Niagara Escarpment Hearing Office
Bureau des audiences sur l’escarpement du Niagara
ISSUE DATE:
July 09, 2019
CASE NO.:
19-006
PROCEEDING COMMENCED UNDER section 25(5.1) of the Niagara Escarpment Planning and Development Act, R.S.O. 1990, c. N.2, as amended
Appellant:
Meaford and District Ridge Runner Snowmobile Club
Respondent:
Niagara Escarpment Commission
Subject of appeal:
Refusal of a Development Permit Application to install a culvert within a watercourse along an un-improved / un-maintained section of the road allowance to allow a dedicated snowmobile trail route
Reference No.:
G/T/2017-2018/9003
Property Address/Description:
Part Lot 22, Concession 2 & 3
Municipality:
Grey Highlands (Euphrasia)
Upper Tier:
County of Grey
NEHO Case No.:
19-006
NEHO Case Name:
Meaford and District Ridge Runner Snowmobile Club v. Ontario (Niagara Escarpment Commission)
Heard:
May 27, 2019 by telephone conference call and in writing
APPEARANCES:
Parties
Counsel/Representative^+^
Meaford and District Ridge Runner Snowmobile Club
Wil Bulsink^+^ and Steve Voakes^+^
Niagara Escarpment Commission
Rick Watt^+^ and Jane Thompson
Robert Hann
Self-represented
Joan Nuffield
Self-represented
Richard Stark
Self-represented
Participant
John Thompson
Self-represented
Presenter
Craig Jowett
Self-represented
REPORT DELIVERED BY MARLENE CASHIN AND JUSTIN DUNCAN
REASONS
Background
1The Meaford and District Ridge Runner Snowmobile Club (“Snowmobile Club”) applied to the Niagara Escarpment Commission (“NEC”) for a Development Permit to allow the Snowmobile Club to install a 1.5 metre (“m”) diameter by 4.8 m long culvert within a watercourse along an un-improved / un-maintained section of the third line road allowance located at Lot 22 between Concessions 2 and 3 (“Subject Site”) to allow a dedicated snowmobile trail route as part of the Ontario Federation of Snowmobile Club’s provincial trails network. The Subject Site is publicly owned by the Municipality of Grey Highlands (“Grey Highlands”) which, by resolution of municipal Council, provided support for the Snowmobile Club making the application to the NEC.
2On January 25, 2019, the NEC issued a Notice of Decision refusing the Development Permit for various reasons, including that motorized trails (including use by snowmobiles) is not a permitted use within the Escarpment Natural Area designation contained in the Niagara Escarpment Plan (“NEP”) and that the application does not satisfy the Development Criteria of the NEP.
3The Snowmobile Club filed an appeal on February 8, 2019 in accordance with s. 25(5.1) of the Niagara Escarpment Planning and Development Act (“NEPDA”).
4A Pre-Hearing Conference (“PHC”) was held by the Niagara Escarpment Hearing Office (“NEHO”) on May 27, 2019 at which time the NEHO received various requests for status on the appeal. Robert Hann, Joan Nuffield and Richard Stark were granted Party status on consent of the Parties, while John Thompson and Craig Jowett were granted Participant and Presenter status respectively.
5During the PHC, the NEHO established a schedule for the filing of a motion by Mr. Stark seeking to dismiss the Snowmobile Club’s appeal on the basis that the NEHO has already addressed the issues to be raised by the Snowmobile Club in a report dated February 1, 2006, where the NEHO considered an application made to the NEC by Grey Highlands for a development permit. The report of February 1, 2006 and its recommendation were subsequently concurred in by the then Minister of Natural Resources (“Minister”) in a decision dated June 22, 2006, and the application for a development permit was denied.
6Mr. Stark filed his motion and supporting materials on May 31, 2019. The NEC filed submissions on June 13, 2019 and the Snowmobile Club filed submissions on June 14, 2019. Mr. Stark served his reply submissions on June 23, 2019 and filed them with the NEHO on June 25, 2019, the filing taking place four days after the deadline set during the PHC. Mr. Stark explained that he had run into technical issues with his internet connection that prevented him from serving and filing earlier. The other Parties and the Participant did not file any submissions on the motion.
