If a 3rd Tier was to come in, and you were hoping to bring in regional teams, you will probably need a way to start grading academies. You cant have so many 'elite' academies, and you have to be weary to diluting LOI underage. If you are expanding LOI to new clubs, there probably needs to be a new stream of a underage competition (lets say an LOI B), rather than just expanding the current set-up.
Might help the gap between established LOI set-ups and new teams wanting to enter LOI.