Huh. reminds me of my own Spring card, but only Gravity. the problem i see is that you have unlimited momentums for the same cost than the card itself. I'm thinking in the basis of Arctic Squid. while Feeze costs 1 quanta, the ability costs 3. that for a rather fragile card. now consider that with a permanent? the ability cost should be at least 3, if not more. the card cost should then get lowered to something like 5, however, otherwise it'd get way to costy.
I'd do a round-by-round showy thingy, but i can't do it well.