Actually it is, considering that you can use spells out of combat as a tool for solving quests. I crushed a door, for instance, using my spells.
Yeah, true. it also could be a problem for the Talking Statues.
All I can think of to deal with that though is that resting in an official rest place will clear the cooldowns. That doesn't solve the problem of being able to bypass cooldowns by resting, but since Elwyn's system has the cooldowns carry over between turns - instead of lasting for ages and ages, there's less motivation to go back to someplace and rest... unless you're expecting a boss encounter, which is exactly the right time that you SHOULD be encouraged to go back and rest.
EDIT: Oh! And of course you can only rest every so often. Even Divine Divinity had a system to keep you from resting too much, and exploiting rest's ability to fully heal you. I think 6 in-game hours should be enough time between rests.
