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Always choose the maximum bitrate that will fit. If it doesn't fit, lower the bitrate until it does. Nothing you can do about the quality at that point anyway.
It is a matter of business economics. I currently charge $900 for a Blu-ray release upgrade from DVD. That reflects a major compute effort that it still requires using an Intel quad-core machine assuming 25mbps, 2-pass bitrates. However, if I can transcode out at 10mbps without loss of quality, the compute times drop radically and I can then lower my price radically.
From what I have seen so far 10mbps is doable but I wanted to see what input others had to say on this.
That will likely depend a great deal on the content. You may find even within your own projects that bitrates which work for one aren't sufficient for another.
Because encoding times are such variables, I myself never price anything based on that, instead leaving such things for nighttime when I go home and work will not be affected.