Actually, that's the problem I have with it. It's just too good. Why would someone give up their awesome magic implement just for a draw from the deck? Especially since it is labelled, oddly, as a Paragon level artifact, despite its base power being at least a level 25 item. Up until now, artifacts have generally been powerful, but at least reasonably tied to the tier in which they are intended for. This item would remain a solid choice at level 30 - having it potentially available at level 11 is a terrible call on WotC's end.
The actual elements of the deck itself? I'm a fan, in general. It seems like a good way to maintain the flavor without allowing it to unbalance things. And, as mentioned earlier - anyone who wants the more powerful version of the deck from past editions? Can pretty easily just port it over directly, if you already aren't concerned about the consequences.
While the idea to portray the deck as an implement is an interesting one, I think it was the one fatal flaw in this article. Having it as a Wondrous Item that encouraged drawing? Maybe allowed for a round of draws from the party before it vanished? That's cool.
Having it as a super-powered implement that discourages the bearer from ever drawing? Yeah, not a fan.