Yowch. Draw replacement is a very harsh ability. I've seen it come up in Generator games before, and it's never pleasant. This way at least they get to see what the card is before choosing whether to pay.
It can definately stand with a drop in CC.
And it is expressly meant for a combo deck that runs Howling Mine type effects that force your opponent to draw extra cards. It is because that colour combo just felt right as it is a kind of pseudo-mill effect.
I am considering changing it to this:
"Whenever an opponent would draw a card, instead put the top 2 cards of that player's library into their graveyard unless that player loses 1 life";
This way they can either draw the card for 1 life OR get milled for 2. This would definately justify the in the cost.
Funny, actually, that, in a one on one match, unless you are playing a strange combo deck, or you're expecting your opponent to draw more than one card per turn, this card becomes worse than Onyx Goblet. I'd drop the card by . As it stands, this card might be okay at , but would require testing.
Also, have you thought about making this instead? Its technically a slow draining taxing card... it seems fine for that color combination as well. Punishing an opponent for drawing cards isn't really a blue thing, anyway, and you could get away with a more aggressive CC if the obvious color to combo it with isn't in the casting cost.
This is a clock. If you can get your opponent down to no cards in hand - which black can do somewhat easily - this is "lose 1 life or mill the top card of your library rather than drawing it" whenever they would draw a card. I played this in a deck with discard cards & Howling Mines or similar abilities to increase draws and it was quite useful.
Also note, Whilts Underworld Dreams is draw and take the damage, it is take damage which can be prevented unlike loss of life - which is a small point in this card's favour. I mean Circle of Protection: Black shuts down Underworld Dreams nicely but would be useless against this.
I have been playing with this quite a bit recently as its in the Red/Blue playtest deck. This can actually be a strong card. I have used it as most players would - to buy a little time BUT I have also used it in the alternative role I was thinking when I designed it. namely, targetting YOURSELF. Skipping a combat phase to have a double-shot the following turn has proven to be a very effective strategy especially later in the game when you have just played something on the largish size.
Yowch. Draw replacement is a very harsh ability. I've seen it come up in Generator games before, and it's never pleasant. This way at least they get to see what the card is before choosing whether to pay.
It can definately stand with a
drop in CC.
And it is expressly meant for a combo deck that runs Howling Mine type effects that force your opponent to draw extra cards. It is 
because that colour combo just felt right as it is a kind of pseudo-mill effect.
I am considering changing it to this:
"Whenever an opponent would draw a card, instead put the top 2 cards of that player's library into their graveyard unless that player loses 1 life"; This way they can either draw the card for 1 life OR get milled for 2. This would definately justify the
in the cost.
Funny, actually, that, in a one on one match, unless you are playing a strange combo deck, or you're expecting your opponent to draw more than one card per turn, this card becomes worse than Onyx Goblet. I'd drop the card by
. As it stands, this card might be okay at 
, but would require testing.
Also, have you thought about making this
instead? Its technically a slow draining taxing card... it seems fine for that color combination as well. Punishing an opponent for drawing cards isn't really a blue thing, anyway, and you could get away with a more aggressive CC if the obvious color to combo it with isn't in the casting cost.
This is a clock. If you can get your opponent down to no cards in hand - which black can do somewhat easily - this is "lose 1 life or mill the top card of your library rather than drawing it" whenever they would draw a card. I played this in a deck with discard cards & Howling Mines or similar abilities to increase draws and it was quite useful.
Also note, Whilts Underworld Dreams is draw and take the damage, it is take damage which can be prevented unlike loss of life - which is a small point in this card's favour. I mean Circle of Protection: Black shuts down Underworld Dreams nicely but would be useless against this.
Given the strength this has shown to have, I may drop the cantrip part.
I have been playing with this quite a bit recently as its in the Red/Blue playtest deck. This can actually be a strong card. I have used it as most players would - to buy a little time BUT I have also used it in the alternative role I was thinking when I designed it. namely, targetting YOURSELF. Skipping a combat phase to have a double-shot the following turn has proven to be a very effective strategy especially later in the game when you have just played something on the largish size.