On Sat, 10 Dec 2005 14:37:52 +0000 (UTC),
wrote:

: I haven't read the regs lately, but do they specifically require
: simulated instrument flight in order to count?

No... you could do all your IFR training in actual conditions. It *does*
require that the dual you get is from a CFII, however. That's not to say you cannot
get dual instruction in IMC from a CFI as the OP suggested... just that it cannot
count it towards the dual required for an IR. Now there's an alphabet soup...

I don't think we're taking about an *instrument* student. Isn't this
subthread talking about whether IMC encountered whilst a primary
student (flying with a CFI, not CFII) could be countable towards the 3
hours required in 61.109(3)?

And 61.109(3) doesn't say whether the time has to be simulated or
actual, it just says "solely by reference to instruments".