SMA ON IFR TRAINING FLT FAILED TO REPORT MOLTS INBOUND AS INSTRUCTED WHILE EXECUTING ILS RWY 9L AT OPF.

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WHILE CONDUCTING INSTRUMENT FLT TRNING UNDER IFR FLT PLAN; DURING DAYTIME AND CLEAR VFR WX. AT OPF THE COMMON PROC IS TO RPT MOLTZ INTXN 5.4 NM FROM THRESHOLD AT 1815' AFTER BEGINNING DSCNT ON G/S. APCH CLRED US FOR THE APCH AND ASSIGNED AN INTERCEPT WITHIN 30 DEGS APPROX 2 MI OUTSIDE THE APCH GATE; WHICH I WOULD ESTIMATE AS BEING APPROX 3 NM FROM MOLTZ INTXN. MORE THAN NORMAL AMOUNT OF TIME WAS TAKEN TO CONTACT OPF TWR AS I ALLOWED THE STUDENT TO GET ESTABLISHED AND STABILIZED ON LOC; PERFORM BEFORE LNDG CHKS AND CHANGE RADIO FREQ TO TWR. DSCNT ON G/S WAS BEGUN BEFORE CONTACTING THE TWR. I HEARD ONLY ONE OTHER ACFT IN CONTACT WITH TWR AND THE ARPT WAS NOT CONGESTED. HAD THE DSCNT CONTINUED FURTHER I WOULD HAVE ADVISED TWR OF OUR LOCATION; HOWEVER STUDENT DID CONTACT TWR AT APPROX 1600-1700' ONCE STABILIZED ON APCH. TWR ADVISED US WE WERE 1 MI INSIDE MOLTZ INTXN AND THAT WE WERE TO CONTACT PRIOR TO REACHING MOLTZ AND ENTERING THE ATA. TWR USED RADAR EQUIP TO LOCATE US AT 1 MI INSIDE MOLTZ AND I WOULD ESTIMATE APPROX THE SAME. THE TWR IMPLIED WE HAD ENTERED THE ATA W/O ESTABLISHING COMS. WHILE I AM AWARE THIS IS REQUIRED TO BE DONE; I BELIEVE SOMETIMES FLT TRNING PLACES STRAIN AND SOMEWHAT OF POSSIBLE PROBS WHICH I ALSO UNDERSTAND ARE SOLELY THE RESPONSIBILITY OF THE FLT INSTR AND NOT THE STUDENT. HOWEVER; I BELIEVE SINCE THE FLT USED A FILED IFR FLT; TFC WAS LIGHT AND THE TWR WAS AWARE OF OUR APCH (THE SECOND ONE AT OPF); IT SHOULD BE THE PLT'S FIRST RESPONSIBILITY TO FLY THE AIRPLANE; NAV; THEN COM. I DON'T BELIEVE OUR POS POSED ANY SAFETY PROBS OR POTENTIAL PROBS TO OTHER TFC OR OURSELVES AS THE AREA WAS CLR OF TFC. THE INCIDENT WAS DISCUSSED WITH THE STUDENT IN POST-FLT AND PLT RESPONSIBILITY TO FLY; NAV; COM; YET IN A TRNING FLT IT IS THE INSTR'S RESPONSIBILITY TO PREVENT SUCH CONFLICTS; YET STILL ALLOW THE STUDENT TO LEARN SUCH PRIORITIES W/O THE INSTR DOING ALL SENSITIVE ASPECTS OF THE FLT. THUS; I FEEL THERE IS A FINE LINE BTWN PRODUCTIVE FLT TRNING AND LEGALITY INVOLVED IN TRNING OPS. IN RESPONSE TO OPF'S IMPLICATION OF ENTERING THE ATA W/O PROPER CLRNC I BELIEVE TECHNICALLY THAT IF WE WERE 1 MI INSIDE MOLTZ (5.4 NM FROM THRESHOLD AS RPTED BY TWR WE ACTUALLY HAD NOT ENTERED THE ATA WHICH IS 5 SM FROM GEOGRAPHIC CENTER OF ARPT. AT 1 MI INSIDE MOLTZ [5.4 NM] WE WERE 5.016 SM FROM THRESHOLD; AND AS ATA IS FROM CENTER OF ARPT THIS WOULD TECHNICALLY PLACE OUR POS FURTHER OUTSIDE OPF ATA. SUCH A TECHNICAL APCH I FEEL IS APPLICABLE ONLY TO DEFENSE OF A POSSIBLE VIOLATION. IN PRACTICAL TERMS I BELIEVE COOPERATION BTWN CTLRS AND PLTS AND CONSIDERATION OF THE ASPECTS ASSOCIATED WITH FLT TRNING IS NEEDED. THE ACFT CALL SIGN IS FAMILIAR TO THE TWR AND APCH AS IT IS OPERATED BY A VERY LARGE FLT SCHOOL WHICH OPERATES AT OPF DAILY. I WILL; IN THE FUTURE TRNING FLTS; MAKE A MORE CONCERTED ATTEMPT TO ESTABLISH OR HAVE STUDENT CONTACT TWR WHEN APPROPRIATE TO AVOID SUCH INCIDENTS. INCREASED DILIGENCE SHOULD PREVENT ANY FURTHER OCCURRENCES.