SMA INSTRUCTOR PLT TAKES ISSUE WITH UNKNOWN VFR NORDO TFC IN AREA USING SAME NAVAID FACILITY WITHOUT CONTACTING ATC.

Narrative

UPON COMPLETION OF IFR TRAINING; I INSTRUCTED MY STUDENT TO INTERCEPT THE LUNKEN LOC TO ENCOUNTER THE EFFECTS OF LOC SENSITIVITY. WE WERE APPROX 3 MI FROM THE FINAL APCH FIX (MADEIRA NDB) AND NOT YET ESTABLISHED ON THE LOC BECAUSE IT WAS NOT EVEN MOVING THE LOC NEEDLE. JUST AS WE TURNED THE BASE LEG FOR THE APCH A MLT HELI 'GUARD' ACFT CAME INTO VIEW APPARENTLY TRACKING THE LOC BUT NOT IN COM WITH LUNKEN TWR. WE HAD NOT CONTACTED LUNKEN TWR NOR HAD WE BEEN IN CONTACT WITH CINCINNATI APCH CTL DUE TO THE FACT THAT WE WERE DOING SOME TRAINING IN THE SAME RELATIVE AREA APPROX 8-10 MI SE OF THE MADEIRA NDB. WE WERE HOWEVER MONITORING BOTH LUNKEN TWR AND CINCINNATI APCH IN ORDER TO LISTEN FOR POSSIBLE INCOMING TFC; HOWEVER WE DID NOT HEAR THE UH-IH ON EITHER OF THE 2 FREQS. I SEE THE PROBLEM HERE LIES IN THE FACT THAT 2 VFR ACFT ATTEMPTED TO TRACK 1 LOC BEAM FROM QUITE A DISTANCE BEYOND THE FINAL APCH FIX FEELING SAFETY IN THE DISTANCE. MY SUSPICION IS THAT THE HELI WAS DOING THE SAME THING MY STUDENT AND I WERE DOING AND THE CONFLICT COULD HAVE BEEN RESOLVED IF EITHER ACFT WOULD HAVE TAKEN INITIATIVE TO BE IN CONSTANT CONTACT WITH ATC WELL BEFORE INTERCEPTING THE LOC. AS SPECIFIED EARLIER THE MLT DID APPEAR TO BE ESTABLISHED ON THE LOC BEAM AND I WAS ATTEMPTING TO CONTACT ATC BEFORE INTERCEPTING THE LOC. KNOWING THIS I FEEL IF ANYONE WAS TO BE FOUND AT FAULT IT WOULD HAVE TO BE THE FAULT OF THE MLT PLT. I DO NOT FEEL THAT EITHER PLT OF EITHER ACFT SHOULD BE FOUND AT FAULT. I SIMPLY FEEL THAT THERE SHOULD BE A REG IMPLEMENTED CONCERNING FLYING INST APCHS IN BETTER THAN IFR CONDITIONS.