No, that is just the COH2 way. People forget you can tech T2 and get a ZiS if you need to, they're just used to clicking the lazy buttons of Elite Inf docs.
Wehr T1 has no AT.
USF has no AT unless you TECH zookas which is a fuel/tech and muni cost. So technically not just T1.
UKF has to tech to 6 pounder AT guns.
OKW does have the raketen and Sturm pios but yet they struggle with AT more than any other faction in the game since both are kinda shit.
Soviets can get T2 right at the start and build a ZiS for no fuel at minute 1 if they want. Then have access to what is considered one of the most useful MG's in the game as well as Cons with AT nades should they want them. Also the best healing in the game for the least cost. T1 has 2 man snipers which are super powerful on their own, along with the M3 which is also useful. Now, with all of this already quite strong early game options does anyone think that Penals need PTRS or that Soviets need AT in T1? You're out of your minds.
Indeed it is the COH2 way, in that the game is quite a bit different than COH1. While I prefer COH1 I have to work with what I have.
T1 on Wehr absolutely has lite AT, in the faust, or as Australian pointed out the teller mine. Lite AT meaning that the unit can slow a mechanized unit and buy time until a suitable answer is developed. Fausts for instance buy time until the AC can arrive and keep them back or hunt them down.
If someone went T1 and had to go T2 then you set up a situation where teching is linear or T1 is never used because it costs twice as much as T2. The penals with PTRS are not strictly early game. Since they require a large munitions investment they are late-early, early-mid game, and you probably won't want to go with them unless you specifically give up on getting hard AT. In this case you need to rely on commanders or some other trick to keep you going for your first vehicle. On top of that you give up your powerful AI squad, with vet targeted at that for some AT to hold the line.
I am not disputing the power of T1, in that it has utility, but forcing it to play without any back up plan makes it such a high risk playstyle it is unlikely to be used. PTRS penals may not be perfect but I haven't heard too many other good ways to make T1 attractive once penals are nerfed.
I did leave off Soviet Cons with AT nades, which certainly are there, and should be considered as well.
I don't think we should automatically accept PTRS penals because the balance team is trying them, but I do think we should try them in the mod first.