Issues
7The three matters before the NEHO for consideration are as follows:
a. Whether to grant the requests for status made during the PHC.
b. Whether Mr. Stark’s reply submissions on the motion should be struck on the basis of lateness.
c. Whether the appeal should be dismissed under s. 25(8.1) of NEPDA on the basis that the main issues raised have already been determined by the NEHO at a previous hearing.
Relevant Legislation and Rules
8The following provisions of the NEPDA are applicable in the context of the motion filed by Mr. Stark:
- (8) Where the delegate receives one or more notices of appeal under subsection (5.1) the Minister shall appoint an officer for the purpose of conducting a hearing at which representations may be made respecting the decision.
(8.1) Despite subsections (8) and (10), an officer appointed under subsection (8) may refuse to conduct or to continue a hearing if,
(a) in the opinion of the officer, the appeal does not disclose a planning justification for the appeal, is not in the public interest, is without merit, is frivolous or vexatious, or is made only for the purpose of delay;
(b) the notice of appeal did not specify the reasons for the appeal; or
(c) the person who appealed the decision has not responded to a request by the officer for further information within the time specified by the officer.
(8.2) Before refusing under subsection (8.1) to conduct or to continue a hearing, the officer shall notify the person who appealed the decision and give the person an opportunity to make representations thereon.
(8.3) If an officer refuses under subsection (8.1) to conduct or to continue a hearing, the decision of the delegate shall be deemed to be confirmed.
9The definition of Existing Use contained in the NEP as of 2017, and which applies to this appeal is as follows:
Existing use: The legal use of any land, building or structure for a purpose that is not otherwise listed as a permitted use under the applicable designation in the Niagara Escarpment Plan, and that was:
a) existing on the day of approval of the Niagara Escarpment Plan, June 12, 1985;
b) approved in accordance with the provisions of the Niagara Escarpment Plan since June 12, 1985 but prior to the date of any amendment to this Plan under which the use ceased to be a permitted use; or
c) existing, in an area added to the Niagara Escarpment Plan at the date of the approval of the amendment to this Plan that added the lands to this Plan;
provided that the existing use has continued without interruption after the effective date as set out under a), b), and c).
10Additionally, the following Rules of Practice of the Environmental Review Tribunal (“Rules”), applicable to matters before the NEHO, apply to the requests for status and the motion:
- The following persons are Parties for the purpose of the Rules:
(a) persons specified as Parties by or under the statute under which the proceeding arises;
(b) persons otherwise entitled by law to be Parties to the proceeding; and
(c) persons who request Party status and are so specified by the Tribunal as Parties for all or part of the proceeding, and on such conditions as the Tribunal considers appropriate.
- In deciding whether to name a person as a Party to the proceeding, the Tribunal may consider relevant matters including whether:
(a) a person's interests may be directly and substantially affected by the Hearing or its result;
(b) a person has a genuine interest, whether public or private, in the subject matter of the proceeding; and
(c) a person is likely to make a relevant contribution to the Tribunal's understanding of the issues in the proceeding.
The Tribunal may name persons to be Participants in all or part of a proceeding on such conditions as the Tribunal considers appropriate. A Participant to a proceeding is not a Party to the proceeding. In deciding whether to name a person as a Participant, the Tribunal may consider whether the person’s connection to the subject matter of the proceeding or issues in dispute is more remote than a Party’s would be. A person who may otherwise qualify as a Party may request Participant status.
The Tribunal may name persons to be Presenters in all or part of a proceeding on such conditions as the Tribunal considers appropriate. A Presenter to a proceeding is not a Party to the proceeding. In deciding whether to name a person as a Presenter, the Tribunal may consider whether the person’s connection to the subject matter of the proceeding or issues in dispute is more remote than a Party’s or Participant’s would be. A person who may otherwise qualify as a Party or Participant may request Presenter status.
