Comment submitted by Paragon D&E

Summary: Thomas Symons, IT Director at Paragon D&E, a small business in the Defense Industrial Base, supports the goal of the CIRCIA rulemaking but argues that the current proposal creates duplicative reporting burdens for small firms already reporting to the DoD. He recommends operationalizing harmonization mechanisms to allow DIB contractors to satisfy CIRCIA requirements by reporting to the DoD, while also requesting a small-business exception or raised threshold for the residual scope gap.