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It would be interesting to find out if there was any science upon which the extra penalty was based. Seems like it is just an arbitrary design decision.
Think about the reasons surface intervals exist and you have your answer.
If a diver has come close to the model's NDL the diver is still decompressing while being at the surface. Right?
For example, in the op's 51 minute first dive a 40 minute tissue compartment would be close to 60% saturated. So in a 40 minute SI that compartment will go to half it's current level of saturation or 30% and it will take another 40 minutes to drop to 15%.
For a that tissue compartment to be able to spend another 60 minutes under water the diver either needs to do a mandatory deco stop or do an SI of over an hour+
I over simplified the math, but the principle is there.
So to answer your question, no it is not arbitrary.