In the Part 25 world (or my part of it) it means the maximum demonstrated using the recommended technique - the technique we recommend is the one we (have to) use for the certification demonstration - as indeed is the case for all the procedures. We're not allowed (supposed) to use one procedure to demonstrate a compliance item, then recommend line pilots do something else. (This would apply to, for example, field performance data - if we stood on the brakes to get max braking, we have to include that in the procedures as well, at least so you know how to get our numbers when you need them)