I get the idea of what they're saying, but I don't think this wholly applies to the film. TDKR isn't solely about Bruce Wayne finding a way to live a normal life; large parts of it are about Batman and others doing cool stuff. It's a big summer blockbuster, not some small-scale indie flick.
And regardless, I think it's fine to take issue with plot holes in a movie. Some movies may be more egregious than others in this regard, and I think TDKR was one of them. I largely ignored the (much fewer) plot holes in The Dark Knight (which was a much better movie) because it had a sense of the story it wanted to tell and presented it in a coherent manner.
The thing about plot holes is that they're a sign of lazy writing, and often in concert, lazy characterization. They're a sign of the writer being unable to fashion a script that makes sense out of the narrative they want to tell. I think it's entirely appropriate to critique a filmmaker who, when he doesn't know how to transition from one scene to the next, just has explosions appear to drive the thing forward.