I did some testing. It generally does not go out side the radius. It does have a higher change of impacting near by terrain. I believe the flight pattern is at fault here
Preferred_height_approach is 15 and the preferred_height_dive is also 15. This makes the IL comes in and stays low. More rounds hit buildings and trees
In comparison to the stuka,
Preferred_height_approach is 30 and the preferred_height_dive is 18. The angle of approach and the higher altitude makes less rounds impact the environment.
Additionally, the lower angle allows the scatter to much more pronounced, relying on more of colliding then impact.
Balance, wise, yes it is very weak. More suppression needed.
Thanks for testing. Even if you just make it more reliable by a simple fix of the angle then that would go a long way though you could obviously reduce CP or do other things to make it more attractive. So sad because this commander has so much potential...