I was thinking the potential of 3 close ranged attack differentiates it from the big treaty cruisers that emphasise ranged fire. Being able to knockout a target in a single turns firing is exciting but its got to be somewhat limited.
A BwG derivative make it a slower weaker version of existing cards rather than its own thing.
Cleveland has 8887(ER4) + 554 & SA
Baltimore Has 10 10 9 8 (ER4) 554
Forcing this to close to R2, and then getting the most of it battery is 9987 + 7765(x2) ofsets that the older ship has better total gun values and save adding any funky actions SAs
Masked Secondary Guns - If you win initiative, this unit can make two Secondary Gunnery attacks against separate targets within range 2 during your Surface Attack step.