I know this is an old topic, but looking back into the archives of
this group, I couldn't find a definitive or current answer. And, this
came up for me yesterday when I booked a simulator for IFR currency.

I called Advanced Aviation Simulators at APA to try out their service.
Based on my understanding of the regs, I also requested an instructor
so I could log at least holding and the 3 approaches I needed. The
instructors there were happy to oblige my request, but insisted I
didn't need an instructor to regain currency for IFR. I showed them
the Part 61 Regs that said that you must *log* 6 approaches, holding,
and intercepting, and that in order to *log* instrument time in a
simulator, you must have an instructor present (interesting to note
the instructor must be present, but apparently need not instruct).

The two instructors there continued to insist an instructor wasn't
necessary. They contend that if I flew solo in the simulator, I would
enter in my logbook the 3 approaches and note the holding and
intercepting in the comments, but not log any flight time. By this
entry in my logbook, I would satisfy the recency of experience
requirement without logging any flight time. This seems dubious logic
to me, so I went ahead and hired the instructor (it was worth it since
I was quite rusty) and now have an instructors entry in my logbook
showing that I have the required recent experience.

Since this company does this as its sole business, I would tend to
believe that they know what they're talking about. But, it doesn't
make any sense to me based on the FAR's. Can anyone point me to an FAA
interpretation, or similar reference that would support their
assertion? I found AC 61-98A which seems to support my position that
an instructor is required. But, that's pretty old (1991?) and still
refers to the old requirement of 6 hours of instrument flight time.

Can anyone help?

Thanks,

Bill Levenson
PP-ASEL-IA