wrote:

OK, I see what you mean, and I'll take your word for it. But the FAR
does state "departure procedure", and the ifr departure procedure
would thus seem to be included as a "departure procedure". The FAR
should be re worded!

Well, that is not in the IFR section of Part 91, and it applies only to
departures at airports with operating control towers. It's basically a noise
rule.

As to the regulation not making that clear, some of those regs are written
without regard to another meaning for a term. Plus, there is a legal
interpretation that muddies it even further.