B2N2
The more significant quote from that
NBAA advice would have been
In order to remain in protected airspace, it is still recommended – but no longer required – that pilots use the next higher approach category if possible, Boll explained.
In other words, the obstacles don't care if a jet is certified as Cat C or D.
If a pilot needs to circle at speeds above 140 KIAS for whatever reason - configuration, icing, a jammed stab, turbulence, whatever - s/he would be wise to respect the Cat D line of minima.