substantial and legally credible.” Samuel J. Lansberry, Inc. v. Pa. PUC, 578 A.2d 600, 602 (Pa. Cmwlth. 1990). 3. The burden of proof is comprised of two distinct burdens: the burden of production and the burden of persuasion. The burden of production tells the adjudicator which party must come forward with evidence to support a particular proposition. See In re Loudenslager’s Estate, 430 Pa. 33, 240 A.2d 477, 482 (1968). The burden of persuasion determines which party must produce sufficient evidence to convince a judge that a fact has been established, and it never leaves the party on whom it is originally cast. Reidel v. County of Allegheny, 633 A.2d 1325, 1329 n. 11 (Pa. Cmwlth. Ct. 1993). 4. Core bears the burden of proving its claims, while Verizon bears the burden of proving the Verizon claims. 5. Core and Verizon are parties to two Pennsylvania interconnection agreements (ICAs): Verizon PA and Core interconnect pursuant to an ICA dated March 31, 2000, and Verizon North and Core interconnect pursuant to an ICA dated August 24, 2005. Amended Complaint ¶10; Answer to Amended Complaint ¶10, fn 3; Joint Petition of Verizon Pennsylvania Inc. and Core Communications, Inc. for Approval of an Interconnection agreement under Section 252 of the Telecommunications Act, Docket No. (Opinion and Order entered February 9, 2001); Joint Petition of Verizon North Inc. and Core Communications, Inc., for approval of the Adoption of an Interconnection Agreement Under Section 252(i) of the Telecommunications Act of 1996, Docket No. (Opinion and Order entered Nov. 1, 2005). 6. Core breached the ICAs by failing to pay Verizon’s bills for facilities, traffic termination and directory listings. 7. The parties’ ICAs control their contractual relationship and are the first place the Commission must look to determine applicable rates. Memorandum Opinion and Order, CoreComm Communications, Inc. v. SBC Communications, Inc., 18 FCC Rcd 7568, ¶ 32
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,