It seems to me that this proposal creates a second kind of immutability in addition to the first kind of immutability that the language has with frozen objects.
Currently ArrayBuffer is one of a handful of cases where Object.freeze() does not actually prevent data structures from changing. The others (that I can think of) are Map, Set, WeakMap, and WeakSet.
I'm a bit unsettled that this proposal is on track to create a second definition of immutability that but without resolving the issues that would then require a third definition of immutability to be developed.
All this means that this proposal actively harms any future proposal to develop deep immutability, and that irks me since deep immutability is one of the most impactful wins that you can get out of having native support for immutability