So what's the point of having 220kts published as a maximum in the hold?
Dunno, but it's a bit daft if it involves min clean plus to the hold, flaps out whilst holding and then flaps back in for the first part of the intermediate approach.
220kts to 230kts isn't going to be an issue in the hold anyway and I'd have thought the FMS could be tweaked to adjust turns and timings if required. Anyone that asks if they can hold above 220kts always gets an affirm in my experience anyway.