The way I read it, tracer simply wants reference to a 135 regulation that allows an aircraft to depart a runway and maintain your own obstruction clearance (ie 'see and avoid') rather than fly the published ODP.
I would agree that performing a visual climb over the airport (even if not published) might be one way of maintaining obstruction clearance on your own. But I also suggest that you can fly your own departure path and accomplish the same, as long as you request and receive a clearance to do so.