1 The significant gap in coverage also includes approximately 0.4 square miles of the residential <br />2 areas around the proposed site as shown on the attached Exhibit 1 to Littlefield Declaration, and the <br />3 lack of reliable indoor coverage constitutes a significant gap in coverage. In addition, Amazon <br />4 Drive is a minor arterial road in the City. According to the City of Eugene 2013 Traffic Flow Map <br />5 available on the City's web site, there are a significant number of vehicle trips on a typical weekday <br />6 through the proposed coverage area, <br />7 East Amazon Drive: 7,900 <br />8 West Amazon Drive: 6,400 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />Hilyard (S. of intersection with Amazon Drive): 12,700 <br />Total average weekday trips on three of the area's roads: 27,000 <br />See: Exhibit 2 to Littlefield Declaration. <br />The gap in AT&T's indoor, in-vehicle and outdoor service is substantially greater than a few <br />blocks or a mere dead spot, and there is significant traffic volume through the area to be covered. The <br />gap in AT&T's service in the proposed coverage area is a significant gap. <br />I personally reviewed the RF Justification and the Addendum for AT&T's Personal <br />Communications Service network in the Eugene area and the data therein, and I reviewed the attached <br />project narrative detailing the technical requirements for the site and the alternatives analysis. AT&T <br />uses several methods to analyze the need to add more capacity to its Personal Communications <br />Service network. These methods include scientifically and mathematically based computer modeling, <br />customer complaint data, and the number of microcells deployed by AT&T's customers in a given <br />geographic area. <br />Computer Modeling. AT&T uses Atoll computer modeling software provided by Forsk <br />Incorporated, headquartered in France with offices in the United States and China. More than 450 <br />24 customers in 115 countries use the Atoll computer modeling software. Atoll is a wireless coverage <br />Declaration of Vicki Littlefield <br />CU 14-3 <br />Page 4 <br />