OFA submitted comments on the proposed modifications to Ontario Regulation 316/06 (Transition Matters – Growth Plans) made under the Places to Grow Act, 2005 to implement the Proposed Methodology for Land Needs Assessment for the Greater Golden Horseshoe. OFA advocated that the province reopen the Growth Plan for the Greater Golden Horseshoe to incorporate the following requirements: 1. Fixed, permanent urban boundaries for all settlement areas throughout the Growth Plan area; 2. Convert the urban intensification and greenfield development targets to mandatory requirements that are not open to appeal; 3. Adopt a broader, province-wide policy to distribute urban growth more uniformly across all Ontario urban areas with the capacity to accommodate growth; i.e. those with adequate development lands within their existing urban boundaries, serviced by municipal sewers, water, roads and transportation infrastructure; and 4. Align the Natural Heritage System policies of the Growth Plan for the Greater Golden Horseshoe with those in the Provincial Policy Statement.