On May 23, 2000, GNYHA testified before the New York City Planning Commission in opposition to aspects of the City's zoning reform proposal as applied to hospitals, related education and research facilities, and continuing care facilities. The proposal, known as the Unified Bulk Program, is the first comprehensive reform of the City's zoning resolution in 40 years and is designed to simplify and clarify the City's zoning requirements. In doing so, however, the proposal would impose new height limits and setback controls and would limit the transfer of development rights. GNYHA's testimony focused on the fact that the proposal would have a disparate and negative impact on health care facilities, which are constantly building and rebuilding in response to the demands of an evolving health care system. In particular, health care facilities often have greater floor-to-floor heights than do residential and other types of buildings and therefore would be significantly affected by the proposed new height limits. This unique design feature of health care facilities is necessary because they must house operating rooms, special equipment, auditoriums, and patient care areas with extensive electrical, plumbing, heating/ventilation/air conditioning, and other special service needs. In addition, health care facilities would be unable to build shorter but squatter buildings because their design calls for appropriate light and exterior space and, therefore, they often must have smaller footprints than do other buildings. Finally, the reform requirements would preclude GNYHA members from being able to afford the costs and burdens of locating and developing additional parcels of land to meet the evolving health care needs of their communities. GNYHA, therefore, asked the City Planning Commission to consider the disparate impact of the proposal on GNYHA members and to permit them to undertake development and expansion to the same extent that they are allowed under existing rules.