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Well, for interest's sake, I called the SLC FSDO and talked to the inspector who does the approvals for this type of thing. Here:s his conclusion:
This kind of installation is considered "a minor alteration" and does NOT require a field approval (i.e., a form 337). Now he admitted that this could vary from FSDO to FSDO and possibly from inspector to inspector. But this guy is going to give it to me in writing. In fact he said if I or my mechanics were to send in a form 337 approval on this he would return it as not applicable and notify us that it was "a minor alteration." He said that was the key phrase, and recommended that the logbook entry use that verbiage. If for some reason you had to make a "major" alteration to mount the thing in your aircraft I suppose that's obviously something that would have to be considered. But I doubt that would be something involved in most cases.
So if you live in the SLC Flight Standards District, you can quote Ron Gudmunson, FAA Inspector - through me, I suppose, unless you want to personally contact him to get your own documentation. But if you live in another district then I recommend you contact your own FSDO people and do accordingly.
As far as I'm concerned, I'm covered, and I'm going to get the written response from him to keep in the aircraft in case I ever get any flak from someone outside this district.
I am attaching a Word document of Appendix 5 of AC-138A, which covers this subject quite clearly.
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