Full opinion text
OPINION AND ORDER STANCEU, Judge. This case arose from plaintiffs’ contesting the final, and amended final, less-than-fair-value determination that the International Trade Administration of the U.S. Department of Commerce (“Commerce” or the “Department”) issued in an antidump-ing duty investigation on certain frozen shrimp from the People’s Republic of China (“China” or the “PRC”). See Notice of Final Determination of Sales at Less Than Fair Value: for Certain Frozen and Canned Warmwater Shrimp From the People’s Republic of China, 69 Fed.Reg. 70,997 (Dee. 8, 2004) (“Final Determination”)', Notice of Am. Final Determination of Sales at Less Than Fair Value and Antidumping Duty Order: Certain Frozen Warmwater Shrimp From the People’s Republic of China, 70 Fed.Reg. 5149 (Feb. 1, 2005) (“Am. Final Determination and Order”). Before the court is the Department’s redetermination issued in response to a remand ordered by the court in Allied Pacific Food (Dalian) Co. Ltd. v. United States, 30 CIT —, 435 F.Supp.2d 1295 (2006) (“Allied Pacific I ”). See Final Results of Redetermination Pursuant to Court Remand (Oct. 27, 2006) (“Remand Redetermination”). Also before the court are plaintiffs’ comments on the Remand Redetermination, defendant’s response, and three motions pertaining to the rede-termination. Defendant United States moves for another remand order, under which Commerce voluntarily would reconsider and further explain, but not necessarily change, the decision Commerce made in the Remand Redetermination on one of the two major issues addressed by the court’s opinion and order in Allied Pacific I. Def.’s Mot. for Voluntary Remand 1-3. That issue is the calculation by Commerce of a surrogate value for raw, head-on, shell-on shrimp, which is the most significant raw material used in the production of the imported merchandise, certain frozen warmwater shrimp from China, that was the subject of the antidumping duty investigation (“subject merchandise”) resulting in this litigation. See id. The other major issue in this litigation is the calculation of a surrogate value for the labor used in producing the subject merchandise. Defendant’s motion and proposed voluntary remand order do not propose to change the surrogate labor rate set forth in the Remand Redetermination. See id. Both surrogate values are used in determining, for antidumping duty purposes, the normal value of the subject merchandise. Plaintiffs Allied Pacific Food (Dalian) Co. Ltd., Allied Pacific (H.K.) Co., Ltd., King Royal Investments, Ltd., Allied Pacific Aquatic Products (Zhanjiang) Co. Ltd., Allied Pacific Aquatic Products (Zhongshan) Co. Ltd. (collectively “Allied Pacific”) and Yelin Enterprise Co., Hong Kong (“Yelin”) oppose defendant’s motion for a voluntary remand. Allied Pacific and Yelin have filed separate counter-motions for remands, each of which advocates a remand order under which the court would direct Commerce to redetermine, in specific ways, the surrogate values for raw, head-on, shell-on shrimp and for labor. PL’s Opp’n to Def.’s Proposed Voluntary Remand and Counter Mot. for Remand 1-10 (“Allied Pacific Opp’n to Voluntary Remand”); PI. Yelin’s Opp’n to Def.’s Mot. for Voluntary Remand 2-5 (“Yelin Opp’n to Voluntary Remand”). Allied Pacific I arose from plaintiffs’ contesting the final determination (“Final Determination”) and amended final determination (“Amended Final Determination”) and moving for judgment on the agency record according to USCIT Rule 56.2. In their motion, plaintiffs claimed that Commerce failed to adhere to the statutory requirement to value raw shrimp and labor according to the best available information. In Allied Pacific I, the court ordered Commerce to redetermine the surrogate values for raw, head-on, shell-on shrimp and for the labor rate. Allied Pacific I, 30 CIT at —, 435 F.Supp.2d at 1323. Plaintiffs argue that the Remand Redetermination does not comply with the court’s remand order in Allied Pacific I and that the findings Commerce relied upon in the Remand Redetermination are unsupported by substantial record evidence. See PL’s Comments on the Department’s Remand Determination 1-49 (“Allied Pacific Comments”); Comments of Yelin Enterprise Co., Hong Kong on Remand Determination 1-25 (‘Yelin Comments”). Regarding the surrogate labor rate, plaintiffs reiterate specific arguments they made in challenging that rate, including the argument that Commerce did not provide an adequate explanation for the finding that its method produced a more accurate result than plaintiffs’ preferred alternative. See Allied Pacific Comments 45-47; Yelin Comments 25. Allied Pacific also requests that the court instruct Commerce to adjust the dumping margin applied to Section A respondents based on the final rates affirmed by the court. Allied Pacific Comments 49. Defendant’s proposed voluntary remand order would direct Commerce either to redetermine the surrogate value for raw, head-on, shell-on shrimp according to a different set of data than that used in the Remand Redetermination or, if Commerce retains its earlier method of valuing the raw shrimp, to provide the court with its reasons for concluding that this method produces a rehable result. Def.’s Mot. for Voluntary Remand 2-4. Allied Pacific and Yelin urge the court not to adopt defendant’s proposed remand order, and