If you’re taking off from a non towered airport, there’s no takeoff minimums published and you’re trained part 135 for RVR 600, can you count the runway markings to equal RVR 600? I would normally say no because I don’t know of a regulation saying you can substitute RVR reporting for markings but I’m confused when I come across this.
If you haven't already seen this, the
DRS/FSIMS Volume 3, Chapter 18, Sections 3-6 covers all of the possible OpSpecs for a 135 operation and has guidance and requirements for the POIs as to how and what to approve. This is the stuff that your Director of Operations needs to know and do to satisfy the POI and get an OpSpec issued and/or modified.
It sounds like this is a somewhat rhetorical question based on the reference you posted, and I'm curious what that is from?
However, it is *possible* for a carrier to get an authorization for a procedure that allows pilot assessment of visibility. Details will be in your OpSpecs under C079 and in your FOM/GOM. It is required that the FOM/GOM contains an FAA-approved procedure for assessing visibility if RVR is unavailable, but what that procedure is, what your limitations are for using it, and the equipment requirements of the aircraft will all be specific to the carrier and contained in the manual if you've got the authorization for it under C079.
If there's any doubt about your specific carrier's authorizations after you look at it in your OpSpecs and FOM/GOM, it's worth a call to the Chief Pilot or DO to ask about it.
And if anyone is looking for someone to lead or join the leadership team of a 135 or 91 corporate flight department, please send me a DM...