Problematic in how it interacts with other devices.
Examples: Would a "Capacitor Array" boost its damage? Would "Armor-Piercing Ammunition" prevent your opponent from reducing its damage? If not, how do you specify that in the space available for a weapon card?
Also, if you hit someone with 6 flamers, do they lose six maneuvers? If not, how do you specify that in the space available for a weapon card?
Hrm. A follow-up thought:
I think a Flamer might work, with the following rules:
Flamer
Energy Weapon
Damage: 0
Range: Contact/Short
This weapon's damage may not be increased.
When this weapon hits, if your opponent has played fewer Maneuvers than your Energy weapon skill, they must immediately place a maneuver card from their hand face-down as if it were a Basic Move.
... hrm. I'll think about it.