Useful life of old hot water heater hadn't expired.

 
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Landlord applied for MCI rent hikes based on the installation of a new hot water heater. The DRA ruled against landlord because the old hot water heater hadn't outlived its useful life. Landlord appealed and lost. Landlord claimed that the old heater had been leaking and inoperative. But the DHCR defines the useful life of a hot water heater as 10 years, and landlord received an MCI increase for the old one in 2003...

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