
I think it is extremely specialized, because rarely would you want this instead of guts. Because you can't rely on drawing a willpower treachery, you need to find ways to make tests more frequently. Obviously, you then look to mystics for that.
Checking some deck building restrictions leads us eventually to Zoey and Rite of Seeking or Mists of R'lyeh. That definitely seems like a functional idea to me, depending on campaign and party make up. I particularly like Forgotten Age Zoey using mists (with Intrepid) to escape a vengeance enemy, moving to a new location, popping a Police Badge and then having 4 actions to use these increased stats (the badge gives you a +1 for mists as well, and if you had Xavier in play as well? Mmm-mmm!)
That's probably best case scenario, so depending on how hard it is to pull off that kind of combo probably determines if this card is playable at all. Would really like the power level of skill cards to be pushed in general.
This and Keen Eye lead me to believe that there could be a "power-turn guardian" deck that sets up to do massively effectual turns. Cards like Police Badge, Leo De Luca, and Double or Nothing all seem to fit that mold, so obviously someone like Zoey or Leo Anderson could pull this off. Intrepid becomes the least dependable part of that combo, however, because it has to lead off with a Willpower test, and on-demand willpower tests are hard to come by in-faction.