Is Type 03 SAM a kind of joke?

[轻拢慢捻抹复挑_鞍山娇喘停不了]

I don’t know what jet or helicopter players think about it, but right now, the Type 03 looks like a “harmless” SPAA. In fact, it is the second-worst SPAA at this BR (12.7), with the only one worse being the Type 81 Kai (which is also Japanese SPAA).

The Stats:

The average K/D of the Type 03 is 0.78, while the mean K/R is 0.62 [1].
At the same time, when we look at other SPAAs at BR 12.7, almost none of them have a mean K/D lower than 1.0 if we ignore “Elde 98” which also has much better data than Type 03.

Possible Solution?
Maybe the Type 03 needs a new modification (like a “Type 03 Kai Missiles”), or it should have a lower BR, such as 11.7.
(Yes, not 12.3. Since the Type 81 (C) at 11.7 has very good performance even in 13.0-14.0 games, an exchange or major adjustment may be needed.)
Or just exchange the location on tech tree?

Reference:
[1] Data from Statshark: https://statshark.net/globalstats