May an instrument instructor log instrument approaches that a student flies in simulated conditions as approaches for currency purposes?

Question

There's rumor that a former DPE claimed that a CFII who is providing training to a student can log that student's simulated instrument approaches as the instructor's approaches for currency purposes.

That didn't sound like it could be true, so I asked him if he could provide a written source to back it, but he could not.

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So, is it true? If so, can you please provide a source to prove it in your answer.

Common sense would tell me this is not true because the instructor is neither flying the plane nor logging instrument time.

Does it make any difference if the approach is simulated instrument in a flight simulator or FTD in which neither the instructor nor student have reference to anything but instruments?

Answer 1

It depends on the conditions.

For actual conditions:

The FAA addresses this in this letter of interpretation: (see full letter for the whole explanation)

QUESTION: Am I correct in understating that a CFII may log approaches that a student flies when those approaches are conducted in actual [IMC]?

ANSWER: Ref 61.51 Yes, a CFII may log approaches that a student flies when those approaches are in actual [IMC].

...

The Chief Counsel's office agrees that the earlier guidance reflects the appropriate interpretation of the regulation.

For Simulated VFR conditions:

If the student is flying under the hood in VFR conditions the Instructor may not log in the time also based on 61.51. Instructors may only log instrument time in actual conditions.

(g)Logging instrument time.

(1) A person may log instrument time only for that flight time when the person operates the aircraft solely by reference to instruments under actual or simulated instrument flight conditions.

(2) An authorized instructor may log instrument time when conducting instrument flight instruction in actual instrument flight conditions.

(3) For the purposes of logging instrument time to meet the recent instrument experience requirements of § 61.57(c) of this part, the following information must be recorded in the person's logbook -

(i) The location and type of each instrument approach accomplished; and

(ii) The name of the safety pilot, if required.

Most GA sims I have encountered can only be used by one person at a time. The CFII is there to observe and advise but cant really "take over"

(4) A person may use time in a full flight simulator, flight training device, or aviation training device for acquiring instrument aeronautical experience for a pilot certificate or rating provided an authorized instructor is present to observe that time and signs the person's logbook or training record to verify the time and the content of the training session.