This is undoubtedly why the developers start there and, in D&D, this is the right place to be. The problem is that DDO inflates a lot of things that would not be inflated were we playing at the kitchen table.
And this is the point that others are making about the DC being too low. It needs to scale upward to match the inflation in DDO or it becomes pointless in eElite content. If it won't work there at an acceptable reliability level then it becomes a worthless feat. And, if it is worthless, then the developers can stop working on it and never implement it because players won't take and use it.
This takes me back to an earlier point. Players of course want spells to work no fail. Developers should want the mobs to present a reasonable challenge. So, at eElite what is the expected success rate for these epic spells?
If it is 50/50 then the DC has to be low enough that a typical caster can get there. If 20 + attribute doesn't get there then 22 + half levels + attribute might be the better formula -- even though it isn't pure D&D it might be the better way for DDO.
Maybe that is even too weak, or maybe it is too strong. What are the DC formulas for spells that are landing on eElite now? What are the character's stats like? What feats/enhancements/gear are they using? What is the current success rate?
The answers are there in the game now. We just need some honest discussion about where the numbers ought to be and a good look at where they actually are for a typical character.