The average programmer would [...] because that's the way the program was written, as evidenced by the semicolon between the two statements. Seriously? I don't even know C# and the "var q0" was enough to suggest the type of whatever Where returns is not an array of int (as opposed to the two functions above, with int and bool types), so why would I expect it to have filtered the array and returned it? Ditto for the 2…
It is possible that Erik has a better (or more cynical) idea of the "average programmer" than you or I might. I'm of the opinion that so long it makes sense and has an elegance to it, then it's fine. If "average" programmers can't handle it, they can use another language or something.
Since Meijer is as an employee of Microsoft I'd extrapolate to say he's heavily influenced in his experience of the "average programmer" by the primary clients of his company.