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I am doing a detail face to face game with myself - this time - looking at EVERY unit on both sides.
I noticed some problems with Dutch AA guns - and began digging. I find there are two guns absent from all WITP
OBs

a Bofors 80 mm L 50 AA gun (which is a variation on the Bofors 75mm M1930 which came in three calibers)

and an unidentified 180mm L46 coast defense gun

Neither is listed by John Campbell - who attempted a comprehensive listing of all coast defense and naval guns

Requesting data on these guns

Turns out the Bofors M1930 was a member of the Bofors M1929 family - widely used - and significantly better than the French 75s of WWI vintage. It has an effective ceiling of 28,000 feet (corresponding to an RHS range of 9 = 9,000 yards).
It has effect of 14 (= shell weight) and penetration of 140 (= 1.75 times caliber in mm). Tentative accuracy rating = 14 (assuming a similar ROF to other 75mm class weapons).

In comparison, the classic 3 inch AA gun has a ceiling of 22,600 feet (corresponding to an RHS range of 7 = 7,000 yards).
It has effect of 13 and penetration of 133. The accuracy is also 14.

Also in comparison, the Japanese 75mm Type 88 has a ceiling of 21,000 feet (corresponding to an RHS effective range of 7 = 7,000 yards). It has effect of 11 and penetration of 133. The accuracy is 11.