Why complicate so much if you can make Penals from 1.1 and add M-42 /Done
This PTRS, PPsh+flamer, then another 3rd PTRS after T4
It's like you have no idea what to do with Penals.
Take away flamethrower, make their stats better than Cons (so they are stronger than Cons but have no utility), no utility (so Cons have better utility) and put M-42.
But of course you haven't tried anything else becasue "PTRS" :/
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If any infantry needs upgrades, it's Cons, not Penals. Cons should be mainline infantry, while Penals should be quasi-elite, better than Cons but without utility, apart from satchel.
Synergy from AI Penals, M3 and Sniper covered with M-42 would be enough to go for T1.
ATM I see no reason why I should go for T1 with all those weird changes.