reasons. The calibration of "bars" to actual signal strength is not consistent across <br />various equipment manufacturers, or even among different handsets produced by the <br />same manufacturer. To demonstrate this, I placed an HTC phone on a desk next to an <br />Apple Phone. (Both were on the AT&T system). At this common location, the HTC <br />phone indicated 5 bars, the Apple showed 3 bars. In addition, there is no mechanism <br />available which would allow a casual user to determine which technologies and/or <br />frequency bands were being measured. In other words, Mr. Collinge's data doesn't and <br />can't tell us if he was measuring the 3G UMTS signal or the 4G LTE signal. Moreover, it <br />does not identify the origin of the signal(s) he observed. This is significant because one <br />of the older facilities currently providing some service to this coverage area will be <br />removed from service in the near future to address interference problems. Mr. Collinge <br />may well have been measuring the signal from this soon to be retired facility. <br />Lack of sufficient data points <br />Looking at the number of bars on a cell phone taken at a dozen points within a proposed <br />coverage area of several square miles provides insufficient data on which to form any <br />conclusion regarding coverage. An actual drive test, as conducted within the industry, <br />employs an automated, calibrated receiver capable of taking multiple field strength <br />readings per second, on multiple frequencies. Each of these readings is tagged with <br />location data from a GPS receiver to facilitate post processing and mapping. This <br />receiver is in operation in a vehicle as it drives (hence the term "drive test") as much of <br />the area under study as possible. At a minimum, all major and secondary roads within <br />the study are would be driven. Even a simple drive test covering a relatively small area <br />will result in literally thousands of data points. AT&T's practice is to conduct a drive test <br />Declaration of Thomas Gorton 2 <br />CU 14-3 <br />