I feel like that would be really strange. All other flak is AI focused so having one that just isn't at all would be awkward I think
Flaks and autocannons are very inconsistent. Some is accuracy based, some is AoE based. Some suppress, some don't.
The oldest flak gun in the game (the 222 upgrade for the Ostheer 221) was originally trash against infantry.
Personally though, I think cloning the stats and costs off the OKW Flak and removing the cost of the sidetech is a cleaner route.