Use of desktop simulators to maintain instrument proficiency

I received this e-mail from Sky Manor Based Cessna 210 pilot Alan Gauthier. I would appreciate your comments.

After many hours of research on the above subject I still do not feel I have found an answer that is "carved in stone" so I thought I'd throw it out to other pilots I know.

Here's the issue. (and I have to thank Don Wright for giving me the opportunity to waste so many hours! ) In August 2009, the FAA issued a change to CFR (FAR) 61.57 effective October 2009 relating to the use of flight simulators in maintaining instrument currency requirements. The issue that I cannot get a definite answer to is: Does an instructor need to be present while logging simulator time for the purpose of maintaining instrument currency. Furthermore, it is clear that an instructor must be present when using a simulator for time accumulated towards a certificate, rating or flight review. However, if a pilot is instrument current he is not accumulating time towards any certificate, rating or flight review he is simply maintaining currency requirements specified in 61.57. For the present, lets not digress into the 3 types of simulators, the question that no one (except bruceair.com) seems to have an answer to is about the necessity of having an instructor present. The folks at bruceair are adamant that an instructor does not have to be present.

A reading of the new 61.57 or 61.51 (logging of time) does not answer the question. The answer to the question is found in the Federal Register of August 2009 which I have personally read and cut and pasted below:

"A person would not need a flight instructor or ground instructor present when accomplishing the approaches, holding, and course intercepting/tracking tasks of §61.57(c)(1)(i), (ii), and (iii) in an approved flight training device or flight simulator. Only when a person is required to submit to an instrument proficiency check must a flight instructor or ground instructor be present. The rationale is that a person is not required to have a flight instructor or ground instructor present when performing the approaches, holding, and course intercepting/tracking tasks in an aircraft. If the person is using a view-limiting device (i.e., hood device) when performing the approaches, holding, and course intercepting/ tracking tasks in an aircraft, only a safety pilot is required to be present. If a person is performing approaches, holding, and course intercepting/ tracking tasks in an aircraft in IMC, it is permissible to log the tasks without a flight instructor being present. Therefore, a person who is instrument current or is within the second 6-calendar month period (See §61.57(d) for currency) need not have a flight instructor or ground instructor present when accomplishing the approaches, holding, and course intercepting/ tracking tasks of §61.57(c)(1)(i), (ii), and (iii) in an approved flight training device or flight simulator."

This seems crystal clear to me and the people at bruceair.com, with whom I have corresponded. However, after days of trying to get an answer from AOPA with nothing but whishy washy answers that never came close to answering THE question I thought I'd send it out to all of you to offer your opinions and thoughts!

Best regards!

Alan Gauthier