Comment submitted by Edison Electric Institute

Summary: The Edison Electric Institute (EEI), representing U.S. investor-owned electric companies, supports the overarching goals of the CIRCIA rule but urges CISA to refine the implementation to avoid duplicative reporting and excessive operational burdens. They recommend harmonizing requirements with existing frameworks, narrowing the definition of "substantial cyber incident," and ensuring that data retention and reporting timelines are practical for real-time incident response.