each moves for a more specific remand order that would direct Commerce to value the raw shrimp according to a different set of data that plaintiffs consider to be the best available information on the record, or, alternatively, to explain why that set of data is not appropriate. Allied Pacific Opp’n to Voluntary Remand 1-9; Yelin Opp’n to Voluntary Remand 2-4. Plaintiffs also argue that the court should direct Commerce to change its method of determining a surrogate labor rate rather than accept the more minor revision to the Department’s labor rate calculation that Commerce effected in the Remand Rede-termination. Allied Pacific Opp.’n Voluntary Remand 10; Yelin Opp’n to Voluntary Remand 4-5. For the reasons discussed in this Opinion and Order, the court concludes that the Department’s new surrogate value for raw shrimp does not comply with the court’s decision in Allied Pacific I. The court also concludes that defendant’s proposed voluntary remand order, although addressing some of the shortcomings in the Final Determination and Amended Final Determination, is not in every respect a satisfactory resolution of the issues this case presents regarding the raw shrimp surrogate value. Further, the remand order the court is issuing in this case differs from the proposed remand orders sought in plaintiffs’ counter-motions. Concerning the labor wage rate issue, the court concludes that Commerce’s redetermined surrogate value for labor was not determined in accordance with law because the regulation and methodology under which the surrogate labor rate was calculated are inconsistent with the antidumping statute. Finally, the court concludes that plaintiff Allied Pacific lacks standing to challenge the dumping margin applied to Section A respondents. Exercising its jurisdiction under 28 U.S.C. § 1581(c) (2000), the court orders Commerce to file a remand redetermination in which it determines new surrogate values for raw shrimp and labor according to specific directions set forth in this Opinion and Order. I. Background The procedural background of the initial phase of this case is presented in the court’s opinion and order in Allied Pacific I, 30 CIT at —, 435 F.Supp.2d at 1298-1308. That background discussion is supplemented herein to recount the various events occurring since Allied Pacific I was decided on June 12, 2006. In its Remand Redetermination, issued on October 27, 2006, Commerce lowered the base surrogate value for raw, head-on, shell-on shrimp from the originally-determined $5.97 per kilogram to $5.07 per kilogram and lowered the labor rate from $0.93 to $0.85 per hour. Remand Redeter-mination 2, 22-23; Issues and Decision Memorandum for the Antidumping Duty Investigation of Certain Frozen and Canned Wannwater Shrimp from the People’s Republic of China 18 (Nov. 29, 2004) (Admin.R.Doc. No. 814) (“Decision Mem.”). On remand, Commerce applied these revised surrogate values in recalculating the dumping margins for plaintiffs Allied Pacific and Yelin, lowering Allied Pacific’s margin from 80.19% to 55.56% and Yelin’s margin from 82.27% to 56.37%. Remand Redetermination 85; Am. Final Determination and Order, 70 Fed.Reg. at 5151. Following the filing of comments on the Remand Redetermination, defendant, on February 13, 2007, filed its motion for a voluntary remand. Allied Pacific and Ye-lin filed their opposition to defendant’s voluntary remand motion and their counter-motions on March 5, 2007. A. The Department’s Recalculation of the Surrogate Value for Raw, Head-On, Shell-On Shrimp Commerce, during the investigation and again on remand, used India as the surrogate country in valuing the various factors of production associated with the subject merchandise, other than labor. See Remand Redetermination 4-5; see also 19 U.S.C. § 1677b(e)(l) (2000) (requiring generally that “the valuation of the factors of production shall be based on the best available information regarding the values of such factors in a market economy country or countries considered to be appropriate by the administering authority”). To determine the surrogate value for raw, head-on, shell-on shrimp in the Remand Rede-termination, Commerce used data on raw seafood material purchases that were contained in the financial statement of an Indian seafood producer, Nekkanti Sea Foods Ltd. (“Nekkanti”), as it had in the Final Determination. Remand Redetermi-nation 22-23. The Nekkanti financial statement had been submitted for the record in the investigation by the petitioners. See Letter from Dewey Ballantine LLP to Sec’y of Commerce at 3, Attach. 