A major part of the game is the spatial element, which functionally works much better with board + tiles than with cards... was you plan to eschew the spatial element altogether? Seems like it would neuter the game.
Yes, It would lose the spatial element. And no, I would not miss it.
And about neutering the game this way - card versions of board games are always a simplification, therefore I would not miss that what would be lost. In any way, this game would last fart shorter than the original Reef Encounter and there would be less Analysis paralysis in it.
The only question still remains if it is not too similar to any card game out there already.