I agree with you about an STC being approved data. I also agree that once a mod is approved 337 or otherwise, it will always be "approved". In other words no one is making the current owner of that 180 hp Citabria in Blunt SD, remove the O-360 engine.
However, when it's done via a 337 it's not the same as an STC. At the time that engine was installed via 337, there was no such thing as a metal spar wing for the Citabria and no mention of the need for one in the type certificate. That meant that when the data supporting the O-360 installation was submitted to the FAA via the 337, there was nothing in the type certificate that said it could not be done.
Yes, someone wishing to install an 0-360 today could go to that current owner and hopefully get the paperwork that was submitted to the FAA to make a similar request for approval to the FAA. However the person at the local FSDO is almost certainly going to check the TC and read the notes ACA has added stating that 160 hp and 180 hp engine installations require the ACA metal spar wings.
Someone *might* be able to make a case that the Millman metal spars are equivalent. But it's a "maybe".
The larger issue is the FAA's current reluctance to approve 337s. The causes were three fold:
First, mechanics were submitting 337s for even minor alterations to cover their butts in response to over zealous FAA inspectors, which inundated the FAA with 337s to approve.
Second, owners and mechanics were using 337s to circumvent using approved STCs - basically using the data and procedures, but not paying for the STC.
Third, the bureaucrats in the FAA are risk averse and are not likely to approve a 337, when it falls short of what the current owner of the type certificate in its current revised form says is required. From the FAA perspective, there are also elements of the problem of circumventing STCs that are present as well. Yes ACA will charge about $30K for their metal wings, and that's outrageous for a Citabria without an engine that might be worth $20K as it sits and will need a $25K engine and $30K wings, and then may be worth $60K. However, the FAA will still look at it as circumventing ACA who did engineering and submitted data saying ACA metal wings are required.