When would you use EF though?
Don't you need all the holy powers to keep SoTR up instead?
I have seen you ask this or make similar comments several times and every single time you have been told the same thing: EF IS WORTH THE HOLY POWER.
You use it when it's just about to fall off, which is every 30 seconds, exactly the same as SS. The only additional thing to consider when using it that you didn't need to do with SS is you want to make sure that you always use EF with 3 holy power.
Obviously if the boss is about to use a big hitting ability you'd want to use SotR instead, but in general refreshing EF should take priority. Plus, you *should
* be banking yourself up to 5hp before using either ability anyways, so that you have the 2 extra hp onhand for emergencies. Which means that in a situation where EF has fallen off and a big boss ability is coming up you can use EF, leaving yourself with 2hp left, hit CS/J to generate a 3rd and follow it up with SotR (see why banking to 5hp is so useful?), though in that situation you may want to reverse their usage, getting SotR up first to make sure it's up before the hit and then EF afterwards where the base heal will help with the damage you took.
And once you have the 4p then the holy power question doesn't even make sense as EF becomes completely FREE.