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You should open a new RFE for your alternative solution. This RFE is implemented in 22.0.0.1.
I have an alternative view on this: Remove server.env completely in cloud environments and inject all of the environment variables you need into the JVM at runtime. This has served us well except for desktop environments. There, you need to specify the environment variables somehow and the tooling has no way to do this as there are no launch configurations to start Liberty. Our only alternative is to create a server.env and then DO NOT package it into the usr package for distribution. Perhaps the "server package" command can be enhanced for this?