To directly address the change though, how do you see that playing out? T1 is now completely devoid of AT, so now OKW will always luchs rush (see: the old dshk meta in which people countered dshks with luchs spam - battlegroup was used even less than it is used now). With no penals and no scout car, t1 will probably just lose hard to OKW. T2 will still be dead, because now your penal build doesn't have the early scout car to lift above its weight. You have an AT gun with your penals, and players will definitely need it with how much harder they'll lose the early game without the m3.
More than that, you now have, as porkloin alluded to, a tier system where basically all of your anti infantry is in one tier, and all of your anti tank is in the other. If that sounds familiar, it's because that was the design of the old USF lt/cpt system.
I'm assuming here that you're talking about my changes i.e. the DsHK for maxim, and also swaps with penals.
T1 still has scout car under this, it's the penals that were moved. Flame engies are the passenger 90% of the time so not much is really changing wrt to the scout car's power. If you're playing the new t1 and in desperate need of PTRS you have two commanders options, another commander with tank hunters, and also two other commanders with the light AT gun.
The comparison to the old USF tech tree kinda falls flat as the old USF system required 110 fuel to unlock both tiers vs 30 fuel for a soviet player wanting both tiers. Soviets also have their key vehicles in t3 while also having a much better selection of commanders call-ins to shore up weaknesses.
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