Well, this specification is NOT wrong and is correct as a geometric datum reference frame. Without a deep dive into what your customers’ requirements are for this component it is not possible to demonstrate “why this isn't the best way to call out the datum structure” where facts may be that this may be the best specification.
I do suspect that a simpler secondary datum single feature and tertiary (single) feature may be more traditional - arguing against a correct specification is not an effort one should pursue.
To better understand this dimensioning and Datum specification see:
Overview as mentioned - ASME Y14.5-2009, paragraph 4.12.3, 4.11.9 and 4.9 and related figure 4-26 “Hole Pattern as a Datum”.
The ASME-2018 standard also provides specific interpretation guidance for a hole pattern identified as a datum.
Paragraph 7.12.3, 7.12.4
Figure 7.18, 7-19, 7-20,
This concept is not in any of my published books - though it should be.