Sorry, I was looking at Part B, normal takeoff procedure which says accelerate and retract flap at 1500'. This does not conflict with the Part A policy of not below 400' for any type.
But since you've spent 377 posts advocating retracting the flaps as soon as the speed reaches V2+20
regardless of height I'll take that as you agreeing that height is a factor.
I think your reading of the NADP's is a bit creative. From DOC8168:
3.3 The initial climbing speed to the noise abatement initiation point is V2 + 20 to 40 km/h (10 to 20 kt).
3.4 On reaching an altitude equivalent to at least 240 m (800 ft) above aerodrome elevation, decrease aircraft
body angle/angle of pitch while maintaining a positive rate of climb, accelerate towards Vzf and either:
a) reduce power with the initiation of the first flap/slat retraction; or
h) reduce power after flap/slat retraction
To be read in conjunction with:
k) The maximum acceptable body angle specified for an aeroplane type shall not be exceeded.
This is for an NADP 2, that has the lowest flap retraction height specificed. NADP1 says reduce thrust and keep climbing with flap to 3000' Also the speed for NADP1 is just "not less than V2+20km/h (10kt)". So I'm not sure how you conclude that V2+20 is not reached until 3000'
And I don't see how whipping the flaps up as soon as the speed reaches V2+20 at 2-300 feet is even remotely compliant.
But regardless of that, you have agreed that your procedure doesn't comply with your Ops Manual, therefore you can't do it. End of story.