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I have a problem with the spam Penal and convert some when needed into AT units. It gives too much solution for the Soviet player by using a single unit for half of the game.
a) Your opponent build a light tank, solution is to convert one or two penal and then adapt your tiering
b) Your opponent build more infantry, solution is to keep your penal AI and adapt your tiering.
There isn't basically a wrong decision making with Penals at this stage of the game.
If you compare with USF which propose a similar gameplay early on, you need to decide whenever you want AI control with the T1 or AT and light tanks with T2. And if you don't, you still need to invest fuel on zook.
Soviet aren't design that way, You went Penal spam, it goes well = T3 and you got AI and AT solutions. You went Penal spam, it goes wrong = T2 and you got AI and AT solutions.
This is why, even if the Penals you build on the patch are balanced as a unit, this will not bring any balance into the gameplay. If I agree that in order to reduce the Penal impact early on we must give a AT solution on the T1, this solution shouldn't be on the Penal themselves. It can come from a M-42 or from other solutions. It should have a real cost, something that impact your strategy and decision making more than -I'm on the downside so T2 + penalPTRS, I'm on the upside so t3 + penalPTRS.