form 1st you must know under lvl 80 (much better under lvl 90), elite boosted gunners, don't rich max cap accuracy and more important, reload. hero's cap reload a little faster, anyway the @ full reload cap is at 2400 reloading ability. so use just 13/11, mean full accuracy, gunners.

the 2nd, RM is lack of dual guns for AA, that mean don't have like almost all other nations something x2 barrell proper use for AA, or something dedicated AA guns, good to the best reloading (us 2x3/70, km 2x4,1, and so long, i don't remeber all guns dual use he / aa).

much worst, the only one almost usefull guns dual role, he-aa, 2x5/38, that 2,56 reloading isn't full relaod cap after gap lvl 30 (lvl gunners vs lvl guns if is +30 lvls almost all old nations rich full reload capability). a suggestion is to nerf this guns, increase reloading speed, less he-ap dmg, a little less aa dmg, to don't be so frustrating nation at low and middle lvl).

now, let see the guns (i will update list how many times anybody try and test guns for aa )

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- 2x5"/38 - GA at 34 (almost all , cl-ca, who can hold and carry 5 he + min 5 AA shells bind)

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- 1x4,7/skoda, 2,16 sec - GA at 28 (29 for short-longest hit at max altitude planes) (surprizing guns T slot for regina margherita, aa - he shells settings, good aa dmg shell, long range for he)

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 - all series 1x3", 1x3,5"  with reload at 1,4-1,6 sec, almost all GA 39 or 44 (good for dd with low gun space, for beginning)

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- 2x3,9"/47 - GA at 44; poor reloading

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the other guns for AA, if you want to spend few time for test and put here, you are welcome.