Do the PRO tiers include PIM?
As a reference, I put together a full list of the four Entry divisions (which includes PIM) by ADP: click here
An interesting note is how much of a better understanding the PRO(s) have about goalie value & scarcity. The Entry divisions are a 15-team league, making goalies VERY scarce and yet they didn't fly at a 50% draft rate (and probably SHOULD have).
As a comparison of the difference between the Entry league & PRO... I was able to nab Bryz at 27 (14th in your league) & Varlamov at 57 (39th in your league).