A Party bringing a motion to dismiss an appeal of a development permit shall specify the basis for the motion, which may include that:
(a) the appeal does not disclose a planning justification for the appeal, is not in the public interest, is without merit, is frivolous or vexatious or is made only for the purpose of delay;
(b) the notice of appeal did not specify the reasons for the appeal;
(c) the person who appealed the decision has not responded to a request by the Tribunal for further information within the time specified by the Tribunal; or
(d) the proceeding relates to matters that are outside the jurisdiction of the Tribunal.
a. Requests for Status
11During the PHC, and on consent of the parties, the NEHO granted Mr. Hann, Ms. Nuffield and Mr. Stark Party status on the appeal in accordance with Rule 62(c) of the Rules. Similarly, as requested and on consent of the Parties, the NEHO added Mr. Thompson as a Participant in accordance with Rule 66 and Mr. Jowett as a Presenter in accordance with Rule 69. All of those granted status during the PHC demonstrated a genuine interest in the subject matter of the appeal and were found to likely make a relevant contribution to the NEHO’s understanding of the issues in this proceeding.
b. Lateness of Richard Stark’s Reply Submissions
12The Snowmobile Club wrote to the NEHO on June 24, 2019 to inquire as to whether Mr. Stark’s motion would be considered by the NEHO given Mr. Stark’s late filing of reply submissions.
13The Hearing Panel notes that it is not a requirement that reply submissions be filed. Even if the Hearing Panel were to determine that it would not consider Mr. Stark’s reply submissions, his main submissions and filings remain to be considered by the Hearing Panel.
14The question is whether the Hearing Panel ought to permit the late service and filing of reply submissions by Mr. Stark. In these circumstances, Mr. Stark has provided an explanation for his late service and filing of his reply submissions. Additionally, there is no allegation that the other parties are prejudiced by Mr. Stark serving his reply submissions two days late and filing them four days late. As a result, the Hearing Panel exercises its discretion to permit the late service and filing of the reply submissions, and will consider them as part of the submissions to be considered on this motion.
c. Motion to Strike
15There is no dispute that the Escarpment Natural Area designation applicable to the Subject Site does not permit a use for motorized vehicles, including snowmobiles. In order for the development permit to be considered therefore, it must be shown that the snowmobile trail is an Existing Use as defined by the NEP. In its appeal, and on this motion, the Snowmobile Club submits that it will lead evidence at a hearing to demonstrate that the snowmobile trail has been “maintained, groomed and signed” since 1968, and the proposal relates to that use. On the other hand, in summary, Mr. Stark and the NEC submit on this motion that the question of whether the snowmobile trail is an existing use was determined by the NEHO and in the decision of the Minister in 2006 and should not be considered a second time by the NEHO on this appeal.
16The NEHO’s February 1, 2006 report to the Minister followed a one-day hearing held on December 1, 2005. As set out in the report, the Hearing Officer heard evidence from various parties, including Mr. Stark and the Snowmobile Club as agent for Grey Highlands, and assessed the issue of whether the snowmobile trail at the Subject Site was an Existing Use as it was defined in the NEP at that time. After considering the evidence and submissions of the parties, the Hearing Officer recommended to the Minister that the decision of the NEC to conditionally approve a development permit to allow for the installation of two in-stream culverts and river crossing should not be confirmed, as a result of the following findings:
a. The use as a snowmobile trail had been abandoned in about 1995 with the exception of the winter of 2004-2005 when grooming and maintenance had occurred.
b. The 2004-2005 grooming and maintenance was an illegal use as the Existing Use had previously been abandoned.
c. Alternatively, even if the use could be considered an Existing Use, the installation of culverts would be an expansion of an Existing Use that does not meet the Development Criteria in the NEP applicable to the expansion of Existing Uses.
Submissions of Richard Stark
17On the basis of these findings made by the NEHO in 2006 and concurred in by the Minister, Mr. Stark submits that this appeal should be dismissed.
18Mr. Stark submits that the applicant on this appeal, the location, and the proposed use are in essence identical to what was considered by the NEHO in 2006 report. He submits that the issue on this appeal is whether or not the snowmobile trail is an Existing Use as defined by the NEP and that this issue had already been thoroughly considered and determined by the NEHO in its 2006 report. Mr. Stark submits that to allow the facts to be re-considered now, 14 years later, raises an issue of fairness, creates an unnecessary burden on the public, and puts the public at a significant disadvantage since witnesses’ memories of the use of the trail have become dated.
19Mr. Stark also references the revised 2017 definition of Existing Use in the NEP which he submits is more restrictive, requiring that the Snowmobile Club demonstrate that the use must have been “continued without interruption”. He submits that it is clear from the findings of the NEHO in 2006 that this requirement cannot be met.