1 (May 21, 2004) (“Petitioners’ Surrogate Value Submission ”) (Admin.R.Doc. No. 269). In the antidumping duty investigation, and again in the Remand Redetermination, Commerce chose the Nekkanti financial statement data over various other sets of data in valuing the raw shrimp input. See Remand Redetermination 8-9, 22-23; De- cisión Mem. 8-16. As it had in the investigation, Commerce concluded in the Remand Redetermination that the Nekkanti financial statement data were superior to all other data sets on the record and therefore constituted, for purposes of 19 U.S.C. § 1677b(c)(l), the “best available information” that could be used in determining a surrogate value for raw shrimp. Remand Redetermination 8-22; Decision Mem. at 8-16; see 19 U.S.C. § 1677b(c)(l). In the Remand Redetermination, Commerce lowered the original $5.97 per-kilogram base surrogate value to the new, $5.07 base surrogate value by making an adjustment in its calculation to exclude those of Nekkanti’s shrimp purchases that were purchases of processed shrimp, as opposed to purchases of raw, head-on, shell-on shrimp. Remand Redetermination 2, 22. With respect to the $5.97 base value, the court concluded in Allied Pacific I that the record lacked substantial evidence to establish that Nekkanti’s shrimp purchases were confined to raw, head-on, shell-on shrimp. Allied Pacific I, 30 CIT at —, 435 F.Supp.2d at 1311-12. Commerce explained that “upon careful re-examination, we agree with the Court’s observation that this value includes processed shrimp.” Remand Re-determination 9. Commerce went on to state that [consistent with the Court’s order, because Nekkanti’s financial statement is being used to value the main raw material input used in the production of subject merchandise, and because it is possible to exclude Nekkanti’s purchases of processed (i.e., headless, peeled, de-veined, etc.) shrimp, the Department has done so in order to achieve a more accurate surrogate value that is more specific to Allied Pacific[’s] and Yelin’s raw, unprocessed shrimp inputs. Id. at 9-10. From data on Nekkanti’s purchases that were submitted in the parallel antidumping duty investigation on certain warmwater shrimp from India, Commerce estimated that Nekkanti’s raw material consumption during that period of investigation (which was October 1, 2002 through September 30, 2003) was 23.99% processed shrimp by quantity and 32.14% processed shrimp by value. Id. at 18; see also Notice of Final Determination of Sales at Less Than Fair Value and Negative Final Determination of Critical Circumstances: Certain Frozen and Canned Warmwater Shrimp From India, 69 Fed. Reg. 76,916, 76,916 (Dec. 23, 2004). Commerce concluded that these purchases were a reasonable basis for estimating Nekkanti’s raw material consumption during the 2002-2003 fiscal year, April 2002 through March 2003, which was the fiscal year reported in the Nekkanti financial statement. Remand Redetermination 18. Commerce stated in the Remand Redeter-mination that it “adjusted Nekkanti’s 2002-2003 consumption of raw shrimp by reducing the quantity of Nekkanti’s raw materials consumed by 23.99 percent and reducing the value of Nekkanti’s raw materials consumed by 32.14 percent.” Id. at 22. Because the Nekkanti financial statement data are not specific as to count size, Commerce retained in the Remand Rede-termination the method it had used in the Final Determination to convert the single value obtained from the Nekkanti financial statement data to individual values representing various categories of shrimp count sizes reported by Allied Pacific and Yelin. Id. As discussed in Allied Pacific I, that method derived standard count size ranges from the information of Urner Barry, a publisher of pricing and other market information for various food industries, including the seafood industry, and correlated the count size ranges of Allied Pacific and Yelin to the count size ranges it had derived. See Allied Pacific I, 30 CIT at —, 435 F.Supp.2d at 1308. As it had in the original investigation, Commerce in the Remand Redetermination assigned the base Nekkanti value for raw, unprocessed shrimp (as revised downward from $5.97 per kilogram to $5.07 per kilogram) to the weighted average count size range of 31 to 40 shrimp per pound, calculated the average price differential between count size ranges, and adjusted the Nekkanti base price by 13.24% for successive count-size ranges. Remand Redetermination 22-24. As discussed in detail in Allied Pacific I, 30 CIT at —, 435 F.Supp.2d at 1303, respondents placed on the record of the investigation several data sets of shrimp prices in India. One set of data consisted of pricing information in issuances (“circulars”) distributed in the surrogate country, India, by the Seafood Exporters Association of India (“SEAI”) listing count-size-specific prices for raw, head-on, shell-on shrimp from two Indian shrimp producing regions, Andhra Pradesh and Tamil Nadu (“SEAI data”). The SEAI data included prices for the dates of June 6, June 21, July 26, and August 9, 2003 for Andhra Pradesh and prices for the period April through September 2003 for Tamil Nadu. Allied Pacific I, 30 CIT at —, 435 F.Supp.2d at 1303. The circulars were submitted for the record of the investigation by Allied Pacific and Yelin. See Letter from Grunfeld, Desiderio, Lebowitz, Silverman & Klestadt LLP to Sec’y of Commerce Ex. 3 (May 21, 2004) (Admin.R.Doc. No. 267) (“Allied Pacific First Surrogate Value Submission ”). In addition, plaintiffs submitted data from World Shrimp Farming 2003, Shrimp News International, Number 16 that lists Andhra Pradesh and Tamil Nadu as ranking first and fifth, respectively, among nine Indian states in production of farm-raised shrimp for 2002. Id. In their motions for remand orders, plaintiffs urge the court to direct Commerce to use the SEAI data to value the raw shrimp input. Also on the record of the investigation are data sets that Allied Pacific and Yelin submitted as alternates during the investigation after petitioners opposed the use of the SEAI data for the calculation of a raw shrimp surrogate value. See Letter from Grunfeld, Desiderio, Lebowitz, Silverman & Klestadt LLP to Sec’y of Commerce 2 (Sept. 8, 2004) (Admin.R.Doc. No. 709) (“Allied Pacific Second Surrogate Value Submission”). Plaintiffs submitted historical prices for raw, head-on shrimp that were published by the Aquaculture Certification Council, Inc. in India (“ACC data”). Id. at Ex. 3. Plaintiffs also provided publicly available, “ranged” purchase prices that two Indian companies, Devi Sea Foods, Ltd. (“Devi”) and Nekkanti, had reported as actual prices paid for raw shrimp (“Devi and Nekkanti ranged data” or “Ranged Data”) in their roles as respondents in the parallel antidumping investigation of certain warmwater shrimp from India. Id. at Attachs. 