KM gunners don't go ACC REL ACC like US gunners do.

Have a look at the "game info" link, and there the "sailors" tab.

Your gunners are fine (well, I would choose different ones, with more reload and good repair stat, but that is by the by).

For AA, take 9/12 or 10/12 gunners, class them AA gunners at level 21, and if you want max reload and better spread, DON'T class them any further (you get lower crew growth in numbers).

Some people even take normal 10/12 gunners (heavy => huge => chief) for their AA gunners with the double 4.1 guns (level 16) that can fire both AA shells and anti-ship shells.