OP's version of this card is amazingly strong.
Probably too strong.
First, you immunize a ship to blockers for 2 points. Not only can they now take an action even if they were blocked, but it's also conceivable to barrel roll out of contact with a ship that had been touching them and target.
Second, you make PS >12 for actions a thing. I'm not sure that's a solid choice of timing. True, it does relieve the current problem of tying the action-pass to the holder's PS, but...I'm thinking the main issue I have is both ships performing an action at the start of the combat phase. Very, very strong.