Perhaps I'll try it w/o SFTF as the primary thing, starting Faramir, COU is a good idea. I don't know what RB to run instead, though. Maybe Boromir, or even Frodo.
If I were to cut Hearts Raised, I'd need different threat removal. Maybe Citadel to Gate would be a good alternative, as Barliman can recur it.
The main problem I foresee now is cycling and not getting cards fast enough.
I honestly don't think you need threat removal. I'd cut
Faramir's Company as well, I don't think it's efficient enough, it just converts one resource to another at a 1:1 ratio (threat to vitality).
Citadel to Gate is way better if you are dead set on needing threat removal.
Try
Poor Creature for cycling, it's great, I run it in my gondor control deck and works wonders really. Or if you switch RB to Frodo you can run
Robin Smallburrow (very underrated card imo), but if you do that Sothron Leader will always be an issue (and to a lesser extent
Chief Counselor, but I don't really see people besides myself running it).
Leowyn is another great cycler and source of healing too, combined with
Weland, it can heal Gandalf too, but that's probably a stretch.
Also having some discard outlet in the shadow side besides Old Villian is nice. I really like
Winged Mount in expanded for example, 2-3 copies are reasonable in any build with
Dark Horseman and stuff.
I'd keep an eye in games on what I usually pull with
Sudden Strike (I may debate who is the inventor of
Sudden Strike, but at the very least I'd say I'm a co-inventor haha, we used to play a LOT with Draino and both developed our versions in the process). If you never want some minions (looking at the likes of
GATS, Sauron, Gothmog, Dunlanding Warrior and Mauhur), then you should probably cut them. Such a tall deck can definitely see more Nelya for example. I think
Sudden Strike works way better in a more focused shadow list that pulls some really hard hitting silver bullets when needed. Like I play it with corsairs, 2 version of nazgul and
Ugly Fellow +
Ugluk's Sword shadows that all have a clear focus, and
Sudden Strike adds specific counters. Stuff I usually pull are: Nelya, Grima,
Demon of Might,
Southron Leader, shotgun Enquaea, Her Ladysip - OR - something that supplements my core strategy. Sauron is very rarely better than
Demon of Might, to a point where I would always play 2nd Balrog befor 1st Sauron. Gothmog without an archery strategy just lets 3 wounds to be spread to
Mithlond away on the next move.
GATS without
Pavise is inefficient and vulnerable. In certain niche cases, sure they are handy, but I think it's better to focus on trying to beat the really tough decks of the format, than roflstomping the less well prepared ones even harder.
Evil-Smelling Fens also gets way better in a more focused list, especially with
Her Sneak and
Plotting Deceiver.