Not the worst spec I've seen like that, but it has the same basic principal:
Take advantage of the state of IT's excessive threat to make a hacked half-spec so you can offer both buffs to your raid.
This one does win over the previous spec in that it will give you the tasty improved DS so you have something to do with FU pairs that is helpful, and you get DRM to get more ITs. The only things I would change are to push the points from RPM to Endless Winter, and possibly move the points from SoB into Dark Conviction, but that's a little more iffy (though with 3/3 in SoB it would support a high avoidance gear very well).
In general, I'm not a fan of halving the two trees because it sort of guts the synergies of each style, but it will certainly work just fine.
The one reason I would use this spec is if you have a regular 10-man with no MM Hunter, Enhancement Shaman (or Shaman at all really), or other DK, and you have a significant number of melee dpsers (read: more than the tanks plus 1-2). If that is you, then you can offer something nice to your group, if you have any of that you are trading for little.