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Can an FTD Simulator be used for 10 of the 15 hours DUAL instrument time required for IFR rating?

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FAA Regulations, Flight Instructor, General Aviation, Instrument Rating

61.65

(d) Aeronautical experience for the instrument-airplane rating. A person who applies for an instrument-airplane rating must have logged:

(2) Forty hours of actual or simulated instrument time in the areas of operation listed in paragraph (c) of this section, of which 15 hours must have been received from an authorized instructor who holds an instrument-airplane rating, and the instrument time includes:

 

Further down 61.65...

(i) Use of an aviation training device. A maximum of 10 hours of instrument time received in a basic aviation training device or a maximum of 20 hours of instrument time received in an advanced aviation training device may be credited for the instrument time requirements of this section if -

(1) The device is approved and authorized by the FAA;

(2) An authorized instructor provides the instrument time in the device; and

(3) The FAA approved the instrument training and instrument tasks performed in the device.

 

I know the FAA requires 40 hours of instrument time. I know that 10 of those hours can be instrument instruction in a BATD with an authorized instructor. I also know that 15 of those 40 hours must be instrument instruction with your CFII... B

Based on those regs, here's the question:

Can the 10 hours of instrument instruction received in the BATD simulator count towards the 15 hours of instrument instruction required for the IFR rating?

 

(2) Forty hours of actual or simulated instrument time in the areas of operation listed in paragraph (c) of this section, of which 15 hours must have been received from an authorized instructor who holds an instrument-airplane rating, and the instrument time includes:

 

All I see is "instrument time" and whether or not it has been received from an authorized instructor. I don't see "flight time" or "in an aircraft/airplane" anywhere in here, except for the cross-country requirements.

 

It would seem that if the answer is yes, I could train my client 10 hours in the BATD, then do the remaining 5 in the airplane, and that counts towards the 15 hours.... thoughts?

(we won't argue whether or not just 5 hours on the plane is a good idea.)

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