That could work, but he's a pretty big character in the books, so IMO it would really be best if he could be worked into the (theoretical) comics. But apparently he's already appeared in a comic, so I guess he's not an issue.
Now would it be possible to just get the rights to one element of a series without getting the whole thing. Like for instance say a comic writer wanted to do a flashback involving Johnathan Archer or T'Pol, would it be possible to get permission to use just them?
From what the IDW editors have said before I'd say a significant Enterprise flashback would be a no: The cameos, such as Tuvok and Seven in The Last Generation were allowed because they were minor easter eggs rather than major characters in the series. I think Andrew Steven Harris mentioned before that he was allowed to use Seven because he didn't do so in a big way, and she was always Annika in that reality, so even the recognisability of here name was a factor. (And was Tuvok being established as part of Sulu's crew the excuse he needed to use Tuvok in the series? - I half remember that)
It has also been previously confirmed by IDW editors that a Titan comic could happen, because Titan is definitely covered by the TNG license.
Even if Tuvok on his own became an issue with that licensing, would it really be that hard to do a story in which the Titan's tactical officer plays a minimal role? Reducing him to cameo appearances for Titan comics?
But, CBS seem to have been pretty liberal with the licenses for IDW so far anyway. We've had a (one panel) Phlox flashback, a Columbia shuttlepod, Rigelians from Enterprise, heavy influences from Enterprise Andorians in the Andorian Alien Spotlight, Janeway and Species 8472 in the Borg one, etc etc