1-2. The data on these reported sales were modified for public consumption pursuant to the Department’s regulations, which allow a respondent to summarize its data by grouping (“ranging”) the data to within ten percent of the actual numerical figures. See 19 C.F.R. § 351.304(c) (2004). B. The Department’s Recalculation of the Surrogate Value for the Labor Rate The Remand Redetermination recalculated the surrogate labor wage rate it applied in the Final Determination, lowering the rate from $0.93 per hour to $0.85 per hour. Rejecting plaintiffs’ argument that the Department’s regression analysis methodology, which the Department applied under its regulation, 19 C.F.R. § 351.408(c)(3) (2004), is contrary to law, the Remand Redetermination concludes that the regulation and methodology are consistent with all statutory requirements. Remand Redetermination 35-46. The Remand Redetermination also concludes that plaintiffs’ alternative of using the countrywide labor wage rate for India would be inconsistent with the regulation and would produce a result less accurate than that resulting from the Department’s regression analysis. Id. at 78-80. Under the Department’s regulation, the surrogate value of labor is not derived in the same manner as the surrogate values of other factors of production. See 19 C.F.R. § 351.408(c)(2)-(e)(3). With respect to the surrogate value for labor, the regulation provides that [f]or labor, the Secretary will use regression-based wage rates reflective of the observed relationship between wages and national income in market economy countries. The Secretary will calculate the wage rate to be applied in nonmarket economy proceedings each year. The calculation will be based on current data, and will be made available to the public. Id. § 351.408(c)(3). As the Department describes its method in the Remand Rede-termination, “[f]irst, the Department uses a regression analysis to estimate the linear relationship between GNI \i.e., gross national income,] and hourly wage rates from a sufficient number of market economy countries.” Remand Redetermination 76. “Second, the Department applies the GNI for each NME [ie., non-market economy,] to the results of the regression and the GNI data to estimate the hourly wage rates for each non market economy country.” Id. “The result is the expected non market economy country labor/wage rate for each NME country.” Id. As required by the regulation, Commerce determines non-market economy labor rates on an annual basis. Id. at 37. Commerce relied on four different data sets in performing its regression analysis: (1) country-specific wage rate data from the International Labour Organization (“ILO”) for fifty-six countries; (2) country-specific consumer price index (“CPI”) data from the International Monetary Fund (“IMF”); (3) exchange rate data from the IMF; and (4) country-specific per-capita GNI data from the World Bank. Id. at 38. The information contained in the data sets is not contemporaneous with the period of investigation. “There is normally a two-year interval between the current year and the most recent reporting year of the data required for [the Department’s] methodology due to the practices of the respective data sources.” Id. at 37. The ILO wage data are inflation-adjusted to correspond to the same “Base Year” as the other data sets; the “Base Year” usually precedes the period of investigation by two years. Id. at 37-41. Specifically, before conducting the regression analysis, Commerce converts the ILO wage rate data to hourly wages, adjusts the wage data using CPI data to reflect the relevant Base Year, and converts the data to U.S. dollars using the exchange rate data from the relevant Base Year. Id. at 38, 40-41. Commerce then regresses this adjusted hourly wage rate data from fifty-six market economy countries against the per-capita GNI data from the same countries and arrives at the following equation: Wage of the Non-Market Economy Country = Y-intercept + X-coefficient * GNI of the Non-Market Economy Country See id. at 41. Commerce uses this equation to estimate hourly wage rates in all non-market economy countries, including China. See id. at 76. In the Remand Redetermination, Commerce made various changes to address what it considered to be errors in its methodology; the cumulative effect of those changes lowered the calculated labor rate from $0.93 to $0.85 per-hour. Decision Mem. at 18; Remand Redetermination 2. Commerce found that in the investigation it had failed to use the most current data for its regression analysis, having inadvertently used computer spreadsheet files from its 2003 