FAA proposed change regarding instrument currency

Among other things included in the massive list of changes the FAA is
proposing to Part 61 is a new allowance for utilizing PCATD, FS, and
FTDs in order to accomplish the recency of experience requirements for
IFR flight:


"Under proposed § 61.57(c)(2), a person could use an FS or FTD
exclusively by performing and logging at least 3 hours of instrument
recent flight experience within the 6 calendar months before the date
of the flight.

Under proposed § 61.57(c)(3), a person could use a PCATD exclusively
by having performed and logged at least 3 hours of instrument recent
experience within the 2 calendar months before the date of the flight.
We have deliberately proposed differences between the use of a PCATD
and an FS or FTD because use of a PCATD to maintain instrument recent
experience is a relatively new concept, and the FAA wants to further
evaluate its use before we allow use of PCATDs equal to that of FSs
and FTDs."


I didn't notice at first glance any additional requirements, such as
an instructor needing to be present when using these devices. This to
me certainly would make staying instrument current much easier, as you
could accomplish the requirements at home on a personal computer using
an approved software app. I think Elite is one such approved
application (at least when used in conjunction with an instructor)
right now.

Anybody have any thoughts on this change?

--
Guy