20 km/hr is pretty choppy and might produce some white caps if the lake is large, or oriented along the direction of the wind.
In a small tinner - that's about it (if there are no protected bays available).
At 40km/hr - big boats (fishing boats 18-20 ft) can be put into a precarious position quite quickly. That can produce some very serious waves.
Even in a bigger fishing boat - after 20 km/hr it's hard to steer and stay on track, hard to keep your anchor fixed and just a plain pain in the butt to be out there sometimes.
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