Imo that is misconception because when it comes to Soviet we went from commander depended reliance with 2 building and doctrinal units filling the gaps, to a non commander design with 3 buildings while keeping the plethora of doctrinal units and the power level of those doctrinal units and in that design some unit are simply redundant.
During that 2 tier building + doctrinal units design, Penals were still irrelevant. The power level of those 2 other units was so high to compensate for the lack of versatility in tech access.
The whole point of moving out of that design was in order to nerf specific units holding the faction to be in a desirable level.
Not sure where is a misconception. The tier is still composed of 3 pseudo shock units, 2 which became more irrelevant the further the opposing factions received updates. It's "unhealthy" for the game to have snipers and clowncars been meta and the tier is composed of that.
If you want the units inside T1 to be fair, the build time and cost of the tier should never be as high as T2 and should be equiparable to OH T1. You can make Penals into PF 2.0, that would just mean people not using T1 even more.
I'm not opposed to someone proposing changes to Penals. But it's too shortsighted to implement them in isolation without taking a look at the tech + 2 other units and early/mid game transition when using them.