calculation rather than data available in 2004. Remand Redetermination 42. Commerce also discovered that the more recent data set it intended to use, the October 2004 wage rate data set, “cannot be used for the expected wage rate calculation because it contains at least five types of errors, each of which represents a departure from the Department’s methodology for the calculation of expected NME wage rates.” Id. at 44. To correct for these errors, Commerce, in the Remand Redetermination, used data available as of December 2004. Id. at 45^16. That data set, however, contained only fifty-four countries instead of the usual fifty-six; Commerce deleted the data from two of the fifty-six countries, Algeria and Zimbabwe, considering it to be incomplete. Id. at 46. Commerce also made adjustments to the data set to correct other errors, which adjustments are not specifically challenged in this case. Id. Commerce determined that the regression analysis it performed using this data set “enables the Department to determine in an accurate, fair, and predictable manner, the labor wage rate of a market economy country at a comparable level of development,” and stated that it considers “the data set used here to be the best available reliable data.” Id. at 79. In the Remand Redetermination, Commerce rejected several alternative methods of determining the surrogate value of the labor input. Commerce rejected valuing the labor input using the wage rate of a single country selected as comparable, because it “is not required by statute and would violate the Department’s regulation.” Id. Commerce concluded that “such a method would not appear to offer greater accuracy,” particularly because of variation in the wage rates of economically comparable countries. Id. at 77, 79-80. Commerce also rejected the use of alternative data sets in the agency’s regression analysis. Id. at 78-84. Citing its wide discretion in determining what constitutes the best available information, Commerce rejected a smaller set of countries with economies comparable to India, explaining that “the basket of countries need not be limited to those with similar per-capita GDP.” Id. at 78. Commerce also turned down plaintiffs’ request that “the Department consider increasing the number of countries in the analysis ... if it continues to employ the current regression analysis.” Id. at 80-84. Commerce reasoned that, because the main benefits of the regression-based wage rate calculation are its accuracy, predictability, and fairness to all parties, “extreme changes in the dataset of countries from one year to the next, or from one case to the next, without the benefit of public comment or the opportunity for adequate analysis of the data available, may result in decreased predictability and fairness for all parties before the Department, and would undermine the purpose of its regulation.” Id. at 80. Commerce found its data set to be sufficiently broad to render an accurate wage rate and considered the proposed alteration to add more countries to be less appropriate because it would not provide all interested parties with the opportunity to comment. Id. at 81, 84. II. Discussion The court will uphold the Department’s Remand Redetermination unless it is unsupported by substantial evidence on the record or otherwise not in accordance with law. 19 U.S.C. § 1516a(b)(l)(B)(i) (2000). “Substantial evidence is more than a mere scintilla. It means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Consol. Edison Co. v. NLRB, 305 U.S. 197, 229, 59 S.Ct. 206, 83 L.Ed. 126 (1938). “This is something less than the weight of the evidence, and the possibility of drawing two inconsistent conclusions from the evidence does not prevent an administrative agency’s finding from being supported by substantial evidence.” Consolo v. Fed. Mar. Comm’n, 383 U.S. 607, 620, 86 S.Ct. 1018, 16 L.Ed.2d 131 (1966) (citations omitted). A. On Remand, Commerce Must Redetermine the Surrogate Value of Raw, Head-On, Shell-On Shrimp Using Record Information Other than the Nekkanti Financial Statement Data In their comments on the Remand Re-determination, plaintiffs again object to the Department’s choice, from among the four available data sets, of the Nekkanti financial statement data for use in calculating the surrogate value of raw, head-on, shell-on shrimp. Plaintiffs argue that the Department’s conclusion that this data set constitutes the best available information as required by 19 U.S.C. § 1677b(c)(l) is unreasonable and not supported by substantial record evidence. See Allied Pacific Comments 5; Yelin Comments 8-9, 22-23. Plaintiffs contend that the revised base surrogate value of $5.07 per-kilogram derived from the Nekkanti financial statement data is aberrational because it is substantially higher than values for raw, head-on, shell-on shrimp determined according to the other data sets on the record. Allied Pacific Comments 4; Yelin Comments 18-21. They also argue that the Nekkanti financial statement is not the best available information under the Department’s own criteria and that the methodology Commerce used to process the data in the Remand Redetermination is flawed. Allied Pacific Comments 6-18, 28-40; Yelin Comments 7-25. In the Remand Redetermination, Commerce concluded that “[ajlthough none of the surrogate value sources available to the Department