This commander accentuates the already slow and dull aspects of the Brits faction while being quite powerful.
Emplacements are so resilient and there is such a large risk with trying to destroying them early - to mid or even late game that matches grind to a halt, becoming static, losing all drama and action.
An axis player will generally have to avoid the emplacements until medium armour is out, all infantry based IDF is countered (without effort) by the counter-arty commander ability.
Even with two mortar HTs dropping flame rounds (10+ flame rounds) emplacements survive with brace, and some repairs.
The biggest issue as I said is that this commander accentuates Brits already defensive play style while increasing passive and static aspects of their play.