True, it was designed to counter Akebono (1-0, EM so far).
Did some testing, and here is the my new card-limited list:
Hover over cards for details, click for permalink
5io 5io 6ts 6ts 6ts 6ts 6ts 6ts 6ts 6ve 6ve 7gk 7h0 7h0 7hi 7i6 7t8 7t9 7tb 7tc 7um 7um 7um 7um 7um 7um 7um 7um 7um 7um 8pp
And here is how it would work with all upped cards:
Hover over cards for details, click for permalink
6ts 6ts 6ts 6ts 6ts 6ts 6ts 6ve 6ve 7gk 7h8 7h8 7h8 7h8 7hi 7i6 7t8 7t9 7tb 7tc 7um 7um 7um 7um 7um 7um 7um 7um 7um 7um 8pp
I noticed that i most of time use Nymph's Tears on Water Pillars/Pends anyway, so using nymphs instead might be good idea. Sadly, i don't have 10 water nymphs, just two.
It's quite slow, can be outrushed, but it's great for EM AI4 (and really fun to play).