In 2010, giving him the benefit of the doubt over Favre, I had him objectively ranked at 15, given everyone's relative resources, and defenses. Actually Cassel, Schaub and certainly Flacco did more with as much or less, and with at least as stiff a level of competition within their divisions. And that was a 1 year anomaly as he lived up, or down to being a statistical bottom 6 feeder each of the other 3 years and from a career perspective. I was being generous if anything; ain't no way I was being overly critical or even viewing it through anything other than coke bottle-thick green lenses did Buttchez even sniff the top dozen QBs in '10.
I'd go with 16-20 myself.