Not really, he's teleported a strapped helmet off of a man's head before, and then teleported several times right after that, it didn't drain him at all. That's how much fine control he has. True if he carries too much weight he'll faint, but most of the heavy animals BB could change in to would be to slow to do anything to Kurt. And a simple teleport blitz could end the whole fight in seconds. I can't remember exactly where, but one version of nightcrawler who was similar to Dark Beast, was known for teleporting appendages off of his enemies and victims.