The permittee's answer to a show cause order shall contain a statement setting forth—

1. (a) The reasons in detail why a pattern of violations does not exist or has not existed, including all reasons for contesting—

   1. (1) The fact of any of the violations alleged by OSM as constituting a pattern of violations;
   2. (2) The willfulness of such violations; or
   3. (3) Whether such violations were caused by the unwarranted failure of the permittee;
2. (b) All mitigating factors the permittee believes exist in determining the terms of the revocation or the length and terms of the suspension;
3. (c) Any other alleged relevant facts; and
4. (d) Whether a hearing on the show cause order is desired.

[43 FR 34386, Aug. 3, 1978, as amended at 67 FR 61510, Oct. 1, 2002]