Originally Posted by
BeenThere
So there we have it. I've also talked to the HNL FSDO, their opinion is that if you are authorized by the Chief Flight Instructor you can in fact conduct sim training under 61 & 141, just like 135 & 121 ops.
The letter posted above by NoyGonnaDoIt is an FAA headquarters legal opinion which was written last month. It says that you CANNOT act as a sim instructor under part 61 with a GI cert.
This opinion itself is reasonable, but their logic in arriving there looks weak. It's basically "This is the way I want it to be, it doesn't matter what the regs say". I'm guessing they won't try to go back and violate anybody who has done this in the past.