Logging simulated instrument time

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First of all hello everyone. I've been lurking here for about a year, this is my first post. I am a recently certified CPL ME IA.

I have a question about logging simulated instrument time. Can I log simulated instrument time while solo on an instrument flight plan, assuming I am flying the plane by reference to instruments?
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Read 91.109
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Thanks 91.109 spells it out. I must have a safety pilot to log simulated instrument time.
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Quote: Thanks 91.109 spells it out. I must have a safety pilot to log simulated instrument time.
... safety pilot or a CFI, CFII or MEI.
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Quote: ... safety pilot or a CFI, CFII or MEI.

A CFI or MEI must also be a CFII in order to give you dual simulated instrument instruction. The only exception is that a CFI/MEI can give instrument instruction to a student pilot for the three hours required for the PPL.

A CFI/MEI could act as a safety pilot of course.
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Quote: ... safety pilot or a CFI, CFII or MEI.
Technically, safety pilot.

Sure it can be a CFI, CFII or MEI, but not if the CFI, CFII or MEI can't qualify as a safety pilot.

It's the safety pilot qualifications that count. CFI with no medical is still a CFI, but can't act as a safety pilot
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Quote: Sure it can be a CFI, CFII or MEI, but not if the CFI, CFII or MEI can't qualify as a safety pilot.
I should have clarified that.
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It doesn't have to be a CFII who gives you the dual. You only need a CFII for 15 hours S.I. Now, if you want to roll the dice with a CFI for 25 of those hours, that's another story.
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Hood Time While Teaching Initial CFI Course
I'm an advanced CFI (triple rated) with a gold seal and I'm able to teach CFI courses at my flight school. Can I log "hood time" while instructing CFI students? For instance, if I wear a hood or foggles during a flight to act as an inexperienced student pilot, to test my CFI student's teaching abilities and situational awareness, can this time be logged? The FAR 14 CFR 61.51(g)(2) mentions that an authorized instructor may log instrument time when conducting instrument flight instruction in actual instrument flight conditions. Does this mean I cannot log hood time under VFR conditions, even if I’m under the hood and my CFI student acts as a safety pilot during the CFI training?
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Quote: I'm an advanced CFI (triple rated) with a gold seal and I'm able to teach CFI courses at my flight school. Can I log "hood time" while instructing CFI students? For instance, if I wear a hood or foggles during a flight to act as an inexperienced student pilot, to test my CFI student's teaching abilities and situational awareness, can this time be logged? The FAR 14 CFR 61.51(g)(2) mentions that an authorized instructor may log instrument time when conducting instrument flight instruction in actual instrument flight conditions. Does this mean I cannot log hood time under VFR conditions, even if I’m under the hood and my CFI student acts as a safety pilot during the CFI training?
The answer is I doubt it. Never heard of anyone doing that.

I see your point, but your primary duty at that point is instruction, and you can log that time as dual given.

Search the FAA legal interpretaions, if there's nothing there you could write them a letter and ask. They respond to those, and the answer becomes a matter of record which you can rely on.

Don't bother asking a FSDO, their answer is not binding on the FAA.
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