According to my research on TS RemoteApp, each session will consume at least 40kb of bandwidth (not counting other types of network traffic. (same as what you have arrived in your experiment)
So, your 256kbps guaranteed is obviously the bottleneck if there are total 20 concurrent session (at least) at any given time.
To conclude, you need a network bandwidth of at least 2MB (SDSL) or you need to move the server to a data centre if you expect that all 40 users will start to use TS RemoteApp in near future.