"Gene Kearns" wrote in message
...

The best way to find out about the rationality of it all is to have
the ASI to (1) show you in the regs where it says it is a major
alteration and (2) explain to you what the purpose of AC 20-138A is
and what it means.

Oh no. Never ask an FAA person to explain the regs -- you most definitely
won't like the answer. Do your own homework.

In all my dealings with certifications, one thing is very clear: It is not
the inspector's or ACO's job to tell you how to comply with the regulations.
Their job is to determine whether you have presented proper evidence to show
compliance. It is your job to show that you are complying with the regs.

The only break you get is the AC. It describes "a means, but not the only
means of showing compliance..." Read it. Understand it. Follow it.
Document everything the way it says to. If you follow it, and submit the
documentation to prove you did, they won't argue with you. There may be
other ways to show compliance; but if you try them, you're on your own. The
AC is the path of least resistance.

Gerry