The following e-filed documents, listed by NYSCEF document number (Motion 001) 2, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 23, 26, 27, 28, 29, 30, 31 were read on this motion to/for ARTICLE 78 (BODY OR OFFICER). DECISION ORDER ON MOTION Upon the foregoing documents, it is ORDERED that the petition for relief, pursuant to CPLR Article 78, of petitioner Jason Mudrick (Motion Seq. 001) is denied and the petition is dismissed; and it is further ORDERED that the Clerk of the Court shall enter judgment accordingly; and it is further ORDERED that the counsel for Respondents serve a copy of this Order with Notice of Entry within twenty (20) days of entry on counsel for petitioner. CASE DISPOSED In this Article 78 proceeding, Petitioner Jason Mudrick seeks an order reversing the decision of the New York City Police Department License Division (the “License Division”) denying Petitioner a Special Carry Business License for a pistol permit. BACKGROUND Petitioner is a resident of New York County, State of New York, and the sole owner of an investment fund, Mudrick Capital Management, LP. Petitioner sought to obtain a New York City Pistol License by filing an application in 2015, which was denied and then administratively appealed. In support of his application, Petitioner submitted a “threat assessment” prepared by the security firm Kroll. The assessment detailed the exposure and risks associated with Petitioner’s occupation and personal wealth, and noted: “Kroll finds the threat environment around Mr. Mudrick to be significant and one predisposed to nefarious/adversarial actions presenting with little or no notice…Kroll recommends Jason Mudrick and Mudrick Capital engage in various executive protection practices for the personal protection of Mr. Mudrick…” (page 4) (NYSCEF doc No. 7, at 2-4). On February 14, 2019, the License Division issued its Notice of Disapproval After Appeal (the “Final Determination”), which is the subject of this Article 78 proceeding (NYSCEF doc No. 4). The Final Determination found that Petitioner was not entitled to a permit as he did not demonstrate “special cause” as required by New York Penal Law pursuant to Chapter 5 of Title 38 of the Rules of the City of New York (“RCNY”). The decision noted that Petitioner’s job managing a hedge fund was not “inherently dangerous work,” and the management of a large sum of capital in and of itself does not place Petitioner in “extraordinary personal danger” (id.). The License Division also dismissed Petitioner’s contentions that he was entitled to Special Carry Business License because of disgruntled investors and former employees, and general negative sentiment towards Wall Street, noting that such contentions were “dubious and highly speculative” (id.) Petitioner argues that he satisfied the requirements demonstrating need for a permit under New York Penal Law. Petitioner contends that RCNY Section 5-03 is unconstitutionally vague and the License Division’s application of the statute in rendering the Final Determination violated his due process rights. Petitioner asks that the case be remanded to the License Division with orders to approve Petitioners’ application.1 DISCUSSION Applicable Statutory Law Pursuant to Penal Law §400 and Administrative Code §10-131, the License Division has promulgated regulations governing the issuance, revocation, and suspension of handgun licenses, which are codified in Title 38 RCNY §5 (“38 RCNY §5″). That regulation provides for six types of handgun licenses. Relevant to this case, §5-01(e)(l) provides for a “Special Carry Business License,” which is defined as “a special license, permitting the carrying of a concealed handgun on the person while the licensee is in New York City”. An applicant for a Special Carry Business License must demonstrate “proper cause” pursuant to Penal Law §400.00(2)(f). Additionally, Title 38 RCNY §5-03 states, in relevant part: “In addition to the requirements in 38 RCNY §5-02, an applicant seeking a carry or special handgun license shall be required to show “proper cause” pursuant to §400.00(2)(f) of the New York State Penal Law. “Proper cause” is determined by a review of all relevant information bearing on the claimed need of the applicant for the license. The following are examples of factors which shall be considered in such a review. (a) Exposure of the applicant by reason of employment or business necessity to extraordinary personal danger requiring authorization to carry a handgun. (b) Exposure