Would it make more sense to instead target the patterns used by predatory commentators rather than shutting down the system completely? This is Google, the company of bringing meaning out of arbitrary data, is it not possible to build social graphs of what people like, scour, and activate these time codes? Couldn't you restrict the features that enforce those patterns?
Lastly, does forcing these comments off negatively impact the rankings of these creators? Comments have traditionally played into the engagement of any said video and had an (understood) impact on how a video ranks on release. Are these channels now just permanently stunted in their future growth?