Sorry, its John Lynch:
John Lynch
Certification Branch, General Aviation and Commercial Division
Flight Standards Service
Regarding Simulated Instrument, from the horses mouth:-
Now in reference to your question/statement “. . . does not use any vision restriction device . . .” Per § 61.51(g)(1), it states “A person may log instrument time only for that flight time when the person operates the aircraft solely by reference to instruments under actual or simulated instrument flight conditions.” So, in order to log instrument flight time the pilot must be utilizing a view-limiting device. Except for when a pilot is operating an aircraft solely by reference to instruments in instrument meteorological conditions (IMC), how else could a pilot comply with § 61.51(g)(1) for logging instrument flight time [i.e., “. . . when the person operates the aircraft solely by reference to instruments under actual or simulated instrument flight conditions.”] unless the pilot was utilizing a view limiting device! So the answer is, in order to log instrument flight time for simulated instrument flight a person must be utilizing a view-limiting device. A promise by the applicant to not look outside the aircraft is not acceptable. And neither is the use of an ordinary ball cap, unless there is view limiting attachments to the bill of the cap that prevents the applicant from having visual reference outside the aircraft.