of the applicant to extraordinary personal danger, documented by proof of recurrent threats to life or safety requiring authorization to carry a handgun.” Before turning to the merits of Petitioner’s Article 78 application, the Court addresses as a preliminary matter Petitioner’s contentions that 38 RCNY §5 is unconstitutionally vague and the License Division’s application of the statute violated his due process rights. Whether 38 RCNY §5 of the RCNY is Unconstitutionally Vague Petitioner appears to argue in his moving papers that 38 RCNY §5 is unconstitutionally vague and void on its face. Petitioner alleges that statute is “rife with undefined and vague standards in every paragraph. They are either purposefully or negligently created so as to trap an applicant. Objective: make it impossible for any law-abiding citizen to qualify for a handgun license” (NYSCEF doc No. 9 at 5). In support of this argument, Petitioner cites to Court of Appeals caselaw noting that statutes may be struck down on grounds of vagueness (see People v. Stuart, 100 NY2d 412 [2003]). Petitioner concludes that the “proper cause” standard of 38 RCNY §5-03 is unconstitutionally vague as it contains no bright line standards and is thus a “standardless requirement which does not provide the applicant with ‘reasonable notice’ of that which the license applicant must initially meet” (NYSCEF doc No. 31, 22, citing Papachristou v. City of Jacksonville, 405 US 156, 162 [1972]). In opposition, the License Division counters that Petitioner has not demonstrated why 38 RCNY §5 is impermissibly vague. The License Division notes that “a statute, or a regulation, is ‘unconstitutionally vague if it fails to provide a person of ordinary intelligence with a reasonable opportunity to know what is prohibited, and it is written in a manner that permits or encourages arbitrary or discriminatory enforcement”‘ (Ulster Home Care Inc v. Valco, 96 NY2d 505, 509 [2001], quoting People v. Foley, 94 NY2d 688,681 [2000]). A law is unconstitutionally vague if it fails to provide a person of ordinary intelligence fair notice of what is prohibited. (See United States v. Rybiki, 354 F3d 124, I32 [2d Cir. 2003])2. It is well-settled that a regulation will only be found to be impermissibly vague if it is too vague to provide clear guidance to reasonable persons. The Constitution “requires only a reasonable degree of certainty so that individuals of ordinary intelligence are not forced to guess at the meaning of statutory terms.” (Foss v. City of Rochester, 65 NY2d 247, 253 [1985]). Here, the Court finds that Petitioner has not met the “heavy burden” required in sustaining a facial challenge to a statute or regulation (see Sanitation and Recycling Industry Inc. v. City of New York, 1997 U.S. App. LEXIS 3600, Docket No. 96-7788, at * 12 [2d Cir. Feb. 28, l997], quoting New York State Club Ass’n v. City of New York, 487 U.S. l, 11 [1988]). Petitioner is correct in noting that statutes and regulations may be overturned for vagueness, but Petitioner does not cite to any caselaw or legal reasoning for why 38 RCNY §5 is vague on its face. The fact that the regulation does not contain bright line standards and is subject to the reasonable interpretation of License Division officers does not support Petitioner’s argument, as “the Constitution does not require ‘meticulous specificity’ and does not require a law to be drafted with such specificity that it leaves no room for interpretation” (People v. Lang, 36 NY2d 366, 370 [1915]). Whether Petitioner’s Due Process Rights Were Violated Petitioner also counters that his due process rights were violated, and he was denied equal protection under the law as the vagueness of the “proper cause” requirement allowed the License Division to arbitrarily abuse its powers and deny him a permit. Petitioner cites to no legal authority for this argument other than the general proposition that a statute violates due process when it leaves an administrative body with arbitrary standards that are unclear to applicants (164th Bronx Parking v. City of New York, 20 Misc3d 796 [NY Sup Ct 2008]). Petitioner also offers no fact-based support for the argument that he was denied equal protection, other than an unsubstantiated allegation that retired New York City police officers do not have to demonstrate extraordinary need for a permit, a separate step of standards Petitioner claims is separate set of standards is “patently unfair, and discriminatory” (NYSCEF doc No. 31,
