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through its third-party consultant that would allow the City to verify the veracity of their information. The CMS report indicates that if the applicant provided simple information and certified the accuracy and truthfulness of the submitted information, an independent reviewer such as CMS couldeasily verify the accuracy of the modeling information and propagation maps. The CMS report also indicates that propagation maps are only predictive models that may not reflect the actual real-world conditions. The only certainty in predictive modeling is a “drive test”, as stated by CMS, “the test of proving that something is unfeasible can only be conclusively proven through the conduct of a drive test”. CMS states that while there is sufficient vertical space for at least one additional array of antennas on the proposed mono-pine, the structural capability of the proposed tower to accommodate additional carriers’ facilities cannot be determined, as there was no structural analysis report provided. CMS also points out that either within or beyond the 2,000 foot radius, no verifiable evidence was provided by the applicant that might have shown whether an existing tower or other type of support structure could or could not be structurally modified to accommodate this provider’s needs. Staff also notes that William Collinge, representative of the Friends of Amazon Creek, submitted evidence from a web chat with an online AT&T sales representative regarding the current cell coverage in the area of 4060 West Amazon Drive (see Attachment 6). In this web chat, the AT&T representative is asked about the coverage in the area and states, “it is showing solid orange coverage, meaning the coverage is very good”. When asked by Collinge about the “G level” the representative states, “it shows full coverage for 4G LTE, 4G, 3G and 2G.” Collinge also provides several maps as examples from the Blanton Ridge site (aka: Rest Haven SR13-5). In AT&T’s submittal, these maps show a lack of coverage in the Amazon Creek area, however, Collinge provides several maps directly from the AT&T website that shows full coverage already exists for this same area in data (4G LTE) and voice. These examples provide further evidence that call into question the applicant’s stated need for coverage in the area. Since the applicant has not adequately demonstrated that alternative sites within a radius of at least 2,000 feetare technologically unfeasible or unavailable, this standard is not met. 3. Evidence demonstrating collocation is impractical on existing tall buildings, light or utility poles, water towers, existing transmission towers, and existing tower facility sites for reasons of structural support capabilities, safety, available space, or failing to meet service coverage area needs. Eugene’s Telecommunication Standards place a priority on collocation as the first option for considering new telecommunication facilities. The applicant indicates they investigated collocation on existing tall buildings, utility or light pole and existing transmission towers, but found no feasible options. In response, the review by CMS states the following: HO Agenda - Page 27