The drill does seem to be a great place to start for LTC's who have recently received their license and/or are looking to get reasonably realistic range training in.
I like the holster work from concealment, time standards, and movement. Ditto with the pair of head shots at both 3 and 7 yards.
Ran the drill in my backyard using airsoft over lunch. Airsoft isn't exactly the same as shooting a real gun, but it is inexpensive and extremely convenient.
Was funny how nervous I was starting out, trying to beat the standard,etc. My biggest issue was remembering what precisely to do, when (was that 2 or 3 shots?, start position?, etc). Working outside in the wind... with movement, my draw from under my shirt got flubbed every now and then, but I was still getting under the 3 sec time limit.
3 yards is the home of point shooting. I was generally under 2 seconds, with a 1.35 sec draw from concealment. Using my sights took at least .25 seconds longer. I'm sure less recoil on the airsoft helped the overall time.
Found that sights weren't really needed for 7 yards either, although I couldn't rush the headshots without loosing accuracy. Still kept times in the ~2 second range.
For the more advanced shooter I would use Mozambique drills instead of the 3 body shots. I ran 2 body + 2 head shots well under the 3 second time standard. Airsoft helped for sure on that!
All-and-all the drill is a good stepping stone towards
Close Range Gunfighting, which involves a lot more movement.