It's not as bad as I thought.

Now, caveat emptor et prende cum grano salis; I'm the guy who loved movies like Sky Captain, the Punisher, the Hulk, and Dude, Where's My Car? I own my own copy of Coneheads. Really.
And, yes, the entire film limps horribly from a painful infection of Tim Burton's childhood obsessions with Toys, Christmas, and Feeling Freakish and Alienated. And, yes, it seemed like they hired the Penguin to play DeVito, rather than DeVito to play the Penguin.
But...
When the Penguin is in full "running for mayor" mode and in Pengy drag, the character nicely straddles the ridiculous/threatening divide. As one should, one feels both contempt and pity for the Penguin. Having Oswald's situation with his parents mirror Bruce's is a nice touch connecting the characters. If the essence of the Penguin is a man who wants the finer things he feels he deserves, but shows himself unworthy by his willingness to take shortcuts to get them, then the film capture that, too. On the whole not as fabulous as Burgess Meredith, but what's being attempted in the portrayal is a heckuva lot more complex.
The film even nicely incorporated of the some of the basic elements of "the Penguin myth" from other media, including "Penguin Runs for Mayor" and "Penguin Gets Control of the Batmobile".
As for Catwoman, well, the film did use most of her Golden/Silver Age origin; an amnesiac woman who was not so much evil as simply self-centered, more amoral than immoral.
While the first movie (the one where some old actor played the Joker) showed the reins of power shifting out of the hands of mobsters and into the hands of villains, the second film showed white collar crime (Schreck) also losing its grip on the city in the face of its larger than life Mego Action baddies. The film even had the wisdom to make fun of some of its predecessor's greatest stupidities.
Maybe I search too hard for left elbows in films (particularly comic book ones). But it's better than simply throwing out the baby with the bathwater every time a film doesn't live up to my hopes....