¶ 14. dissenting. The majority has failed to grasp the importance of the issue we confront in this case, that is, the appropriate legal structure for allocating parental rights and responsibilities between unmarried parents who live separately, when there is no family court order in effect and one party is indisputably the primary care giver. I would reverse because the trial court erroneously failed to agree with the parties that mother was the primary care giver of a preschool child; therefore it accorded no weight to that factor in determining the best interests of the child in a close case. The primary care giver doctrine is particularly relevant when the parties are unmarried and have de facto arrangements of custody and visitation. If it is applicable, as it is here, it is the only factor that acts as a cautionary barrier to a change in custody. *19Because close scrutiny of requests to change custody has long been a mainstay of our family law jurisprudence, I respectfully dissent.
¶ 15. Ms. Porcaro and Mr. Drop met at a plastics factory in Rutland, Vermont, where they both worked. They have one child, who was bom in April 1996. At the time, the parties were in an ongoing relationship and lived together in father’s parents’ home. Mother initially took an eight week leave from work to care for the infant. When she returned to work, the child went to day care. In the spring of 1997, the parties moved into an apartment of their own in Rutland. During this period, mother cared for the child during the day and worked the third shift at the factory. Father would care for the child at night, while mother worked. In May 1999, the parties moved out of the apartment they were sharing and the relationship ended. Mother moved with the child into her mother’s home and father returned to his parents’ home.
¶ 16. In October of that year, the Rutland Family Court issued a temporary order regarding parental rights and responsibilities, based on the parties’ stipulation. That order called for the parents to have joint legal custody, while mother would have sole physical custody of the child. Father would have contact with the child two weekday evenings and one overnight on the weekends, and time on holidays would be split approximately equally. The order explicitly stated that it was temporary and would remain in force until further order of the court.
¶ 17. In the winter of 1999-2000, the parties attempted areconciliation. Father moved in with mother in her apartment in Rutland. By March 2000, that attempt failed and father moved out, and the parties reverted to the parent-child contact schedule of the temporary order. In the spring of 2000, mother met Maco Stewart over the Internet. Mr. Stewart resides in Los Alamos, New Mexico, where he is employed by the federal government. After two meetings and extensive contact on the Internet with Mr. Stewart, mother moved to Los Alamos with the child in June 2000. Shortly thereafter, mother was engaged to Mr. Stewart, whom she has since married. Because of the move, fatherwas unable to see the child on the weekly schedule the parties had adopted.
¶ 18. In response to several motions filed by father in an attempt to resume contact with the child, the family court held several days of hearings on the issue of parental rights and responsibilities. After hearing testimony from both parents, as well as several witnesses for each, the court issued findings and conclusions. The court’s findings, twenty-three short sentences, were extremely sparse and do not begin to reflect the character of the relationships as revealed by the transcripts of two full days of testimony. In its conclusions, the court determined that because *20the order of October 1999 was temporary, parental rights and responsibilities for the parties had never been conclusively determined. The court, therefore, set out to determine the parental rights and responsibilities based on 15 V.S.A. § 665(b), which directs a court to determine the best interests of the child based on nine factors. The court determined that it is in the best interests of the child for father to have sole physical custody with mother entitled to parent-child contact.
¶ 19. With respect to the primary care giver, the court concluded without discussion that, “[tjhough Ms. Porcaro was initially the primary care giver, this has changed over time to become more equal between the parties.” The trial court’s findings of fact are entitled to deference and will not be set aside unless clearly erroneous. V.R.C.P. 52(a)(2); Nickerson v. Nickerson, 158 Vt. 85, 88-89, 605 A.2d 1331, 1333 (1992). Indeed, the majority opinion is based on the acceptance of the court’s finding that neither parent was the primary care giver. But, I cannot agree with the majority that this finding has any support in the record. Moreover, the finding is contradicted directly by the testimony of the parties, including father, and was conceded by father’s counsel on oral argument before this Court.
¶20. Attrial,fatheracknowledgedthatmotherwasthechild’sprimary care giver. For instance, on direct examination father was asked:
Q: There’s been a question as to who was the primary care giver of [the child] during his life. Um, do you have any opinions in that regard?
A: Um, I agree that Melissa was strongly the larger care giver than I was.
On cross-examination on the same point father was asked:
Q: Now, I believe you stated that, um, Melissa was the primary care giver during... the entire relationship up through to the time she left in June; is that correct?
A: Okay.
In fact, the transcript reveals that for each relevant period in the couple’s history, both when they lived together and apart, father admitted that mother was the primary care giver. Additionally, the temporary order gave sole physical custody to mother, with father to have visitation. That order was the basis for the parties’ parent-child contact at all times when the parties were not living together, and it was entered into by stipulation of the parties. Based on the uncontroverted record evidence, there is no *21basis to uphold the trial court’s determination that there was no primary care giver.
¶ 21. The question presented, then, is whether the failure to find that mother was the primary care giver makes a difference in this case. Section 293 of Title 15 allows the family court to determine parental rights and responsibilities and parent-child contact “[wjhen parents of minor children... whether said parents are married or unmarried, are living separately [and] on the complaint of either parent.” 15 V.S.A. § 293(a). When the court’s jurisdiction is based on § 293, the court applies the statutory framework of § 665(b), even though the best interests determination of § 665 was designed to determine the parental rights and responsibilities for married parents who are separated or divorced. See Bissonette v. Gambrel, 152 Vt. 67, 69, 564 A.2d 600, 601 (1989) (upholding trial court’s use of § 665(b) factors to determine custody of child). Section 293 places no limitation, other than establishing parentage, on when or under what circumstances an unmarried parent may involve the family court in the custody of the child, regardless of any de facto custody arrangement the parties may have. In other words, § 293 sets no bar or threshold determination for the court to make before it applies the multifactored analysis of § 665.
