How noticeable is clipping in MP3 and why can't LAME.exe forcefully apply gain regulation during encoding? "replaygain" option presumably does something to the tags but that doesn't work on generic equipment. Maybe the issue is underestimated and by using MP3Gain utility or scaling mp3 encoding down by 3db improves sound.
One could say that when you turn down volume, clipping problem doesn't matter but if volume regulation is done after decoding mp3 into wave, clipping still occurs.
To test this apply +12 gain on a file and then play it with volume turned down by 12db. In most cases you'll hear horrible clipping or huge limiting.