I think that tool change commands(?) lines should be on their separate lines like you suspect. Also, you seem to have negative coordinates in the drill file, which is thing to avoid also (check alignment with gerber coordinates, although CAM operator can align layers, it is better to ensure this before sending out files). Furthermore, I think it would be also wise to include drill sizes, so the file should probably look something like this:
M48
METRIC,TZ
%
T1C1.02
X192785Y222665
X232915Y222665
X232915Y241335
T2C1.1
X306340Y186000
X306340Y191080
X306340Y188540
T3C2.1
X105200Y113800
X105200Y161000
X105200Y179300
Regards,
Janne