20Mr. Stark submits that allowing the appeal to proceed will undermine the NEC’s Development Permit process by allowing unsuccessful applicants to continually reapply. He submits that this is not in the public interest. Mr. Stark submits that the language of the NEPDA is unambiguous at s. 25(14) that the Minister’s decision is final and there is no appeal from that decision. He submits that a final decision of the Minister should not be allowed to be circumvented by a previously unsuccessful application being re-applied for based on the same proposal and on the same facts.
21Mr. Stark submits that the Snowmobile Club repeats a statement of alleged facts regarding Existing Use but fails to identify how the NEHO erred in its previous report and why any such errors should be reconsidered at this time.
22Mr. Stark references and relies on the decision of the NEHO in Bolton v Ontario (Niagara Escarpment Commission), 2016 19447 (ON ERT) where the NEHO dismissed the appeal, finding at paras. 34 and 36 that the appeal lacks a planning justification and should not proceed.
23Mr. Stark submits that the NEC is a delegate of the Minister’s decision making power under s. 25(1) of NEPDA and is subject to the Minister’s prior decision on an identical matter. By extension, Mr. Stark submits, the NEHO does not have the jurisdiction to hear this appeal.
24Mr. Stark concludes by requesting that the appeal be dismissed or that the NEHO refuse to hear it on grounds that the appeal is not in the public interest, is without merit, and is frivolous or vexatious. Further, he submits that the appeal should be dismissed as it does not specify the reasons for the appeal.
Submissions of the NEC
25In support of the motion filed by Mr. Stark, the NEC submits that the current proposal is for the construction of one culvert, somewhat larger than the two culverts previously proposed in 2005 at the same location as was considered in the 2006 decision. The NEC explains that NEC staff recommended refusal of the application because it is not a permitted use and was found not to be an existing use in the 2006 decision and also because it does not meet the development criteria in the NEP.
26The NEC submits that in deciding whether the test set out in s. 25(8.1)(a) is met, the NEHO may consider the doctrine of abuse of process. A subset of that doctrine is the doctrine of issue estoppel which may apply to the decisions of administrative tribunals, relying on Penner v. Niagara Regional Police Services Board, 2013 SCC 19, Penner v. Niagara Regional Police Services Board, 2010 ONCA 616 and Darcie v. Niagara Escarpment Commission, [2008] O.E.R.T.D. No. 44 (“Darcie”).
27The NEC submits that the criteria that are to be applied in determining whether issue estoppel applies to a decision of an administrative body are:
a. was the earlier decision a final decision;
b. were the parties to the earlier proceeding the same as the parties to the current proceeding;
c. is the issue to be decided the same as was decided in the earlier proceeding; and
d. even if the tests in a. to c. are satisfied, in the interests of fairness should the tribunal exercise its discretion to not apply the doctrine.
28The NEC submits that where the criteria for issue estoppel are not technically met but the circumstances warrant, the earlier decision may form the basis of a finding that the current proceeding is frivolous, vexatious and not in the public interest. For example, even where the party asserting issue estoppel was not a party to the earlier proceeding he or she may argue successfully that the re-litigating of the same issue by the other party is frivolous, vexatious and not in the public interest: Hynes v. Niagara Escarpment Commission, 2000 CarswellOnt 6383 (“Hynes”).
29The NEC submits that the criteria for the application of issue estoppel and therefore abuse of process are met in this case, as the decision of the Minister was final, the parties to this proceeding were parties to the previous proceeding, the issue raised in both cases is whether the snowmobile trail to which the proposed development relates is an existing use as defined in the NEP, and there are no circumstances which would make it unfair to apply the doctrine of issue estoppel to this case.
30The NEC submits that while there is a change in the nature of the development from two smaller culverts to one larger culvert (or to a removable, temporary platform structure), this change is not material, since either proposal, in order to succeed, would have to be based on the snowmobile trail being permitted as an Existing Use under Part 1.3 of the NEP. The NEC submits that the central finding in the Hearing Officer’s 2006 report was that there had been no maintenance of the snowmobile trail from 1995 to 2004 and on that basis, he concluded that the use had been abandoned and was no longer an existing use. The NEC submits that this finding is determinative of the current appeal. The NEC submits that if the snowmobile trail was not an Existing Use in 2006, then it is not an Existing Use today. The NEC submits, relying on Hynes, that any evidence that exists today could, with reasonable diligence, have been raised in the 2005 hearing and that a party will be estopped from bringing forward evidence that was introduced at the previous proceeding as well as evidence that could with reasonable diligence have been brought forward in the earlier proceeding.
