Yes -- and, tactically, no.
What the heck does Chris mean?
In net average damage dispensed, which is probably the most important evaluation, you are correct -- 3 AD is nastier. It's actually even more important when you consider interceptor effects (as the game currently stands today).
But the crit mechanism right now provides a Gank dimension. Sure, that Rohric will only probably do 15 damage this turn. But, it can, with reasonable luck, perhaps generate say, 50-60 if it hits one of the two superyahtzee crits occurs. Does possibility affect what order its opponent fires ships in? Often it does, and it should. With the mechanism cited, the maximum reach threshold is lowered.
As to katadder's point --- I wholeheartedly agree. I have Chicago-area players who have almost dropped the game because they think Critical effects happen far TOO often. For one-weapon arc ships, this change is absolutely fundamental, and boresight ships are often hosed by all-stop crits. I don't want to fathom what this does to the Drazi, Drakh Raiders, or the WhiteStar, who only have one arc and lose their life when they lose their mobility.
Critical effects are powerful right now, even outside of damage. Losing SA is even a big deal. I don't think, given the criticals in the chart that exist now, that this is a workable premise, espeically as the ships get bigger.
I prefer the as-is state, but that is simply my opinion.