yeah just tested it, submerged it's a joke, a real disaster. non submerged it's better, it can be more or less close depending how good ur micro is but you still get owned no matter what . I especially recommend the test submerged vs cyb destro . I've just made the test once again (I already did to test the navies) and 10v10, 5 cyb remain and in quite good shape
submerging is good though to avoid those t1 frigates.
EDIT : oh and btw they mostly get owned cause the anti torps aren't working from what i've seen so far