¶ 22. In contrast, in other settings where a more formal custody arrangement already exists (i.e., a final court order), a parent must show a “real, substantial and unanticipated change of circumstances” before a court will reexamine the allocation of parental rights and responsibilities according to § 665.15 V.S.A. § 668. This prevents a court from getting involved in a family where there already is a parenting arrangement, and potentially disrupting that arrangement, without requiring the person seeking the change to identify some event or circumstance that requires altering the status quo. See Kilduff v. Willey, 150 Vt. 552, 553, 554 A.2d 677, 679 (1988) (noting, in relation to the predecessor statute to § 668, that “custody ought not to be modified without critical justification” because of the importance of stability in a child’s life).
¶ 23. Most of the factors of § 665 require the court to compare the two parents relative to each other with no one factor weighing more heavily than another. The one exception is § 665(b)(6), which calls on the court to evaluate “the quality of the child’s relationship with the primary care provider, if appropriate given the child’s age and development.” 15 V.S.A. § 665(b)(6). For this factor, we have consistently held that if there is a primary care giver, that factor must be given greater weight, and the burden on the nonprimary care giver is higher to establish a basis for switching the child’s physical custody. In Harris v. Harris, 149 Vt. 410, *22418, 546 A.2d 208, 214 (1988), we established that the primary care giver factor “should be entitled to great weight unless the primary custodian is unfit.” Although we declined to create a per se rule in favor of the primary care giver, the result in Hams requires “the court to look carefully at the desirability and impact of changing the primary custodian.” Id. Thus, once one parent has been identified as the primary care giver, the court may no longer consider the parties to be on the equal footing they were on when the § 665(b) inquiry began. See Nickerson, 158 Vt. at 89, 605 A.2d at 1333 (court must give due consideration to primary custodian in evaluating child’s best interests); Bissonette, 152 Vt. at 69, 564 A.2d at 601 (affirming award of custody of child bom out of wedlock to mother because her role as primary custodian outweighed other factors that were unfavorable to her).
¶ 24. In cases such as this, when an unmarried parent’s desire to have custody over a child would replace a long standing de facto custody arrangement,3 the added weight accorded the primary care giver is the crucial element that ensures that courts do not disrupt existing custody relationships simply by comparing one parent to the other, without special reference to the custodial history. The primary care giver doctrine recognizes the need for stability in a child’s life, and that it is likely to be in the child’s best interest to remain with his or her primary care giver. Because § 293 gives virtually unrestricted access to family court for unmarried, separated parents, the primary care giver inquiry functions as an important gate keeper, much the way § 668 does, to require some added burden on the one seeking to change the existing arrangement. “Otherwise, if moved on the basis of only momentary changes of advantage or benefit, children might be rendered totally insecure by frequent switches in home and custody.” Kilduff, 150 Vt. at 553-54, 554 A.2d at 679.
¶ 25. Asa consequence, the trial court erred when it balanced the nine factors of § 665 because it did not accord any added weight to the primary care giver inquiry.4 Although we have stated that it is difficult to determine exactly how much weight this factor ought to be accorded, “the court should ordinarily find that the child should remain with the primary custodian if that parent is fit.” Harris, 149 Vt. at 419, 546 A.2d at 214. Certainly, there is no evidence that mother is unfit. Cf. Rutherford v. Best, 139 Vt. 56, 61, 421 A.2d 1303, 1306 (1980) (under guardianship statutes, to *23find a parent “unsuitable,” there must be a showing “that the child has been abandoned or abused by the parent, or that the child is without proper parental care or subsistence, education, medical, or other care necessary for his well-being”). The trial court acknowledged that this was a very close case, stating at the end of the first day of testimony that “it’s very apparent... that both parents are good parents and both parents care very deeply about their child____[B]oth have the ability to... raise the child.” The court’s decision, therefore, was the result of a simple balancing of evidence in a close case. Because the court found to the contrary, there is no mention of according a primary care giver greater consideration.
¶ 26. Although the trial court is accorded wide deference on review of custody determinations, Nickerson, 158 Vt. at 88, 605 A.2d at 1333, when the court found both parties to be loving parents who could provide a suitable home for the child, the added weight that ought to have been accorded to the primary care giver could have altered the result. Father was chosen only because the court perceived that mother’s relationship with Mr. Stewart “indicate[s] the lack of stability in her life.” The court did not identify any other reasons, based on the § 665(b) factors, for its result. This narrow finding, without more, may have been enough to justify giving father custody in an equal determination. This rationale, however, is not sufficient to warrant a determination in father’s favor when mother should have been given the extra consideration due her.
¶ 27. In my view, the majority s holding jeopardizes the importance of our well-established primary care giver doctrine. If the doctrine does not have an impact in a case with these findings, then I can imagine no case where the status of primary care giver would ever have influence over the ultimate outcome. That is contrary to our law, and I respectfully dissent.
Indeed, this custody arrangement is to some degree a de jure one because of the temporary order, which gave mother sole physical custody and joint legal custody to both parties.
Even if the court’s finding could be interpreted to mean that mother was the primary care giver, the court still failed to accord this finding added weight as required by Harris.