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Case 1:19-cv-12333 Document 1 Filed 11/13/19 Page 7 of 21 <br /> neighborhoods, including the communities of New Seabury, Seabrook, Monomoscoy Island and <br /> Popponesset Island(the"Coverage Gap"). <br /> 50. Verizon Wireless and T-Mobile are experiencing increased network capacity in this area of south <br /> Mashpee and as a result,the existing personal wireless service facilities are burdened,calling for a <br /> new facility to off-load capacity. <br /> 51. The existence of the Coverage Gap and capacity issues led Verizon Wireless and T-Mobile to enter <br /> into agreements with Blue Sky to co-locate on the Proposed Site. <br /> 52, The Coverage Gap and capacity needs have been documented and established by Blue Sky,Verizon <br /> Wireless and T-Mobile through multiple scientific,industry standard methods. <br /> 53. Verizon Wireless and T-Mobile.each independently conducted computer-based Radio Frequency <br /> Propagation Studies that showed a lack of coverage for this area. <br /> 54. These studies consider coverage and capacity needs from existing wireless facilities in this area <br /> and show predicted coverage with and without the proposed 150=foot monopole. <br /> 55. These studies show a significant Coverage Gap and capacity need for both carriers in this area. <br /> 56. The Coverage Gap was further demonstrated through"drive-test data"provided for both Verizon <br /> Wireless and T-Mobile,which collects and measures actual radio frequency signal strength for each <br /> carrier as a vehicle travels along specific roads. <br /> 57. The drive test data confirmed that neither Verizon Wireless nor T-Mobile has adequate signal <br /> strength in the area of the Coverage Gap. <br /> 58. The Coverage Gap was also fully reviewed and confirmed by the Cape Cod Commission's <br /> independent wireless expert,Isotrope,LLC. <br /> 59. Isotrope, LLC reviewed all of the studies and drive-test data together with additional data that it <br /> requested regarding location, height and the interrelationship with existing sites and the <br /> Commission:confirmed the need for the Proposed Site at the requested height and location. <br /> 60. The Coverage Gap is physically large and affects'a substantial number of users. <br /> 7 <br />