Certification—11​.100 (c)

"(c) Persons using electronic signatures shall, prior to or at the time of such use, certify to the agency that the electronic signatures in their system, used on or after August 20, 1997, are intended to be the legally binding equivalent of traditional handwritten signatures.

(1) The certification shall be submitted in paper form and signed with a traditional handwritten signature, to the Office of Regional Operations (HFC-100), 5600 Fishers Lane, Rockville, MD 20857.

(2) Persons using electronic signatures shall, upon agency request, provide additional certification or testimony that a specific electronic signature is the legally binding equivalent of the signer's handwritten signature."

Certifying the persons using electronic signatures are intending to apply the legal equivalent of a handwritten signature is also only a procedural activity. This certification is applicable to all systems where a certified person is able to apply electronic signatures. Certifications are required for each person and not each system.