It depends.
Accuracy for WP hops is empirical. That is, all of the calculations and assumptions are based on observations, not studies.Why? There simply is scant research on WP hopping. On top of that most of the research is on wort that's under 50 IBU and what's there shows that simple IBU calculations are not sufficient for the needs of modern craft brewing. Flavor development is still the art of the brewer.
You can assume at least 20% utilization for WP additions at the duration you've laid out. Most utilization happens in the first 20 to 30 minutes of exposure and even then, it's Cohumulone that isomerizes first. CoH is considered responsible for "coarseness" in bittering perception, but there are other contributors, as well.
Certainly, the quickness of Alpha Acid and Oil separation from the hop material is faster with pellets. So, that's a good reason to place their addition further down the process.
The main thing is consistency with your commercial batches. That may take a couple of batches to dial in. Once dialed, it'll be a piece of cake for you to know what to add and when, with any new recipe. In the meantime make a batch with all pellet hops at the same addition times. Compare that to the whole hop version and decide the appropriate adjustments.