Each element is suposed to have it¡s own abilities, at least in cost (see Mindflayer, Bloodsucker, puffer fish, scarab...). Besides, this isn't even thematical. And I don't think the game needs another simple devouring creature.
Sorry for the bad rate, I hope I made myself clear.
EDIT: can't rate because it's in card art instead of in the CI&A board xD