At the appellant’s option, the Review Board may make findings and submit recommendations to the PSTEB based solely on the written record. The appellant may provide additional relevant documents to the Review Board, and shall submit a written statement explaining the appellant’s position. A party seeking to file additions to the file shall do so at least 15 days before the scheduled appeal. Licensure staff may submit a written response to the appellant’s statement and provide any additional relevant documents to the Review Board at least 10 days before the scheduled appeal. The appellant may submit a written reply to staff’s response at least 5 days before the scheduled appeal.