Philosophical discussion regarding tank berms

[Mustang]

If it's buried then it wouldn't be able to move without destroying the entrenchment, and should be a fortification. Berms can vary, but from the official history at least it sounds like they were shot through all the time.

It mainly makes a difference with modern MBTs. 30 points PEN matters if you score a rear hull hit on a Leo instead of a front turret hit. Although I admit that doesn't happen often.