So, let's see:
At level 2 you can have:
Paranoia (+ 5 initiative)
Trigger happy (+ 7 initiative)
Gunslinger (+ 7 initiative)
With some dexterity and agility, that's easy 40+ initiative.
What exactly at this point prevents you from just taking a 10AP-or-less attack, leaving the zone, coming back, taking another 10AP-or-less attack, leaving again, etc, etc?
Seems completely foolproof and unbeatable to me. The -10 initiative penalty is still not enough to make you lose any initiative rolls. Slap another +5 from root soda if the need be. And you can get initiative even higher with specialization points.