61.109(a)(3) 3 hours of flight training in a single-engine airplane
on the control and maneuvering of an airplane solely by reference to
instruments...


61.65(d)(2) A total of 40 hours of actual or simulated instrument time
on the areas of operation of this section...


They may not be equivalent to each other, BUT the key here is they are
NOT mutually exclusive. A given experience CAN meet both requirements at
the same time. It wouldnt be the first time a DE has been wrong.

On a side note, I went to look up the part 61 FAQ section for guidance
and have discovered that the FAA has removed it from their website in
favor of issuing personalized opinions to individual questions.

Dave