Wes and I have talked out our differing views on DR, and his reading is the correct one.
Shield health does indeed dip with successful hits below the threshold of the target's shields. While other factors -- under GM control -- could change that equation in practice, it's the correct fundamental reading of how our DR system works.
Therefore, that reasoning for rejecting this submission is vacated.
However, as Wes and I talked, we came to the conclusion that the submission's potential for being overpowered -- especially in the intended chief submission, the C5 -- bears explaining.
Bottom line: it's min/maxing our DR system in a way that is abusive. Whereas starships have only so much surface area -- let alone energy reserves and internal space for routing them -- this submission purposely bypasses those concerns to allow a starship to simply attach as many units as it can to become a powerhouse far beyond what it was designed to be.
And far beyond what the DR was created to regulate. Though arguments about "glass cannons" might abound, no other starship weapons cluster of any faction could do so much single-shot damage on a lone target area.
The intertwining of this submission and the C5 cannot be undone, as one begets the other, and the potential for DR abuse for other starships is too great to ignore.
With that new justification applied, this submission remains rejected.