Bad moves
1. Your hp does not drain fast at 65 because of SoS, one of our best dots is SK which heals us for 150 a tick (200 dmg a tick).
2. MC3 should be one of your last AAs because of how expensive it gets and how little it gives, SoS gives 50 mana a tick, FS gives 2, and if you're grouping you might have bst crack, bards songs, 9, etc. Grouped I consider 90 mana a tick to be ok mana regen. That said in a group I probably have blessing of replenishment, 9, symbol, and bst crack which means I'm losing 0 hp a tick... and even then I'm casting SK.
So in response to the path you're suggesting I'd say thats pretty unwise.
The AA path I would suggest now is run 3 at 55ish (use sow potions even with run 3) ideally you'd get your run 3 AAs from raids, then get level 64 for Seduction (65 is mostly worthless unless you can afford blood of thule and child of bert), then solo vxed for 14% AA XP a kill to buy 9th spell slot, regen 3 (needed for scm3), SCM3, then your utility AAs (suspend minion, pet hold, conjure corpse, flesh to bone), then your fun but mostly useless AAs (WTD, SoD, etc), then your "I want to dual weild envy and woe and pretend I'm a warrior" (casting fear I can hold aggro better) type of AAs. Might also be wise to charge all the way to lvl 67 to get PG groups and not stop till 70, up to you althought its probably the best path.
The truth is until you get 10k hp you're not going to be tanking, ND3 gives a 10% hp bonus and since I'm assuming you're not using uber nodrop gear you'd get about 200hp out of it. Do the math 200 hp for 12 AAs = 16.6 hp per AA. At 65 you're kiting mobs that quad for 1k, for 12 AA would you prefer 30% mana reduction on spells or 1/20 of a quad's damage added to your hp? If you are intending to tank defensive AAs would be wiser.