If you include that "using ZFS", it is a small subset and "a few individual users", but that may be because they care and don't choose ZFS because of it.
If you remove that clause, I would think there are way more people in that situation. That still wouldn't imply that those who write ZFS have to care, though. There's nothing wrong with providing a great solution for a selected subset that isn't suitable for the majority. In ZFS's case, that certainly applies. For its target audience, the ability to shrink pools is nice to have, and nowhere to minimum viable product.
That argument applies to btrfs, too, by he way.cthere are way more users for whom something like Google drive is a better option than running their own btrfs system.cthat doesn't mean there is no reason to develop btrfs.