I think you're wrong. The amount of power I'm using to maintain the batteries at a "warm" temperature isn't much. The charging time lost to having to first heat the batteries could be significant. A battery at 0 F takes a long time to come up above 32 F. While it's warming, you may be trying to use power from the battery, further depleting the charge. In the winter you have limited sun exposure (less time and less insulation) so you have to be as efficient with that as you can.
Yes, but you do not want to charge when you are below freezing, anyway, right? So, if your pack is frozen, and your bms has shut off charging, then you are not losing charging. You MUST raise the temp above freezing before you can charge. That does raise the question, however, does that bms heat the pack when the sun doesn't shine? At night? I don't let my pack freeze. If it looks like cold weather, I keep my pack warm all night. I use a seedling heater that runs off my inverter. I only connect it to power when there is a possibility of freeze, and I am near Houston, Tx, so I only use mine on rare occasions, but it does not draw much juice when it is idle.
One further point: In winter, it's true there's less sunlight, however, cold solar panels work much better than hot ones. You get epic power boosts in cold weather
Edited to add: I just reread your comment, and I see we are actually of the same mind. Better to keep the pack warm and functioning properly, than to allow it to freeze overnight, then try to rewarm it. . The bms is, as intended, a Fail-safe. This implies that your bank stores enough power to do heat constantly. Mine does. This also implies that you have two heat pads. One for 'maintenance' and one as a 'last-ditch effort'.
I suppose, in off-grid, occasional use cabins, etc, it would be better to let this bms function unattended, than to leave a heater running full time, and potentially drain your battery. In an occasional-use scenario, losing a few hours of charging would be a non-issue.