perfectly satisfied the Department’s criteria of public availability, contemporaneity, broad market averages, specificity and reliability, the [Nekkanti financial statement data] satisfied the Department’s criteria better than the other surrogate value sources.” Remand Rede-termination 57. Defendant, in its brief commenting on the Remand Redetermination, argued in support of the Department’s determination that the Nekkanti financial statement data constitutes the best available information on the record. Def.’s Resp. to Pl.’s Comments upon the Remand Redetermination 4-23 (“Def.’s Remand Resp.”). Subsequent to oral argument, however, defendant filed its motion for voluntary remand, stating that Commerce would “reconsider its selection of surrogate value sources for raw, head-on, shell-on shrimp.” Def.’s Mot. for Voluntary Remand 2. Plaintiffs oppose such a voluntary remand and instead seek a remand that generally would require Commerce to value the raw shrimp input according to the SEAI data. Allied Pacific moves for a remand “instructing] Commerce to use the SEAI prices unless Commerce can demonstrate based on specific record evidence ... that the SEAI prices have a deficiency or distortion.” Allied Pacific Opp’n to Voluntary Remand 9; see also Yelin Opp’n to Voluntary Remand 3-4. Congress has vested Commerce with considerable discretion in selecting the “best available information” for use in valuing factors of production. See Nation Ford Chem. Co. v. United States, 166 F.3d 1373, 1377 (Fed.Cir.1999) (“Nation Ford ”). “ ‘[T]he process of constructing foreign market value for a producer in a nonmarket economy country is difficult and necessarily imprecise.’ ” Id. (quoting Sigma Corp. v. United States, 117 F.3d 1401, 1408 (Fed.Cir.1997)). “While § 1677b(c) provides guidelines to assist Commerce in this process, this section also accords Commerce wide discretion in the valuation of factors in the application of those guidelines.” Id. Nevertheless, the Department’s exercise of discretion to select the “best available information” pursuant to 19 U.S.C. § 1677b(c)(l) must be guided by the broader purpose of anti-dumping law. “[A]n overriding purpose of Commerce’s administration of antidumping laws is to calculate dumping margins as accurately as possible.... ” See Parkdale Int’l v. United States, 475 F.3d 1375, 1380 (Fed.Cir.2007), cert. denied, — U.S. —, 128 S.Ct. 1063, 169 L.Ed.2d 807 (2008); see also Lasko Metal Prod., Inc. v. United States, 43 F.3d 1442, 1443 (Fed.Cir.1994) (“Lasko ”) (stating that “there is much in the statute that supports the notion that it is Commerce’s duty to determine margins as accurately as possible”). The record does not contain substantial evidence to support findings of fact from which Commerce may conclude that the Nekkanti financial statement data constitute the “best available information” under 19 U.S.C. § 1677b(c)(l). Commerce, in the Remand Redetermination, explains that in selecting the best available information, Commerce “prefers to use surrogate values that are publicly available, broad market averages, contemporaneous with the POI [ie., period of investigation], specific to the input in question, and exclusive of taxes and exports.” Remand Rede-termination 5. Commerce rejected the Devi and Nekkanti ranged data, SEAI data, and ACC data principally for a claimed lack of “reliability,” a criterion that Commerce “also considers.” Id. at 6-7. “The Department determined that the prices from SEAI, ACC and Ranged Data on the record were unreliable as each suffered from fundamental problems that called into question the representativeness of its prices.” Id. at 7. The court concludes that Commerce’s finding that the financial statement data are more reliable than certain other data on the record (specifically, as discussed below, the Devi ranged data and the SEAI data) is not supported by substantial evidence on the record. Although the court concludes that Commerce’s finding on remand that the Nekkanti financial statement data do not include data on seafood other than shrimp is supported by substantial evidence, and although Commerce has made an adjustment to its calculated base value to address an important deficiency in the financial statement, ie., that the data therein pertain to raw material that includes processed shrimp, the record lacks substantial evidence to support a general finding that the financial statement data constitute the best available information on the record with which to value unprocessed shrimp. An unresolved deficiency exists because the Nekkanti financial statement data, unlike competing data sets, do not pertain to any specific shrimp count size, and because the method Commerce used to address this deficiency relies on an unsupported inference rather than on findings of fact supported by record evidence. 