This only serves to allow firms to erect effort barriers to keep rent seeking fro their customers. The "gotcha" that the Khan FTC didn't "follow the rules making process" is parallel construction.
It doesn't seem that farfetched to me to imagine two sites offering equivalent services, one at $5/month and the other at $6/month, with the only difference being the $6/month site offers click to cancel. This dollar price difference is often the difference between the life and death of a company.
A harsher way of phrasing it would be this serves the consumer who actually pays attention to their bills. I've had a cheap gym membership sitting around for a few months that I haven't gone to. I don't want to go to the effort of cancelling it, because that's hard. My sloth subsidizes the gym goers who actually do use the service every day and pay less than they otherwise would for the privilege. Poor, lazy, stupid people like me should still be given the option to spend our money in poor, lazy, stupid ways.
Options provide value to the purchaser even when they are not exercised. It is a common but grave error to model options the same way one would model a simpler pay-per-usage style service for that reason. We might as well start telling people they can't buy monthly bus passes if they don't use them every day.