As usual, great bugfixes and quality of life changes (especially retreat point distance, feels like it should've been done ages ago). You've done some great work.
As to balance changes:
Flak HT behind healing
may be good for balance, but it doesn't 'make sense' logically, though I agree this shouldn't be a priority.
About the hot topic of Penals, I can't speak for their performance or new role(s) yet, but I hope you don't fall victim to sunk-cost fallacy. The point of the balance mod is to play around with ideas (and I love that you're giving us a chance to try stuff out), but please don't get fixated on the PTRSs if you come up with something better. I may be biased because I'm not a fan of hand-held AT in general, but I would prefer another solution if possible.
oh, and people that play SOV Tier 1 usually follow it with partisan and guards commanders.
SU is not UP. let's stop with this insanity.
That's the point. It's not about being UP or OP, it's about not being stuck with a Guards or AT-sans commanders if you go T1, opening up strategic variation. I am not saying I necessarily agree but that's the balance team's reasoning.