and you establish a clear lateral separation from Ob
How exactly do you do this? Its not as simple as drawing a line down the centre of a valley….
Follow on question, what nav performance is your gnss operating to whilst you are executing this SID? and therefore, what protection area is applicable?
What terrain / obstacle information are you using? What obstacle clearance value is applicable?
IFR procedures can only be flown if they are extracted from a navigation database, they cannot be user defined or manipulated.
At a minimum, this is a breach of numerous parts of CASR,s 91, and 173. It touches on 175 and maybe 61….
Im very surprised that CASA couldn’t (or weren’t able to) answer your question. To be honest in the conditions you describe an IFR departure is not possible because it cannot be conducted legally