Rick,
61.1(2) allows ground instruction "in accordance with the privileges and limitations" on the GI cert. Section 215 lists those priviledges, "ground training for the knowledge test."
We were through this a few months back on PPRUNE so I'll just cut and paste.
"I got my GI certs under Part 143. In the late 1990s there was a major rewrite of 61 and GI stuff was moved there and 143 went away. One of the things in the NPRM is:
"Section 61.223 Ground Instructor Endorsements and Authorizations
This proposed section would list the endorsements and authorizations that a ground instructor could give. A similar section does not appear in part 143."
Note the last sentence, which is probably why Mrs. Ruth wrote her letter. The numbering got off, there were plans to make GI certs category and class specific that didn't happen but we now have 61.215 which post dates the Chief Counsel letter.
So now if we break down 61.215:
c) A person who holds an instrument ground instructor rating is authorized to provide:
(1) Ground training in the aeronautical knowledge areas required for the issuance of an instrument rating under this part;
Aeronautical knowledge is FAA speak for the written test so an IGI can run a ground school class.
(2) Ground training required for an instrument proficiency check; and
Ok, that's great but when you look up a IPC, there's no requirement for any ground training!
(3) A recommendation for a knowledge test required for the issuance of an instrument rating under this part.
Sign, date and put your cert number on the dotted line.
But nothing about any flight proficiency training. So I'd say to the OP, they could but not for the last 10 years or so."
The Ms. Ruth comment is because someone had posted a Chief Counsel letter from 1980 where the old 61.65 did allow an IGI to give sim training.