between a LEC and a telecommunications carrier other than a CMRS provider that is not and repeatedly stated that the mirroring rule applies to interstate or intrastate access traffic,” traffic, not to switched access traffic. ¶ 89, FN 177 and ¶¶ ISP Remand Order, “local voice” 31. In subsequent proceedings relating to the both the ISP Remand Order, FCC and the courts recognized that the offer required by the mirroring rule applies to “local” traffic. 32. Nothing in the 2011 allows Core to override the ICC Reform Order FCC’s by retroactively collecting over a worth of uneconomic and ISP Remand Order decade’s reciprocal compensation payments for terminating ISP-bound traffic for which Verizon already paid at the $0.0007/MOU rate for ISP-bound traffic. This result would FCC’s promote regulatory arbitrage, whereas a key purpose of the was to reduce ICC Reform Order arbitrage opportunities in the intercarrier compensation realm. 33. argument that Verizon must retroactively pay it at reciprocal Core’s compensation rates for ISP-bound traffic that Verizon has already paid for at $0.0007/MOU is without legal merit. 34. Verizon is entitled to continue to pay Core $0.0007/MOU for ISP-bound traffic. 35. Pursuant to the $0.0007/MOU rate for ISP-bound ISP Remand Order’s traffic, switched access charges do not apply to ISP-bound traffic. ORDER THEREFORE,
between a LEC and a telecommunications carrier other than a CMRS provider that is not interstate or intrastate access traffic,” and repeatedly stated that the mirroring rule applies to “local voice” traffic, not to switched access traffic. ISP Remand Order, ¶ 89, FN 177 and ¶¶ 31. In subsequent proceedings relating to the ISP Remand Order, both the FCC and the courts recognized that the offer required by the mirroring rule applies to “local” traffic. 32. Nothing in the FCC’s 2011 ICC Reform Order allows Core to override the ISP Remand Order by retroactively collecting over a decade’s worth of uneconomic and reciprocal compensation payments for terminating ISP-bound traffic for which Verizon already paid at the FCC’s $0.0007/MOU rate for ISP-bound traffic. This result would promote regulatory arbitrage, whereas a key purpose of the ICC Reform Order was to reduce arbitrage opportunities in the intercarrier compensation realm. 33. Core’s argument that Verizon must retroactively pay it at reciprocal compensation rates for ISP-bound traffic that Verizon has already paid for at $0.0007/MOU is without legal merit. 34. Verizon is entitled to continue to pay Core $0.0007/MOU for ISP-bound traffic. 35. Pursuant to the ISP Remand Order’s $0.0007/MOU rate for ISP-bound traffic, switched access charges do not apply to ISP-bound traffic. ORDER THEREFORE,
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