I agree 100% with your comments here. The AC shows that there is a line between the PMA and the engineering to prove the part acceptable. One can get a PMA to manufacture one part but it is a complete package from engineering through traceability of raw materials incoming right through testing of finished part.
You MAY not need a DER but you sure will need the engineering data
It still comes down to making the part to some "approved" data sheet which the AC provides a pathway
The idea that we can just say "Its my airplane and I can OPP this part because I think it is made better than the original" just won't cut it for OPP nor would short cut approaches work for holding it out to the public for sale.
Its a full process $$$$$$$$$$ Cost per unit made???????
Balance the cost of setting up a full PMA PROCESS for one part against the cost of a DER to design and sign off on one part and the balance may swing to using a DER for each airplane owner that wants one even paying the DER his "cut" for each sign off.
Finding a DER that will sign of on an intake duct may be a bigger problem than first anticipated.
All of us involved with legacy airplanes face the same fate- death by lack of parts