Agreed to all posts here, but i'll add.
The substrate will have an insulating effect on the heater. It will cause the heater's thermostat to respond to the temperature up against the heater body because of the low circulation rate of water around it and the insulating effect.
This means that your heater will short cycle, causing ineffective heating and possibly premature heater failure from the thermostat cycling at much higher rates than you'd normally find.
You'll note that undergravel heater cables have their heating unit (the cable in this case) spread out over a much larger area to distribute the heat that is normally distributed by water movement with a normal heater, and that their thermostat is mounted on a separate cable, so it is checking the temperature of the water column, not of the hotter areas right next to the cable.
Finally, the heater will be hard to adjust if buried.
You can mitigate this by using a Via Aqua or Won heater that has a remote thermostat probe and adjustment, but all the difficulty in maintenance will still be a problem, plus the insulating effect will cause ineffective heating regardless. IMO it's not worth the trouble.