I wouldn't argue but I would debate whether his form should give him an unsubstitutable starting place.!
It depends on what system you want to play with really. He should clearly be in the squad. To suggest otherwise, to me, strikes me as a bit of Evertonian bias or something. There have been threads on this before, but personally, I would go for something like:
Johnson Someone Ferdinand Cole
Play a similar system to Barcelona. Expansive full-backs, three ball-retaining central midfielders and the pace and purpose of Walcott and Lennon to provide Rooney with some support. It seems to be the most efficient system England could possibly play as it would probably be one of the few formations that can get the best out of both Lampard and Gerrard, and it would give us some much needed pace, energy and width.
Then, you have three central midfielders to play with. I suppose you could have Barry, Carrick and Lampard with Gerrard on the bench but I'd much prefer Gerrard over Carrick. Let's be honest, Carrick hasn't had a good season either. So if you're dropping Gerrard from the first team, who plays instead?