My point is, if you don't reach an aerodynamic or structural limit, instead you just demonstrate it can reach a limit sufficient for certification, as far as the operator is concerned isn't that the same as all limits?
For the R22, apparently it's been demonstrated to 17kts. That might also be an aerodynamic limit (probably not, but according to flight test information we have right now it could be). Or you won't reach that until 18, 20, 30, or 80 knots. Who knows? When you only have what is demonstrated, that is all you know it is good for. That IS a limit.