As Iranon said, the listed rates are always taken from ideal situations, usually on land.
The problem is much more than just having to get the shells up from inside the sub. The gun is not stabilized. It has the same complications that have been with naval gunnery since the sailing ship days, and that is that the ship pitches and rolls, and the gun moves with it. The gunner performs what the British called "Firing on the roll", which means waiting until the boat is level before pressing the trigger. Obviously this takes time, and the heavier the roll the more time is needed.
The problem is with the game itself - it doesn't adjust for changing weather conditions nor for the fatigue of the loaders.
I keep mine set to 12 seconds for the 8.8cm gun and 15 seconds for the 10.5cm, and call it good.
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