**Statement of Requests**

**For The**

**Federal Communications Commission**

**Regarding The**

**MCI WorldCom-Sprint Merger**

# TDI

## April 5, 2000

### TDI hereby submits this list of requests to the Federal Communications Commission (FCC) regarding its review of the MCI WorldCom-Sprint merger application. This statement of requests concerning the merger application review is divided into two parts. The first part consists of TDI's requests concerning the MCI WorldCom-Sprint merger generally, and the second part outlines TDI's requests specifically concerning the merged corporate entity as a TRS provider. These requests of the FCC do not reflect any position of TDI either in support of, or opposed to, this proposed merger, but rather are requests that we would hope the FCC could take into consideration during their review of this proposed corporate merger. 

**Requests Concerning The MCI WorldCom-Sprint Merger Generally:**

a)  TDI requests that the FCC ensure that MCI WorldCom-Sprint is
    committed to either maintaining the present level, or increasing the
    level, of funding for research and development (R&D) within the
    merged organization. Corporate mergers frequently result in a
    reduction of total operating costs in order to maximize profits, and
    this all too often includes a reduction in R&D funding. Any
    reduction in R&D funds usually has an adverse impact in the future
    on the availability of accessible products and services for
    individuals with disabilities, including those who are deaf,
    late-deafened, hard-of-hearing, or deaf-blind.

b)  TDI requests that the FCC ensure that MCI WorldCom-Sprint would
    maintain an affirmative action policy regarding hiring of persons
    with disabilities for clerical, specialized, and administrative
    positions. In particular, TDI requests that the FCC ensure that MCI
    WorldCom-Sprint conduct its recruitment and promotion activities so
    as to recruit and retain persons who are deaf, late-deafened,
    hard-of-hearing, or deaf-blind for a wide range of corporate
    positions, including those in management, sales and customer
    relations.

c)  TDI requests that the FCC ensure that MCI WorldCom-Sprint make
    products and services available to its customers in adequate supply
    regardless of geographic location and business or residential
    status. Many Americans with disabilities, especially those who are
    deaf, late-deafened, hard-of-hearing, or deaf-blind, live or operate
    businesses in rural areas. It is important that the merged corporate
    infrastructure be enhanced so as to guarantee that the merged
    corporate entity be able to provide greater access and delivery
    capabilities throughout all of its market areas.

d)  TDI requests that the FCC ensure that MCI WorldCom-Sprint would
    routinely conduct assessments on the telecommunications and
    information needs of individuals with disabilities, including those
    that are deaf, late-deafened, hard-of-hearing, or deaf-blind.

e)  TDI requests that the FCC ensure that MCI WorldCom-Sprint would
    guarantee that any emerging and future telecommunications technology
    distributed to its customers, including people with disabilities,
    would be compatible with any telecommunications technology and
    service currently used by them, or that a period of transition for
    transfer of one technology to another would go orderly and smoothly.
    Furthermore, TDI requests that the FCC ensure that any new product
    or service offering undergoes review and market testing with people
    with disabilities in the design and development stages. This is
    essential to ensure that persons who are deaf, late-deafened,
    hard-of-hearing, or deaf-blind experience functional equivalency
    with the general population.

f)  TDI requests that the FCC ensure that MCI WorldCom-Sprint maximizes
    the number and availability of accessible telecommunications
    products and services for persons with disabilities, including those
    who are deaf, late-deafened, hard-of-hearing, or deaf-blind, and
    that those offerings are made available at a cost comparable to
    those that are enjoyed by the general population.

g)  TDI requests that the FCC ensure that MCI WorldCom-Sprint
    establishes and maintains consumer advisory groups that include
    representatives from national, state and local organizations that
    represent individuals with disabilities, including those who are
    deaf, late-deafened, hard-of-hearing, or deaf-blind. These
    mechanisms would provide consumers avenues and opportunities to give
    input and evaluation on the merged entity's existing and emerging
    products and services, as well as other telecommunications issues.

**Requests Concerning The MCI WorldCom-Sprint Merger Specifically
Focused On The Merged Corporate Entity As A TRS Provider:**

a)  TDI requests that the FCC ensure that the provision of TRS by the
    merged corporate entity be of the highest quality level, consistent
    with the excellent services that Sprint has provided during the
    past. Furthermore, TDI requests that the FCC would ensure that the
    merged corporate entity keep intact the infrastructure, management
    and staff, customer relations, and technical operations that have
    contributed to Sprint's current success in 27 states.

b)  TDI requests that the FCC ensure that the merged corporate entity
    treat TRS as a vital consumer-business service, and not judge it
    solely by its profitability as a cost center.

c)  TDI requests that prior to the FCC's granting full or conditional
    approval for the merger, a special report for the FCC's review be
    prepared and submitted by MCI WorldCom-Sprint detailing its
    12-month, 5-year, and 10-year plans for its overall TRS operations.
    Furthermore, the FCC is requested to ensure the intent is with the
    merged corporate entity to meet or exceed FCC's TRS rules, and to
    fully commit to its TRS contract obligations as well as to upgrade
    its TRS offerings as new technologies are developed.

d)  TDI reiterates its previous request in conjunction with the recent
    TRS Coalition recommendations that the FCC establish an
    administrative mechanism to set quality standards, as well as to
    monitor and evaluate TRS operations, on a national basis. If such a
    mechanism existed today, the FCC would have the opportunity to get
    advice from this mechanism in order to help it evaluate the
    implications for the TRS industry as a result of this proposed
    merger, and to get a recommendation in order to help it make an
    overall decision on the merger. If this merger takes place, this
    mechanism would continue to monitor the TRS operations of the merged
    corporate entity, as well as those of other TRS providers.

e)  TDI requests that the FCC ensure that the successful approaches used
    in developing TRS by Sprint be applied to the planning and design of
    any new accessible telecommunications products and services for
    individuals with disabilities by the merged corporate entity.

f)  TDI requests that the FCC, if it were to grant approval to the MCI
    WorldCom-Sprint merger, that it only do so after being given
    assurances by MCI WorldCom and Sprint that the quality,
    availability, accessibility, and affordability of products and
    services, including TRS, will be provided to its customers anytime
    and anywhere.