The procedural formalities introduced on 1 February 2017 via the coming into force of the new 2016 EEA Regulations, mean that where an application for EEA residence documentation is not submitted on a prescribed application form and is not accompanied by specified supportive documentation, such an application is now very likely to be rejected as invalid, i.e it will not be considered at all by the Secretary of State.
Regardless of whether the Secretary of State may exercise discretion over whether to accept the application or not, it is not clear why EEA applications submitted after 1 February 2017, must now pass a validity hurdle.