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Not a chance. A large transport isn't going to hit anything with those stats. Contrast your ammendment with the current Type 3s (see below). They're superior in every way. That velocity makes it a terrible anti-snub turret, probably worse than it is currently.
A bomber sticking at 700m+ is not going to be so much as touched by those guns. What you're proposing is Type 2s with a higher refire, worse damage and dispersion. Suppression doesn't work unless you're up against a fighter who has no choice by to go close range. The current 2s and 3s can take care of them already. These turrets should be balanced against bombers, and they're not going to do their job at all in that case.