Your math is wrong it is less then that.
At 200% scaling you need 3 bonus dice to overtake the old system. 11 * 4.5 * 2 = 99 avg damage.
It looks a lot better at 200% scaling. But inquisitives builds are not all equal some will get more than 3 bonus dice while others won't have any so it's hard to say if it's "fair" or not.