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Well I finally received paperwork from the FAA inspector of the SLC FSDO. It included a short cover letter referencing the materials sent in the envelope, which were basically the kinds of things mentioned in my original posting: Appendix 5 of AC20-138A and FSAW 94-32C, the most recent copies available per his letter. Various items were highlighted but basically I conclude with no hesitation that the installation is legal and sound and a Form 337 is not required. In fact the inspector stated to me on the phone that if one were submitted he would return it with "Not Applicable" noted.
Even antenna installation is noted. There are a lot of little sticky rules listed in the sections quoted above, and some appear even contradictory, such as the need for a placard "GPS Approved for VFR Use Only" in one instance seeming to imply that a Form 337 would be required yet in the Appendix saying the addition of such a placard is in accordance with the Appendix which doesn't require a field approval (Form 337). So like many things in the regs, the FAA could conceivably argue things many ways. We are used to this and the FAA is known to be squirrely in what they want to prove at any time in court. And as we also know, the appeal process is tilted in favor of the agencies at all times.
Nevertheless I think the inspector has made it clear that he sees no reason a Form 337 is required. He told my IA/A&P the same, and as far as I'm concerned anyone out there who feels differently - in reference to my particular case - can go bark up a tree. As for another FSDO (and someone else's aicraft), well we all know that nothing can be set in concrete just because one FSDO says something.
For me the matter is ended. If it ever comes up I have paperwork and a communications trail to support my case.
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