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BS! They already have all the advantages on their side.
Also SS unlike normal ships only have torps so it's like the aim assist on your guns
Having less than 40 secs reload is not balanced in any way, right now a sub can be at periscope depth 3 km from you and spam torps with impunity bbecause at that range you don't need to ping. Also a lot of BBs have only 5 or 6 km depth charges that are useless against a sub pinging you from 10 km