I know the OP was talking more about what the text said and not what the impacts on the target say. While I may not personally care for the comments either, I will address the target also.
As far as the target is concerned or any target for that matter, we must consider what is an acceptable hit zone for the target that we are facing. We must also consider the time in which we can deliver acceptable hits. We have all heard of speed and accuracy and this must apply here but first I will say that this is a horrible target for LE qualification. This target is almost as bad as the B27 which was status quo in LE for many years and still in use today. Both targets focus a shooter on a less than ideal hit zone when it comes to shot placement on a human torso.
Now if we ignore the shot placement topic, which is easily fixed by training and a more correct target, we really need to consider how quickly those hits occurred. I hate to say that distance is irrelevant, but it really is. We must look at #1 are those hits acceptable to be effective and #2 is the shooter able to effect those hits faster than the opponent, regardless of the distance?
As an example, if macsak and I were both able to be accurate enough to place a round on each others nose at any distance, who would win that fight? Obviously, whoever can deliver that shot faster. Now does macsak need to hit me right square on the tip of my nose to win? No he does not. Can he hit me in the eye (less accurate) but be a tenth or two faster and still get the job done? Yes, he can. This is balancing speed vs necessary accuracy. Of course a fast miss is still a miss and accuracy is King, however all the accuracy in the world matters little if the opponent can do it faster. Now of course this is purely hypothetical because we are both non-violent, rational adults but this helps to illustrate a point. Speed and accuracy applies no matter if it is IPSC or defensive shooting, however the emphasis may vary depending on the situation.
Again outside of placement being too low on that target, the group size would be acceptable provided time constraints of the qualification were met. Again we can easily adapt a shooter to select more ideal target areas, so the reality is that the target is not horrible by any stretch. It is actually more than acceptable given the variables.