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.
You could also get Molotov conscripts. Point stands that a unit that overlaps with 3 other infantry troops in what it counters (garrison) isn't good when call-ins and the Maxim exist. The fact that nobody uses Penals is pretty good proof, it's better if they get removed from a niche urban BO and become a more widespread unit. It's like if Panzgrens were a cost inefficient gren substitute with an ability that let them set up like an MG42-nobody would build them because Grens + hmg would be 99% better, just like outside of urban bo that would be better off with maxims anyway can use Penals.
You would get 300 mp Penals for guard level anti-infantry without the PTRS. If anything I want Penals to become weaker Panzerfusilers, which ftr are a bit stronger at range than Cons.
And yes, flamer Engies and shocks are both anti-garrison, they just have different price upkeep durability utility, etc. Penals fall into the same boat, only they're the least cost efficient, are tier locked, and have the least utility outside coming early. Try the guys tuning mod (although a bit different than penal change to fusilier type unit) and tell me you think current Penals are better for the faction as a whole.