1. Commerce’s Finding on Remand that the Financial Statement Data Do Not Include Purchases of Raw Material Other Than Shrimp Is Supported by Substantial Evidence In Allied Pacific I, the court concluded that Commerce did not make a finding that the Nekkanti financial statement data excluded raw material purchases of seafood other than shrimp. See Allied Pacific I, 30 CIT at —, 435 F.Supp.2d at 1309-11. Commerce, in the Remand Re-determination, made such a finding, stating that “[i]n accordance with the Court’s remand order, the Department thoroughly reviewed the record of the investigation, including all items in Nekkanti’s 2002-2003 audited financial statement from which the raw shrimp surrogate value was derived.” Remand Redetermination 18-19. Commerce then sets forth the record evidence that supports its finding that the Nekkanti financial statement data are confined to purchases of shrimp. Id. at 19-21. Upon review of the Department’s discussion in the Remand Redetermination and of the relevant documents on the record, the court concludes that substantial record evidence supports the finding that the purchasing data in the financial statement pertain only to shrimp and not to other seafood. Within the entire body of the record evidence, the court finds particularly significant the listing, in the same table as the raw material data used by Commerce, a “Sale Quantity” of 3,785 metric tons of “Processed Shrimp” for the fiscal year with a “Sale Value” for “Processed Shrimp” of 1,641,654,771 Rs. and the absence of any reference to production of seafood products other than shrimp. See Nekkanti Sea Foods Ltd. 19th Annual Report 2002-2003 23 (2003) in Petitioners’ Surrogate Value Submission Attach. 1. Opening and closing inventory of finished product is expressed only for shrimp. Id. The summary information at the beginning of the financial statement discloses exports of “about 3785” metric tons of “Marine Products,” valued at “around 164 Crores,” which corresponds with the “Sale Quantity” and “Sale Value” data for processed shrimp, and also discloses that the company had production and sales of prawn seed. Id. at 2, 23. Contrary to plaintiffs’ argument in their comments on the Remand Redetermination, the listing on page twenty-five of the financial statement of the generic name of one of the company’s principal products as “Sea Foods/Frozen Shrimp” does not unambiguously signify that the data in question include non-shrimp products, particularly in light of the specific references to “Processed Shrimp” discussed above. See Allied Pacific Comments 8-9; Yelin Comments 4 n. 3. Plaintiffs also direct the court’s attention to record information found in Nekkanti’s questionnaire responses in the parallel Indian shrimp antidump-ing investigation in which Nekkanti disclosed processing of non-shrimp seafood during the period of investigation, October 1, 2002 through September 30, 2003, including “deep sea lobster,” “cuttle fish,” and “fish.” Allied Pacific Comments 9-10 (citing Nekkanti Sea Foods Ltd. Section D Resp. Ex. D-l (Apr. 15, 2004) in Allied Pacific Second Surrogate Value Submission Attach. 1; Supplemental Resp. to Section D of Nekkanti Sea Foods Ltd. 16, Ex. SD-12 (July 12, 2004) in Allied Pacific Second Surrogate Value Submission Attach. 1); Yelin Comments 5 (citing Nek-kanti Sea Foods Ltd. Section D Resp. at Ex. D-l in Allied Pacific Second Surrogate Value Submission Attach. 1). According to ranged data in the questionnaire responses, shrimp accounted for 97.2% of Nekkanti’s total processing during the period of investigation, while other products accounted for only 2.8% of that total. This record evidence does not suffice to negate Commerce’s finding that Nekkanti did not process seafood other than shrimp during the time period covered by the financial statement, i.e., from April 1, 2002 to March 31, 2003. Nekkanti Sea Foods Ltd. 19th Annual Report 2002-2003 at 2 in Petitioners’ Surrogate Value Submission Attach. 1. As discussed above, Commerce’s analysis of the Nekkanti financial statement concludes that Nekkanti produced and sold only shrimp during this period. The information in Nekkanti’s questionnaire responses does not necessarily contradict this analysis; Nekkanti could have processed this small amount of other products during the last six months of the period of investigation in the parallel anti-dumping proceeding, i.e., between April 1, 2003 and September 30, 2003. The court therefore concludes that substantial record evidence supports the finding that the purchasing data in the financial statement pertain only to shrimp and not to other seafood. Even if Commerce might have made a different finding with respect to this issue based on the record evidence, under the substantial evidence standard, “the possibility of drawing two inconsistent conclusions from the evidence does not prevent an administrative agency’s finding from being supported by substantial evidence.” Consolo, 383 U.S. at 620, 86 S.Ct. 1018 (citations omitted). 2. The Department Adjusted the Nekkan-ti Financial Statement Data Using Data That Were Partly Contemporaneous Commerce adjusted the Nekkanti financial statement data in the Remand Redetermination in response to the court’s observation, in Allied Pacific I, that these data included purchases of processed shrimp. See Allied Pacific I, 30 CIT at —, 435 F.Supp.2d at 1311-12. Commerce now acknowledges the error. Remand Redetermination 9. To address the problem, Commerce adjusted the financial statement data using ranged data provided by Nekkanti for its purchases of raw and processed shrimp during the parallel antidumping duty investigation on certain frozen shrimp from India. Id. at 17-18. Using those data, Commerce altered its calculation of the surrogate value by reducing the quantity of Nekkanti’s raw materials consumed by 23.99% and the value