The effort to implement OpenVG 1.0 and OpenVG1.1

Dear all,
Now we want to implement the OpenVG (1.0 or 1.1) on a SoC in C. The proposed effort estimation is as follows:
OpenVG1.0 from zero:
Line of Code: 25 - 30k
Development: 16 staff-month.
Conformance test to get the logo: 4 staff-month

OpenVG1.1 from zero:
Line of Code: 30k - 35k
Development: 20 staff-month
Conformance test to get the logo: 5 staff-month

Is it reasonable? Thanks a lot!

Any comments or suggestions on that?