I think technically this being at the bottom works but being in the footer does make using the datalayer much more complicated. The values aren't available for early hooks meaning if you're trying to pass them to something like the page view event they aren't available.
Additionally, since they only push the values on, not triggering any events, there isn't a way to trigger pushing any values into a tag.
It seems like it would cause fewer problems for developers if it was in the header somewhere. even better if it could go before tag manager.
https://www.drupal.org/project/datalayer/issues/3396490#comment-15727184