Unless the Pack Hounds become available to every player, this isn't a viable counter.
So, it should be possible to equip a counter to a counter?
AFAIK, that the beauty of having the pack hounds (or would have been if they did good damage, which might now happen). Same, all power specific modules should have strengths and weaknesses as compared to regular weapons.
I think the original idea was that if you have a counter it makes you have to worry less about something being used against you. In return, you have to sacrifice something. You can have 4 shield boosters on an Asp if you want at least one PDT, something has to give.
Perhaps the PDT could be made to be a little less efficient, it does seem to have a 100% success rate. The ECM could be made a bit easier to use as well, the hold and charge idea is a tricky one to deal with. When do you release? Why not just get a PDT which requires no effort?
Anyway, will be nice to see the PDT and possibly the ECM being worth bothering with again.