Seems a trifle high end to me. . .but.
Yamma, are you looking at this as the hi/lo problem? i.e. that say You and I are fighting, you SNP me for 1 round, then your next attack while I'm counting stars at low DB is one of those 40EK results. . .followed by a low crit roll for +5 hits?
45 hits in one shot is nothing to sneeze at, but it cn be really frustrating to finally get a tough opponant where you want them, follow it up with a 150+ attack table result, then roll a 3 on the crit.
Is that the situation you're trying to fix here?
To a degree, yes.
Note: I dont use the set phases, but an intiative mod for each action (+10 for snap actions, +0 from normal actions and -10 for deliberate).
The purpose is to make combat more cinimatic and to portray a stronger advantage to stunning a foe. I have played with the rule set several times now, including penalties to the modification based on foes AT (representing the reduced ability to place a lethal shot against a well armored foe). It has worked. The players like it.
I should also note that I don't use stun mnv as a skill in my game anymore, even though I always run a game that focuses on pleasing the players (my philosophy is it cost me nothing to have happy players and happy players make good stories that I can enjoy, and hey, on some level it's all about me, lol).
I'm just playing with the mechanics cuz...well, i can. Been at this a long time and new stuff or new twist is engaging.