For other cases holding that proposed relocation requests which would result in the effective termination of a shared physical
custodial arrangement should be treated as a modification of custody, see, e.g., Lewellyn v. Lewellyn, 351 Ark. 346, 93 S.W. 3d 681 (2002)(both mother and father petitioned for sole custody of children after mother's proposed relocation would make parties» shared physical
custodial arrangement unworkable; court found that mother's relocation constituted material change of circumstances warranting award of sole custody to father, even
though such a relocation would not be considered a material change in circumstances in a case that did not involve shared physical custody), and In re Marriage of Garst, 955 P. 2d 1056 (Colo..