Comments on the Information Provided <br />Technical Need not proven, i.e. by clear, convincing and verifiable evidence <br />. <br />The application presumes that the intended service area will be covered from a single <br />location/facility. Nothing inapplicable federal law says that a carrier must be allowed to fill a gap in <br />service from a single facility. <br />1 <br />Based on the information provided, the technical needfor a new 75’ tall support structure, to the <br />exclusion of all reasonable alternatives, has not been demonstrated by clear, convincing and/or <br />verifiable evidence. In other words, the applicant has not shown by clear, convincing and <br />verifiable evidence that <br />-there is no way to do what it wishes other than to build a 75’ tall new tower; <br />or that <br />-the selected location is the only location that would at least mitigate or <br />reduce the size of the gap in 4G LTE service and improve the service overall <br />as asserted. <br />Relatedly, there is no way to verify the correctness, accuracy or veracity of what information has <br />been proffered as evidence of the technical need for what is requested vis-à-vis the propagation <br />maps submitted. <br />Propagation maps can easily be manipulated (and all-too-often are) to show a pre-determined <br />desired result or situation. Without the ‘modeling’ informationthat was used to generate the maps, <br />i.e. the variables inputted into the software used, there simply is no way to verify the correctness, <br />accuracy or veracity of the maps submitted. Attached as Exhibit 1 is an example of such a <br />manipulated situation that occurred in the real world vis-à-vis an application, showing how easily <br />propagation maps can be manipulated. <br />Also, propagation maps are notthe only means of determining the technical need for a new <br />facility, or from the Community’s perspective the best and least intrusive way to meet a technical <br />need. Propagation maps are also, by their nature, predictivemodels and don’t necessarily reflect <br />the actual real-world situation. Frequently the real-world situation differs substantially from what a <br />‘modeled’ depiction estimates and depicts the situation to be. It is common for both carriers and <br />tower companies (of their own volition and for their own business purposes) to do ‘Drive Tests’ <br />that do reflect the actual (signal strength/coverage) situationat any point in the [intended] service <br />area, and from that to determine the extent and locations of a given situation. This can show the <br />true size and extent of a gap in service, as well as the signal strength at any point within the <br />driven area. For example, it may show that the fringes of an asserted gap can be, or already are, <br />served from an adjacent site. <br />Given the lack of clear, convincing and verifiable evidence related to the technical need for what <br />has been proposed, the City maywant to consider requiring a ‘Drive Test’ to be done, supervised <br />by a qualified individualto assure valid test results. <br />The narrative of the ‘Coverage Justification’ submitted in this case implies a ‘weak’, unreliable <br />and/or inconsistent signal in the subject area, i.e. one that should be improved. However, none of <br />the propagation maps submitted contain or denote the ‘threshold’ (i.e. minimum needed) signal <br />1 <br />“Need”in this context means what is technologically required for the provision of service (in any substantive <br />portion of the intended service area) and for the user equipment to function as designed by the manufacturer. <br />3 <br />