Doing damage comparisions is just missing the point: nearly every stat in this item is defensive, as this is clearly a labbing weapon and possibly the best one by a quite large margin too.
Naginata in labs is generally not amazing, no block, requires melee, little HP pool and one of Nagi's biggest strengths, "crowd control", becomes countered as early as t3. As you approach the higher labs and face lockdown, dying really is no longer an option. And as nagi main you probably know how difficult it is to build a large HP pool. Low HP pool (11-12k pre Pcloak buff) on melee range is just not viable, you'll get hitlocked to death.
ZKT has originally been the labber weapon (at least pre whirlpool buff) because you could main broadside and mostly play ranged. However it was never worth to transition from phys/Fryst to ZKT because the gear is too different and also more expensive, requiring stuff like great nats roll. Now you effectively have two well defined paths with SUs, phys with Fryst or ele ZKT into BI, depending what you're aiming to do: turbo fauzt farm (psn+fryst) or labbing.
Also, just because black ice works with IED doesn't mean you *have* to commit to IED when you are building it elemental. Black Ice, just like nagi, is meant to be highly versatile, and can be built in several ways; elemental (f,c,l,p) - cold (vit spam) - phys (larzuk).
Building it physical can offer some high amounts of EWD that nagi generally has little access to while also providing some nice survivability, but I wouldn't say phys is the main way to build it. Neither would be an IED setup, this probably becomes viable with insane vitality, kind of like a baby Azurewrath build. My fav way to build it is just to go rainbow, like oldschool waysin. I feel like people don't generally consider this option and focus on larzuk/ied shenanigans instead.
One of the "problems" with waysin has been lack of the cold element. Gear that provides all -pierce is generally expensive to obtain, and it just felt somewhat bad when using items like
Bad Mood
Bad Mood
Ring
Required Level: 100
Item Level: 120
-20% Cast Speed
Adds 50-100 Fire Damage
Adds 50-100 Lightning Damage
Adds 50-100 Cold Damage
-(5 to 20)% to Enemy Fire Resistance
-(5 to 20)% to Enemy Lightning Resistance
-(5 to 20)% to Enemy Cold Resistance
or
Quov Tsin's Talisman
Quov Tsin's Talisman
Amulet
Required Level: 110
Item Level: 110
15% Innate Elemental Damage
-(20 to 30)% to Enemy Elemental Resistances
. This item allows waysin to finally feel complete as you obtain the missing element to get the maximum benefit from pierce items.
Black Ice LoS keeps your sustain in check, meaning one of the best aspects about wdm, leech, you don't even need to care about with this. Waysin has traditionally never cared about WDM phys, it always used LoS combined with cb for phys dmg, but without trying to scale the phys, as waysin never had any sources of EWD. The point is,
you don't need phys to have good lab killspeed when using black ice.
Shifting all dex into vitality gives you decent cold damage, not as high as smaxed ways but a several thousand at least, which will be boosted by capped pierce you most likely already have when building rainbow. The only issue is attack rating, but both the enormous MO space, double MO effect and %allstat bonus help a lot to cover this aspect.
On top of this you will end up with a really happy HP pool, over 20k. Will the damage on paper be worse than Fryst? Likely, but in practice it's a lot better because you aren't dead.
Trivia: the inital idea was to name this item "Way of the Raven", to give a small hint as to how to build the item and to reference the once assassin ennead skill with that name. But it just sounded stupid.