Mike Granby wrote:

BB, I believe it has *always* been at the IA's discretion
to make major alterations. The rub is that major alterations
require approved data.


Well, quite. If the alteration has approved data (eg. an STC) then the
IA can sign the 337, and he then sends it straight to OK City. But if
he merely has acceptable data, the most common route open to him is a
Field Approval whereby he sends that data with a 337 to the FSDO, and
gets them to turn that into approved data by stamping it and signing
the magic box. The IA can then sign the form after completion, and send
it off to OK City for filing. But that still means that the FSDO is
involved in the Field Approval process. Do you still assert the Field
Approvals do not involve a FSDO and go straight to OK City???

Yes, the FSDO's are being directed not to approve data unless it's
something that's pretty simple, stuff that is probably a minor
alteration in the first place. What they really seem to be saying is we
don't have the expertise in the field anymore so send it to our
engineers in OKC or get your own DER. Which I think in the end is good.
This should create a demand for DER's which will mean more of them and
known stable prices.