Yes. This is how its working.
Couple of options, he can also shoot with -10 ob on 3rd round. This should be raw just like if you spend 20% moving and attack with 80% action would be -20 to ob.
In RM 1st ed or 2nd edition with out the action % system. it was like you could reduce your QU bonus form reloading minuses.
short bow 1/round
combosite bow 1/round -20 ob
long bow 1/round -30 ob
So character with +30 qu bonus could fire every round with out negative bonus.
The RMC arms law rules say that you can allow minuses in maneuvers with an interval. ie. C/C has a 50-100% but missile fire has 50% without interval.
The activity rules, as I commented before, allow an archer to shot two following turns without penalties having to prepare the third (what I find very interesting having into account how we played until now).
On the other side, I thought adding shot and recharge in a complex maneuver for a (50+80)% = 130% so, you can shot every turn with a -30 (that coincides with the classic rule from previous editions).
I spent time deciding what option should I to use and eventually I decided to choose one of them but not to mix.