31The NEC submits that the current definition of Existing Use now states expressly that a use which has not continued without interruption will not be considered an existing use. Based on a hiatus of use from 1995 to 2004, the use was found by the Hearing Officer in 2006 to be abandoned. As such, it has not continued without interruption, which would be required to meet the current definition.
32The NEC submits that the NEHO has the discretion not to apply the doctrine of issue estoppel where it would be unfair to do so. Equally, the Hearing Office, it is submitted, has discretion to exercise authority under s. 25(8.1) of the NEPDA depending on the fairness of the matter. Relying on the Darcie case, the NEC submits that no facts have been raised that give rise to unfairness if the appeal is dismissed without a hearing.
33In conclusion, the NEC submits that it would be appropriate in these circumstances for the NEHO to dismiss the appeal without a hearing as it would be an abuse of process and therefore not in the public interest to allow an appeal to proceed on the very issue that was considered and decided in the 2006 decision. The NEC relies on the decision of the NEHO in Hynes where it was determined that a subsequent appeal on grounds that were decided in an earlier identical appeal is considered vexatious.
Submissions of the Snowmobile Club
34In response to Mr. Stark’s motion, the Snowmobile Club submits that it intends to prove the snowmobile trail existed prior to 1985 when the NEP came into effect and was never subsequently abandoned from 1995 to 2004. It intends to show at a hearing that the trail was continually maintained during this period and the only reason it was not groomed or staked in some years was the lack of snow and the potential for damage to crops, fields and the potential for angering local landowners.
35The Snowmobile Club submits that the definition of an opened unmaintained road allowance in Ontario under the Highway Traffic Act is that the road is a highway. Therefore, it submits, the definition of an opened unmaintained road allowance allows for a motorized trail, and the Snowmobile Club should be able to use this road allowance just as it is permitted to use any road in Grey Highlands.
36The Snowmobile Club submits that it will prove the trail was never abandoned between 1995 and 2004, by bringing new evidence to a hearing that was not at the previous appeal in 2005, consisting of the follow:
a. A retired police officer who patrolled the trail in 1985 and rode the trail from 1995 to 2004.
b. The groomer driver/coordinator who was in charge of the trails for the club from 1997 to 2004.
c. Snowmobilers/Club volunteers who rode or staked the trail from 1995 to 2004.
37The Snowmobile Club submits that it had not led evidence to rebut the evidence of witnesses who had testified during the 2005 hearing that the trail had been abandoned, and that the Hearing Officer did not give specific years the trail was abandoned in his report, but rather, only found that it was between 5 and 10 years sometime between 1995 and 2004.
38The Snowmobile Club also stresses that there is a significant safety and environmental concern at issue with not having a crossing at the Subject Site, as all-terrain vehicles, trucks and other motorized vehicles, as well as pedestrians, are traveling through the Beaver River tributary on a daily basis. They submit that a solution is needed to protect the tributary.
Reply Submissions of Richard Stark
39In reply, Mr. Stark submits that historical weather data records kept by the Government of Canada for the weather station at Thornbury, Ontario indicate that the average annual snowfall during the 10 year period from 1995-2004 was within 3% of the annual average snowfall for the period 10 years prior (1985-1995) and within 5% of the overall 20 year average 1985-2004, and that the same data analyzed in five year increments shows an even smaller variation. He submits that the argument that the abandonment of the use was a result of lack of snow is without merit.
40Mr. Stark also submits in reply that even if use prior to 1985 had been established at the 2005 hearing, the finding was made that it had been subsequently abandoned. It follows, he submits, that this does not qualify as a new planning justification for appeal and the principle of issue estoppel applies to this intended argument.
41With regard to municipal road allowances, Mr. Stark submits that municipalities and their lands are subject to the policies of the NEP, and that s. 13(1) of the NEPDA is a complete answer to the argument regarding use and the definitions under the Highway Traffic Act.
42Regarding the “new evidence” the Snowmobile Club intends to call at a hearing, Mr. Stark submits that this evidence was available in 2005 and that the principle of issue estoppel applies not only to matters which were proven in the previous proceeding but also those which might have been proven: Parna et al v G & S Properties Ltd et al, 1973 733 (ON CA), [1973] 2 OR 765 and Darcie.
