I was dubious since Amulet of Transference costs Kiyoko to have in your possession (so you can't have spell pen from the amulet and Kitsune-Bi Kiyoko at the same time) and Tome Holster isn't obtainable (unless it actually is, in which case please correct me), but the new piece of gear I hadn't considered before is the new prone/stun immunity armor, which enables you to use the Channeler Stance at-will (20 spell pen) without being interrupted. With a juice and Wooden Rod and Blank Scroll in your weapon slots (30 spell pen vs Cloudforger 20) mostly replacing the 13 spell pen missing from the amulet+Tome Holster, you're at 141 spell pen, uninterruptible (unless silenced), and guaranteed to act after Kiyoko's turn 1 Entropic Fortune. Anything with 82 ward or less and no boss-specific one shot protection is deleted on the first turn.
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So with respect to both thinking there isn't enough penetration in the game for the new Black Mage perk to catch up to Eye for Weakness and gear not having a substantial role to play in closing the gap, I'm happy to say I was wrong. There will probably still be some fights where high ward/encounter specific damage caps favor Eye for Weakness (Reggie), but after ~3 years in the game mechanical wasteland Black Mage finally has a reason to exist late game.