Originally Posted by
jspudich
I recently received this regarding the need to have an instructor present on the simulator. Do you have any comments?
The October 2009 Part 61 revision was to have done this - no CFI for currency.The explanatory material in the Final Rule says it does.
But the language of the regulation does NOT say that. I and some others noticed the discrepancy shortly after the Final Rule was published. I wrote to John Lynch, who was with FAA for many years and one of the primary authors of the revised rule, who confirmed that this was what they meant to do.
Unfortunately, they didn't. And the FAA Chief counsel said so:
http://www.faa.gov/about/office_org/...0/Keller-1.pdf
IOW, depending on how old your letter is, at least until the Chief Counsel's office and Flight Standards get together on this, the regulation and the Chief Counsel both say a CFI needs to be present in order to log anything in a simulator.