Four points:
1. Artillery battalions have 36 guns or 3 battalions worth for most armies throughout the period, meaning some big compromises in trying to create historical templates.
2. The artillery is not powerful enough. With that many guns, many more than most divisions had, and no distinctions from light through to siege guns, the artillery soft attack should dwarf the infantry soft attack, but it barely exceeds it.
3. Manpower is way off. A division with 9 infantry battalions, engineers, recon and 11 battalion equivalents of artillery should be at the very least 15,000 men, if not more.
4. Historically the Netherlands only managed to field less than half that number of guns per division when including the guns held at corps level, so there's been some alternate history explored. An extra 80 artillery pieces probably more than makes up for the missing 24 x 47mm AT guns.