If by "do the job" you mean fulfill an identical role to flamer Engies and Shocks while eating up a valuable slot in a tier that sees no competitive use in a faction that has no non doctrinal elite infantry and relies on HMG spam, I agree.
Penals don't have to be an urban unit, they should be an inbetween of Cons and Guards.
When you look at the Special Rifle Command, it says it deploys tough infantry for reconnaissance. Semi-elite, ranged Penals could easily represent Soviet Razvedka, too. It even makes sense thematically.
Completly wrong.
Show me triple engi/shocks build on maps like Trois Points or Lierneux. With engis you gonna lose map presence since their only power is flamethrowerer. Shocks are avaible at 2CPs and expensive.
Again, why should I get 300MP squad with 1 DP if I can get better Guards?
Or just get Cons for better long range and better vet.
Semi-auto + flamer make Penals great units. All they need is -30% rec. acc. and suddenly they will become quasi-elite with lower rec. acc.
And no, Enigs, nor Shocks fill their role.