I suggest to try and see how they perform against 60 muni STG Volks. Vet 0 and vet 5 vs vet 3.
60 would be more than fine and i would suggest a different kind of nerf on the ability in order to keep the current damage. Increasing cooldown so it's harder to equip as many units early on despite having the munition to do so.
Yes, I am aware of the fact that svt cons perform well. IMO this is one of the salient features of this commander. Infantry focused. Hence we get 3 dp on air guards and no button ability or anything sort of anti-tank. we get an AT strafe which is quite good when it connects. the thing is volks have stg as a non-doctrinal upgrade. SVT drop is a doctrinal upgrade which exists in only one commander if we exclude dropping svt for our allies. Further, this commander is quite muni starved in the early game. I do 4 v 4 with soviets a lot and lately, I am using this doctrine when I get angry after okw player decides to bum rush with infantry. then I am like. u think u can blob? I will blob bigger. lol. jk
TL; DR SVT drop is a doctrinal ability. it should have some benefit/incentive over regular non-doc ability. also, volks get tech for free. conscripts have to purchase that for fuel and mp. I have no issue with timer increase to delay the early game mass svts.
as for penals I don't quite use them with ppsh because I don't wanna waste fuel on t1 when I know I need to get a zis gun eventually. ppsh penals die and are 30 mp to reinforce. better make air guards with free ppsh.