I should think that as long as the charges put a fixed upper limit on the number of uses you have (not unlike our MP is for Flood/Edge), whether or not you beg for HoTs becomes a waste of raid DPS and source of overhealing provided that Drain (or any single-target variant) can largely repay that cost, but I can only speak from a theoretical standpoint.
"Particularly frequent" is a bit of a tricky statement though. Too long between uses and you could acquire multiple DAs before a single charge is spent, so we probably want to keep its CD and TBN's close together (or just scrap the idea of having DA subvert HP costs at all, returning to exactly what we have now).
Around a 30 sec CD and 2-3 charges ought to work I think? Assuming TBN is normalized due to not using MP anymore, the spender CD would be slightly longer than an on-demand but the additional charges will allow you to line up DAs for most of the encounter...
Alternately they could do something wild and make it so the cost paid to use DRK's HP-spending skills can only be repaid by DRK somehow, like putting a debuff on his max HP based on how much HP he paid, which he has to cleanse with his personal healing skills.
I would be for it. As I said before, they could recycle effects that exist as needed -- for instance, having Flood of Shadow/Darkness become the HP-consuming action and retain its Dark Arts interaction, or a lower-level holdover for (if we take the PvP inspiration to its most literal extent) Shadowbringer.I take it we're effectively removing Flood of Shadows, then?
But as far as making Abyssal Drain take Flood's current position as the AoE MP spender, I'm for it, and it's a functionally irrelevant distinction in raid content anyway.
What happens to Edge, if anything at all, is the slightly more important question for that. And again, none of the loop I've proposed has any consideration for the place of Blackblood skills.