I find that annoying also. I have found the 40mm to be a great weapon even against larger merchants. There have been more than a few occasions where I ordered the crew to engage one merchant with the deck gun while I engage the other with the 40mm and usually I finish first. Historically sub commanders used the AA guns mostly on surface targets and dove rather than engage aircraft on the surface.
There should be an option for the AA gunners to shoot at a surface target.
On the other hand using SH3 and U-Boat missions, the german AA guns are useless against even small boats.
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