Main difference between guards and penals is this one:
The problem lies with the AI power Penal have without the PTRS...
Patch difference from live
flamer removed, Xp value increase, vet 3 armor decreased.
All this have little impact on the initial punch of the unit thus the problem remains, just replace guards with AT partisans or PTRS conscripts or PTRS conscripts and the blobbing remain the same...
It would be a different story if Penal come out already equipped with PTRS but now they are about the same spot as before with the added option to upgrade to PTRS if and when they like, I would actually call that buff from live and not nerf since they can stay relevant for even in later stages of the game...
in addtion
"Penal Battalion
To continue our attempts at finding a good fit for Penals in Soviet teching, we are going to trial a second version of Penal squad. This time, we are restoring part of their veterancy so that Penals excel as hard-hitting long-range skirmishers, which will allow them to defend against advancing short-range squads."
If the role of Penals is long range skirmishers they should be equipped by bolt action rifles and lmg and not semi auto.
In addition the only sort range infantry is axis side is pio and the doctrinal assault grenadiers so there is little point in having them....