The determination is rationally based on petitioner's failure to adduce documents showing that at least 75% of the buildingwide and apartment systems had been completely replaced, in accordance with the substantial rehabilitation criteria of DHCR Operational Bulletin 95-2. We reject petitioner's argument that it was arbitrary of DHCR to apply a 1995 standard of proof to an alteration that was done in 1983 at a time when there were no published standards or guidelines concerning...
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