Can the new Essence Reaver be an Active item?

Its an item marketed for "Spellslinging" marksmen,but the problem is,its too situational and its harder to pull of properly than it appears at first glance,its not only tied to your ultimate cd,but it also has an internal cd of 30 secons.

If you have a 100 second CD ult and its down,its now an useless passive

If you want to poke with your ult like Kog but save the item for a team fight,tough luck

If you use your ult to disengage rather than nuke with Xayah you're more than likely wasting the active

If you kill someone with your ult then again you've wasted your proc that could have been used for your next engagement where your ult is down and you need that extra power

If you're most ADCs would be a terrible first or second choice of an item,and i'd even say that there's no reason to buy it anytime over something like LDR,GA,Lifesteal... I'd rather have all 3 of those and just IE RFC than to trade any of that for some cdr,mana and an active i'll more than likely waste.

The best solution i think would be changing it so it becomes an active item,so we can more freely decide when to use it,since not every ult is an all in,not every ult is instant cast and not every ult is used for engaging.

Thoughts?