Navy Seals use a SAC rate of 2.5 and can't keep it going for that long. It is a ridiculously high rate for the working portion of a dive, and I mean really working your buns off. That isn't going to happen on a simple, NDL rec dive. The only way a SAC rate would get that high would be a full blown CO2 hit. That is also not gonna happen on a simple, NDL rec dive. And forget about taking a few minutes to solve a problem at depth. That is certainly not on the mind of the average rec diver once he has bailed out to his pony bottle.
And even if all this were not ludicrous, going from 110 feet to 20 feet at 30 fpm would take 3 minutes at an average depth of about 66 feet. So that's 3 ATA for 3 minutes at 2.0 SAC, or 18 cf. Then tack on a lower SAC of 1.0 for 3 minutes at 20 feet for an additional 4.8 cf. And before you start questioning the assumptions, answer these questions.
1. Why would you ascend at only 30 fpm if it was an emergency instead of the accepted 60 fpm? And yes, I would do it despite my PFO.
2. Why would you even stop at 20 feet for 3 minutes if you are still huffing and puffing at 2.0? Although you probably would have passed out by that time.
3. Why would you even think the ascent would be at a SAC of 2.0 if that is the rate of the working portion of a commercial dive?
I can do the calculations. Based on any realistic scenario, a 40 cf pony bottle is overkill. A 40 cf stage bottle or deco bottle or bailout bottle is a different animal. The OP was asking about getting a reg for his 19 cf pony bottle for recreational diving. The thread has taken many different turns since then.