I agree with Caveman and Enigma. If you do not have the data available to you, in the cockpit, don't do it.
What you "think" is safe may very well be safe, but you have to be able to "prove" it. You can't do that without "approved" data. All those pages of takeoff performance data in the AFM are essentially useless. You as a pilot cannot calculate obstruction clearance with any degree of accuracy. It is not possible. Why? Because you do NOT know where the "obstructions" are and you have NO MEANS of making that determination.
With respect to the "engineering department", most small alirlines and many large airlines simply do NOT have the in house capability of generating accurate runway analysis charts. That's why they a purchased externally. Don't take anybody's word for it, no matter who they are and yes, that includes the POI. That dude doesn't know a bit more than you do, he simply has a badge. Either you have the approved data or you don't. It's that simple.
Operation without supporting data is not legal, period. That applies to everything, not just intersection departures. You can't land on a runway 3 times as long if your have no data for that runway. You can't "hold short" of an intersection if you have no data (one of the reasons LASHO was thrown out). You can't divert to an airport if you have no data for that airport. You can't run a "charter" to an airport that is not in your analysis book, unless you get the data before you depart. You can't operate with the "gear down", even if you have a "ferry permit" unless you have the data for gear down operations. You can't pull and reset circuit breakers, even when maintenance control tells you to do so on the phone, unless you have an "approved" procedure for that particular CB. You can't use airports or minima that are not in your Ops Specs. Etc., etc., etc. It's all a part of the same basic principle, i.e., you, as Captain, always have to be able to prove that whatever you did, was by the book. If there is no "book", don't do it. Your "ticket" is your only asset; protect it. The life you save may well be your own.
Intersection takeoffs are for the "convenience" ot the Tower. Do not facilitate "their convenience" by risking "your license". It ain't worth it.
Don't forget the "catch all regulation" buried in Part 91. The "careless & reckless" gambit. It is totally subjective but turst me, you don't want to put yourself in the position of having to prove a negative.
Finally, remember this very old axiom: "The runway behind you and the altitude above you are both useless."
What you "think" is safe may very well be safe, but you have to be able to "prove" it. You can't do that without "approved" data. All those pages of takeoff performance data in the AFM are essentially useless. You as a pilot cannot calculate obstruction clearance with any degree of accuracy. It is not possible. Why? Because you do NOT know where the "obstructions" are and you have NO MEANS of making that determination.
With respect to the "engineering department", most small alirlines and many large airlines simply do NOT have the in house capability of generating accurate runway analysis charts. That's why they a purchased externally. Don't take anybody's word for it, no matter who they are and yes, that includes the POI. That dude doesn't know a bit more than you do, he simply has a badge. Either you have the approved data or you don't. It's that simple.
Operation without supporting data is not legal, period. That applies to everything, not just intersection departures. You can't land on a runway 3 times as long if your have no data for that runway. You can't "hold short" of an intersection if you have no data (one of the reasons LASHO was thrown out). You can't divert to an airport if you have no data for that airport. You can't run a "charter" to an airport that is not in your analysis book, unless you get the data before you depart. You can't operate with the "gear down", even if you have a "ferry permit" unless you have the data for gear down operations. You can't pull and reset circuit breakers, even when maintenance control tells you to do so on the phone, unless you have an "approved" procedure for that particular CB. You can't use airports or minima that are not in your Ops Specs. Etc., etc., etc. It's all a part of the same basic principle, i.e., you, as Captain, always have to be able to prove that whatever you did, was by the book. If there is no "book", don't do it. Your "ticket" is your only asset; protect it. The life you save may well be your own.
Intersection takeoffs are for the "convenience" ot the Tower. Do not facilitate "their convenience" by risking "your license". It ain't worth it.
Don't forget the "catch all regulation" buried in Part 91. The "careless & reckless" gambit. It is totally subjective but turst me, you don't want to put yourself in the position of having to prove a negative.
Finally, remember this very old axiom: "The runway behind you and the altitude above you are both useless."