Agreed. I didn't really think he was very consistent with how he's been written in the other titles.
I still enjoyed this issue though. Underbelly as a personification of all of the evil in Gotham seems like a potentially much more significant villain than you would guess from this issue alone. The banter between Jason, Roy, and Jim as they figure out how to take him down was amusing. The real highlight for me though was definitely Jason going to visit Bruce at the end. That was very nicely done. Joker's Daughter is back already? We just got rid of her over in Detective Comics. Not my favorite villain but we'll see how she does here.