*1197DISSENTING OPINION BY
Judge COLINS.I must respectfully dissent from the majority opinion, as I do not believe that Fell should control in the instant matter.
The Department couches the first issue before this Court as a question of whether the Deklinskis submitted sufficient evidence to fit within the first exception to a registration suspension. However, that question becomes relevant only when the Department satisfies its initial burden. Although the trial court’s opinion does not acknowledge the above noted burdens, it is clear that the trial court found the Department’s evidence insufficient to sustain the registration suspension. With this in mind, we must proceed to evaluate whether the parties satisfied their respective burdens.
The Department submits that it met its initial burden through the submission of its certified documents. Specifically, the Department asserts that the document labeled “SUSPENSION INQUIRY DE-TAIL1” established that Allstate terminated the Deklinskis’ policy on March 9, 2006. In support of that position, the Department argues that the document
shows that the ‘DETERMINATION DATE’ as reported by Allstate for the cancellation of the Deklinskis’ policy of insurance was ’03/09/06’ (R.R. 54a). The ‘TERM[INATION] REASON’ was for ‘NON PYMNT,’ i.e., nonpayment of the premium. Id.
(Brief of Department at 26). The Department continues that the document is the same electronic transmission sent to the Department by Allstate.
After reviewing the document titled “SUSPENSION INQUIRY DETAIL1” it is clear that the document, standing alone, is not sufficient to establish that Allstate terminated the Deklinskis’ insurance policy on March 9, 2006. The document does not contain a termination date. In fact, contrary to the Department’s insertion of the word in the above quoted passage, the actual word “termination” does not appear anywhere in the document. Instead, the document lists “DETERMINATION DATE: 03/09/06” without any further explanation. The document also lists other cryptic references, such as, “SOURCE: CA CANCEL” and “STATUS: P PENDING.” Moreover, as exhibited in the above quoted passage, these references are not clear without additional explanation or context. However, before the trial court, the Department relied solely on the information contained in the document and it cannot now give meaning to the terms through counsel’s arguments. See Grover v. Department of Transportation, Bureau of Driver Licensing, 734 A.2d 941, 944 (Pa.Cmwlth.1999). Consequently, the Department’s certified documents, as presented to the trial court, were not sufficient to satisfy the Department’s initial burden.
Because the Department failed to establish that insurance coverage on the Dek-linskis’ vehicle was terminated on March 9, 2006, the burden never shifted to the Dek-linskis to prove otherwise. Nevertheless, the trial court credited Mrs. Deklinskis’ testimony that any lapse that may have occurred was for less than 31 days and during that period the vehicle was not driven. Accordingly, the trial court’s decision, sustaining the Deklinskis appeal and reversing the vehicle registration suspension, was supported by substantial evidence.
The Department’s assertion that the trial court abused its discretion by sustaining the Deklinskis’ statutory appeal to help them avoid economic hardship must also be rejected. Although I agree with the Department that economic hardship is not *1198a basis for sustaining an appeal, Banks v. Department of Transportation, Bureau of Motor Vehicles, 856 A.2d 294 (Pa.Cmwlth.2004), the Department has offered no evidence to support its position.
Since the trial court accepted the Dek-linskis’ testimony and evidence as credible, it is my judgment that this Court is substituting its factual determinations for those of the trial court.
Judge FRIEDMAN joins in this dissenting opinion.