2. As Penals accumulate veterancy, they definitely tend to outscale all infantry OST can field by that point.This is, even though Penals receive massive amounts of accuracy (which is the primary stat for long-range troops)Even with LMGs, Grenadiers will bleed/even lose very hard to Penals.This makes infantry investment for OST futile every time the Soviet player picks T1.This is one of the core issues this patch is trying to address.
ost infantry definetely has a hard time against penals, but also against pretty much every other infantry type in the game. so why not give ost strategic diversity by creating an upgrade in t0 unlockable with bt3 that gives grens ( maybe also pzgrens) a fifth man for a decent investment. that would be a global upgrade (something coh2 is missing a lot), it would increase wehrmacht lategame scaling and strategic diversity and maybe solve your problem.
if not (probably the case), then slightly nerf penals to give them a more defined weakness, maybe change their vet and accuracy so that they are worse at long range (right now thnx to flamer they are quite strong at every distance)
edit: and maybe make penal flamer a bit more costly