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Different methods of defining building penetration loss for high elevation angle paths exist. A key factor is the selection of the reference level. A comparison of four of the most common types of reference levels used to determine building penetration loss for high elevation angles is presented based on a measurement trial using unmodulated carriers at 2.0 GHz and 5.0 GHz performed at a three-storey office building. It was shown that the choice of reference level significantly affects the results obtained. Particular cases are discussed and general recommendations on the selection of the reference level for building penetration loss measurement are provided.