While studying of FAA's Instrument Procedures Handbook, I noticed that on page 1-16 (Chapter 1: Departure Procedures) it defines the Initial Climb Area (ICA) as follows:
The ICA is the segment of the departure procedure that starts at the DER and proceeds along the runway centerline extended to allow the aircraft sufficient distance to reach an altitude of 400 feet above DER elevation and to allow the establishment of positive course guidance by all navigation systems. A typical straight departure ICA extends 2-5 NM from the DER along the runway centerline extended. It is 500 feet wide each side of the runway centerline at DER, then spreads out at 15°
However, I can not understand how it is possible for the ICA to extend more than 2 nautical miles, since the maximum horizontal distance covered by an aircraft until it reaches an altitude of 400 feet above DER elevation can be found by using the default minimum climb gradient of 200 feet/NM, which corresponds to 2 nautical miles. For an ICA to extend more than 2 nautical miles, a climb gradient of less than 200 feet/NM would be required, something that violates the rules imposed by FAA.
Could someone point me in the right direction?