For PC I get it, uncountable hardware variations. But for console games, it's inexcusable. You have one and only one variation of the console. Up your game.
I would say it has more to do with the fact that consoles now have hard drives and broadband internet connections. Games can be released as "good enough" to meet deadlines, with the bug fixes coming at a later date. This wasn't possible when consoles couldn't apply updates to their games.
Granted, I'm not sure why they included some games with client side problems in their list of examples.