Lanefan
Victoria Rules
That's not the problem, it's the point!The problem with Touch AC is the notion that your level 12 Fighter with a Sword in his hand which he is exceptionally good at but with Dex 10 (Cos Heavy Armour) can't actually defend himself with any competence.
The whole idea of touch AC is that sometimes armour just doesn't help very much: you're going to get hit anyway, so best to just attack all-out. As a pleasant side effect, a fight against creatures using touch attacks gives some usually-non-melee characters a chance to do some real fighting.
I'd been using a variant of touch AC for years without realizing it, before 3e formalized it.