Haaaaang on.. I know it doesn't strictly apply to 3.184 but from
AC 23-19A - Airframe Guide for Certification of Part 23 Airplanes p.26-27
46. Why would I want to define VC as equal to 0.9 VH? Use this definition if you are designing an airplane that is capable of a sustained speed (VC) higher than that obtained by using the wing loading (W/S) formula.
So The PA-28-181 Archer III does not seem to be compliant with Vc min regs, it looks be 7MPH short. Other PA-28s Cessnas etc. appear OK but not the Archer III:
Vc min for 15lbs/sq.ft wing loading =
147mph CAS
PA-28-181 Vno =
140mph CAS
§ 3.740 Maximum structural cruising speed
(Vno). This operating limitation shall be:
(a) Not greater than Vc chosen in accordance with § 3.184.
(b) Not greater than 0.89 times Vne established under § 3.739.
(c) Not less than the minimum Vc permitted in § 3.184