
Flight instructors who provide flight training on the "control and maneuvering of an airplane solely by reference to the instruments" in§ 61.109 are not required to have an instrument rating on their flight instructor certificate. See Legal Interpretation to Taylor Grayson (Jan. 4, 201 0). Therefore, the 3 hours of flight training on "the control and maneuvering of an airplane solely by reference to instruments" in§ 61.109(a)(3) may be applied toward the 40 hours of actual or simulated instrument time under § 61.65( d)(2), but may not be applied toward the 15 hours of instrument training unless the flight instructor who provided the flight training under § 61.1 09( a )(3) held an instrument rating on his or her flight instructor cetiificate and otherwise meets the requirements of§ 61.65.