erroneously ruled that tariffed special access rates, and not the TELRIC rates Verizon’s outlined in Appendix 2, are applicable to the ATCs. In view, the Commission Core’s wrongly relied on Footnote 1 of Appendix 2 for this conclusion. Core Petition at 12-13. Core suggests that to the extent that there is any ambiguity in the analysis of Attachment IV, Section 1.1.2 of the Verizon PA ICA, the Commission’s Commission can resolve this ambiguity by examining other sections of the ICA, particularly, Attachment VIII, Sections 3.1.3 and 3.1.3.5. Core submits that these sections the arrangement whereby Verizon provides i.e. govern “meet-point billing,” tandem switching and Core provides end office elements to IXCs for exchange access traffic transiting over Verizon access tandems to Core telephone numbers. Core PA’s argues that ATCs are an integral part of this arrangement because they facilitate the flow of exchange access traffic from the IXCs through Verizon access tandems and on to PA’s end offices. In view, when Attachment IV, Section 1.1.2 and Attachment Core’s Core’s VIII, Section 3.1.3.5 are read in tandem, it is clear that each section requires that the TELRIC rates should be applied to ATCs, overriding Footnote 1 of Appendix 2, ICA’s upon which the Commission relied. Core Petition at 13-14. Core also argues that any ambiguity in the Verizon PA ICA language regarding the appropriate rates to apply to ATCs can be resolved (1) via the ICA’s reference to to include of Exchange Access “Local Interconnection” “the provision and the exchange of more than just local traffic and (2) via the numerous ICA Service” provisions which incorporate Section 251 of the Federal Telecommunications Act of 1996 (TA96). Core submits that it is clear from this statutory provision that ATCs are a form of local interconnection to the extent that ATCs are specifically designed to carry exchange access traffic. Core Petition at 14-15. Core avers that all of the Verizon PA ICA provisions governing local interconnection and the provision of ATCs indicate that the TELRIC rates set forth in
erroneously ruled that Verizon’s tariffed special access rates, and not the TELRIC rates outlined in Appendix 2, are applicable to the ATCs. In Core’s view, the Commission wrongly relied on Footnote 1 of Appendix 2 for this conclusion. Core Petition at 12-13. Core suggests that to the extent that there is any ambiguity in the Commission’s analysis of Attachment IV, Section 1.1.2 of the Verizon PA ICA, the Commission can resolve this ambiguity by examining other sections of the ICA, particularly, Attachment VIII, Sections 3.1.3 and 3.1.3.5. Core submits that these sections govern “meet-point billing,” i.e. the arrangement whereby Verizon provides tandem switching and Core provides end office elements to IXCs for exchange access traffic transiting over Verizon PA’s access tandems to Core telephone numbers. Core argues that ATCs are an integral part of this arrangement because they facilitate the flow of exchange access traffic from the IXCs through Verizon PA’s access tandems and on to Core’s end offices. In Core’s view, when Attachment IV, Section 1.1.2 and Attachment VIII, Section 3.1.3.5 are read in tandem, it is clear that each section requires that the ICA’s TELRIC rates should be applied to ATCs, overriding Footnote 1 of Appendix 2, upon which the Commission relied. Core Petition at 13-14. Core also argues that any ambiguity in the Verizon PA ICA language regarding the appropriate rates to apply to ATCs can be resolved (1) via the ICA’s reference to “Local Interconnection” to include “the provision of Exchange Access Service” and the exchange of more than just local traffic and (2) via the numerous ICA provisions which incorporate Section 251 of the Federal Telecommunications Act of 1996 (TA96). Core submits that it is clear from this statutory provision that ATCs are a form of local interconnection to the extent that ATCs are specifically designed to carry exchange access traffic. Core Petition at 14-15. Core avers that all of the Verizon PA ICA provisions governing local interconnection and the provision of ATCs indicate that the TELRIC rates set forth in