I can't see it being a step too low when you have people like Deli Alli smashing it, it can work but if the managers aren't honest with each other then you automatically have an inefficient loan system. It's up to the clubs and managers to protect their "assets"
Delli Alli is a pretty special case though - no doubting his quality, but a player like that comes along very rarely.
There must be 100's of players in the U21's and lower that would be decent EPL players if they get the right imputus early in their career but it stalls before it even gets going because they dont get matches
Either way something has to change soon in regards to the England setup in general otherwise the International side is going to waste the likes of Kane / Alli and who ever else appears just as much as they wasted Scholes/ Lampard / Gerrard and to a certain extent Rooney