43Mr. Stark also submits in reply that the failure of Grey Highlands to find a solution to the unauthorized use of the Subject Site may be regrettable, but it should not affect the determination of this appeal.
Discussion, Analysis and Findings
44The Hearing Panel has considered the submissions provided on the motion and finds that the motion should be allowed for the following reasons.
45The Hearing Panel agrees with the submission of the NEC that in deciding whether the test set out in s. 25(8.1)(a) is met, the Hearing Panel may consider whether the appeal can be considered an abuse of process, a subset of which is the doctrine of issue estoppel. The Panel is also in agreement with the NEC and Mr. Stark that this is a situation where issue estoppel applies for the following reasons.
46First, the 2006 Decision of the Minister was a final decision. The Minister’s Decision brought finality to that particular appeal process.
47Second, the parties to the 2005 hearing are the same parties that now come before the NEHO on this appeal, with the Snowmobile Club, in effect, acting as agent for Grey Highlands in both cases.
48Third, although there may be a marginal difference in the proposed development and the one previously decided, the main issue to be decided in this case is identical to the question determined by the NEHO in 2006 and concurred in by the Minister in his final decision: whether the underlying use as a snowmobile trail can be considered an Existing Use as defined in the NEP. The language of the NEP since 2017 has created a tougher hurdle for the Snowmobile Club in this regard, by adding that an Existing Use must have been continued without interruption since 1985. This question has been determined by the Hearing Officer in his report and in the concurring Decision of the Minister of 2006.
49Fourth, the Snowmobile Club may wish to raise evidence beyond what was provided to the NEHO at the 2005 hearing, but that is an insufficient basis to ground an argument that it is in the interests of fairness for the Hearing Panel to exercise its discretion to not apply the doctrine of issue estoppel. It would run contrary to the interests of fairness to require the other parties to muster evidence, prepare for, and attend a hearing, on an issue that has already been decided. The Hearing Officers agree with the NEC and Mr. Stark that the Snowmobile Club should be precluded from raising evidence that, with reasonable diligence, could have been raised during the 2005 hearing, and that the Snowmobile Club should be estopped from doing so. The Hearing Panel would situate the issue of legal definitions under the Highway Traffic Act in the same basket as the proposed new evidence. The issue of permitted uses under the Highway Traffic Act, vis-à-vis the permitted uses under the NEP, could have been raised during the 2005 hearing. The Snowmobile Club has not met its onus of proving that the evidence and issues it seeks to raise at a hearing could not have been raised in 2005.
50Similarly, the issue of motorized use of the opened unmaintained road allowance by others is a matter for consideration in other venues: through the development permit application or NEC enforcement processes for example. The Hearing Panel finds that the use by other motorized users and the problems that this may create does not give rise to fairness considerations that the Hearing Panel must consider in exercising the discretion not to apply the doctrine of issue estoppel.
51In conclusion, it appears that this is a situation where the Snowmobile Club believes that with improved evidence and legal submissions, they may obtain a different result before this Hearing Panel than they did in 2006. Unfortunately for the Snowmobile Club, the doctrine of issue estoppel is intended to apply to prevent parties from seeking to do just that, with an expectation that each party put their best foot forward at their first opportunity unless some special circumstances exist that prevents them from doing so.
52Having made the above findings, the Hearing Panel determines that the motion is allowed and that this proceeding is dismissed under s. 25(8.1)(a) of the NEPDA. Finally, as required by s. 25(8.3) of the NEPDA, the Hearing Panel also confirms the decision of the NEC to refuse the development permit.
DECISION
53The Hearing Panel orders that:
a. The motion filed by Mr. Stark is allowed;
b. In accordance with s. 25(8.1)(a) of the NEPDA, the appeal is dismissed and the decision of the NEC to refuse the development permit is confirmed.
Motion Allowed
Appeal Dismissed
NEC Decision Confirmed
“Marlene Cashin”
MARLENE CASHIN
HEARING OFFICER
“Justin Duncan”
JUSTIN DUNCAN
HEARING OFFICER
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Niagara Escarpment Hearing Office
A constituent tribunal of Tribunals Ontario - Environment and Land Division
Website: www.elto.gov.on.ca Telephone: 416-212-6349 Toll Free: 1-866-448-2248