Can I compare the second segment climb gradient to TERPS climb requirements?

No. This is a common misconception. TERPS climb gradients:

• Are based on all-engines-operating conditions.
• Are not regulatory for OEI performance.
• Often ignore low, close-in obstacles.

In contrast, APG’s OEI runway analysis is based on AFM-certified data and FAA-required obstacle clearance standards (i.e., 35 ft net clearance within a defined corridor). These two systems serve different purposes and are not interchangeable.