I'm not exaggerating I really didn't notice any speed difference between flying straight and with full rudder - speed tends to stay above 180 km/h while level and at full throttle. While in Rise of Flight the plane loses about 20 km/h. Though otherwise I agree -- you've made the behavior very similar to ROF.
Curiously, the stock WOFF FM already resulted in some bad habits for me: I've got used to doing full power approach and then performing a crazy crab landing in any spot of my choice, but with your FM I had a hard time slowing down in that tiny airfield surrounded by a forest.
I really like what you've done, but with those possible AI problems (which I can understand as a programmer) I hope devs will revise the rudder behavior officially.