And now...the rest of the story...
Just got off the phone with AFS-800. Yes, you can log approaches, holding and tracking in an approved flight simulation device for the purpose of meeting instrument currency without an instructor present. However, you cannot log the time. IOW, all the time colums should be blank -- you fill in only the date, location, device type, approaches and remarks. The reason is that they consider the approaches to be "experience," and there is no longer a requirement for "time" in 61.57(c), so approaches in the FSD without an instructor are experience enough to meet that section, but 61.51(g)(4) prohibits logging instrument time in an FSD without an instructor present. This is documented in FAQ #649 in the no-longer-available-on-line Part 61 FAQ file which AFS-800 still uses internally to answer questions from FSDO's. Caveat: They have not run this past the Chief Counsel, so if someone asks the question of the legal eagles, the answer is subject to change.
Here's the full Q&A. Note that they do not say it's OK to log the time -- they confirmed verbally that it's not OK.
QUESTION: If I use an approved flight training device or flight simulator to accomplish the approaches, holding, and course intercepting/tracking tasks of § 61.57(c)(1)(i), (ii), and (iii), do I need to have a Flight Instructor-Instrument or Instrument Ground Instructor present to sign off the instrument experience? I ask this question because of how § 61.1(b)(10) reads.
ANSWER: Ref. § 61,.51(g)(3)(ii) and § 61.57(c)(1); Provided the person is instrument current or is within the second 6‑month period [See § 61.57(d) for currency], the answer is no a person would not need to 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. Only when a person is required to submit to an instrument proficiency check must a flight instructor or ground instructor be present.
The rationale in my answer 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 instrument meteorological conditions (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‑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.