If you weigh165 lbs's and your exposure suit is a3mm wet suit and your air tank is made out ofsteel and you're diving in salt water,
then you'll need approximately15lbs (+/- 2kg)of weights.
To answer your question, I'd say it's not even remotely close. If I use an Aluminum Backplate with a steel 100 in this configuration, I don't need any weight. Your formula don't take into account body fat vs muscle mass... All of that aside, I wouldn't comfortably recommend to a student in a jacket BCD with a 3mm wet suit (which has foam and is buoyant) with an Aluminum tank to wear 15lbs of weight... 12 Lbs maybe as a starting point? But with Steel, probably not.