I find this very interesting.
However there is a catch for departure, Clean if VRF +80 so when close to MAX TO Weight you will have at least 260, Normaly we call ATC and tell them about the speed for performance requirements, they always answer Approved
My question now is: Who is the "Administrator"? Does ATC qualify as the "Administrator" in the case you just mentioned?
The way I have understood this after discussing with other pilots and also considering the way it is written in the regulations, ATC does not qualify as "the Administrator" they refer to in 91.117 a).
Therefore, at least the way I understand it, they can not give authorization for not complying with 91.117 a) in the case you mentioned.
Lets have a look at 91.117 (b):
"Unless otherwise authorized or required
by ATC, no person may operate an aircraft at or below 2500 feet above the surface within 4 nautical miles of the primary airport of a Class C or Class D airspace area at an indicated airspeed of more than 200 knots (...)"
As you can see it is written differently from (a), as they here specifically state that ATC can authorize you to deviate from the regulation.
However, when it comes to the particular case you mentioned, it might still be legal under 91.117 (d) which says:
"If the minimum safe airspeed for any particular operation is greater than the maximum speed prescribed in this section, the aircraft may be operated at that minimum speed."
PS: in part 1 "Administrator" is defined as: "the Federal Aviation Administration or any person to whom he has delegated his authority in the matter concerned".
Someone please further enlighten me.