of those raw materials by 32.14%. Id. at 18. The adjustment lowered the base surrogate value from $5.97 per-kilogram to $5.07 per-kilogram. Id. The court concludes that Commerce’s adjustment to the financial statement is supported by record evidence. As an initial matter, the court notes that the parties to this case appear to be under the impression that there is no temporal overlap between the data from the parallel antidumping investigation and the Nek-kanti financial statement data. Rather, they seem to assume that the data used to adjust the financial statement data pertain to a time period immediately following Nekkanti’s 2002-2003 fiscal year. Commerce, in the Remand Redetermination, stated that the “downward adjustment to the 2002-2003 Nekkanti shrimp price ... used data from the immediately following six month period to make an adjustment to the 2002-2003 Nekkanti shrimp price.” Id. at 67-68 (emphasis added). Defendant repeats Commerce’s statement in its submission to the court. Def.’s Remand Resp. 12-13. Both plaintiffs are of the same point of view. Allied Pacific Comments 12 (stating that “the purchase data for processed shrimp Commerce has used reflects Nekkanti’s purchases during the six month POI [ie., period of investigation], which Commerce has already acknowledged is not contemporaneous with the 2002-2003 Nekkanti fiscal year”); Yelin Comments 7 (stating that Commerce “adjusts Nekkan-ti’s raw material price for the 2003 fiscal year based on Nekkanti’s publicly ranged purchase data covering a different time period, April through September 2003”). The record contradicts these statements. The period of investigation for the parallel antidumping duty investigation on frozen shrimp from India was from October 1, 2002 through September 30, 2003, while the fiscal year analyzed in the Nekkanti financial statement began on April 1, 2002 and ended on March 31, 2003. See Supplemental Resp. to Section D of Nekkanti Sea Foods Ltd. in Allied Pacific Second Surrogate Value Submission Attach. 1; Notice of Final Determination of Sales at Less Than Fair Value and Negative Final Determination of Critical Circumstances: Certain Frozen and Canned Warmwater Shrimp From India, 69 Fed.Reg. at 76,-916; Nekkanti Sea Foods Ltd. 19th Annual Report 2002-2003 at 1 in Petitioners’ Surrogate Value Submission Attach. 1. The data Commerce used in making the adjustment, ie., the data from the parallel antidumping investigation, therefore overlaps the period analyzed by the Nekkanti financial statement for the time period of October 1, 2002 to March 31, 2003. See Remand Redetermination 18 (stating that the “downward adjustment is based on record data showing Nekkanti’s period of investigation purchases of raw materials”); see also Letter from Grunfeld, Desiderio, Lebowitz, Silverman & Klestadt LLP to See’y of Commerce 5-6, Attachs. 1-2 (Dec. 7, 2004) (Admin.R.Doc. No. 825). It was reasonable for Commerce to use information submitted by Nekkanti as part of the parallel antidumping investigation to adjust the financial statement data. The Nekkanti financial statement and the Indian antidumping investigation data sets both pertain to purchases of shrimp, processed and unprocessed, made by Nekkan-ti. Because of the overlap in the periods covered by the data sets, Nekkanti’s purchases of processed and unprocessed shrimp that occurred between October 1, 2002 and March 31, 2003 are reflected in both data sets. While there is no overlap with respect to the remaining portion of the shrimp purchases covered in the two data sets, plaintiffs have pointed to no record evidence that would suggest that the ratio of unprocessed shrimp purchases to processed shrimp purchases that existed during Nekkanti’s period of investigation changed significantly from the ratio that occurred in the time period covered by the Nekkanti financial statement. 3. The Nekkanti Financial Statement Data Are Not Count-Size Specific, and the Department’s Method of Estimating Count-Size-Specific Values for Nekkanti Rests in Part on an Unreasonable Inference In Allied Pacific I, the court identified shortcomings in the Department’s method of determining count-size specific values from the financial statement data. Allied Pacific I, 435 F.Supp.2d at 1318-20. The Remand Redetermination retains the same flawed method, without change. Remand Redetermination 22-24. The Nekkanti financial statement does not present data on prices paid for shrimp of any specific count size. See Nekkanti Sea Foods Ltd. 19th Annual Report 2002-2003 at 23 in Petitioners’ Sum-gate Value Submission Attach. 1. In contrast, the Devi and Nekkanti ranged data, the SEAI circulars, and the ACC data pertain, in some way, to purchases of shrimp of a specific count size or range of count sizes. See Allied Pacific First Surrogate Value Submission at Ex. 3; Allied Pacific Second Surrogate Value Submission at Ex. 3; Supplemental Resp. to Section D of Nekkanti Sea Foods Ltd. at Ex. SD-3 in Allied Pacific Second Sumgate Value Submission Attach. 1; Supplemental Resp. to Section D of Devi Sea Foods Ltd. Ex. Supp.D-l-Supp.D-8 (July 13, 2004) in Allied Pacific Second Surrogate Value Submission Attach. 2. Commerce has acknowledged the importance of using eount-size-speeifie prices for the calculation of an accurate surrogate value for unprocessed shrimp. Decision Mem. at 15-16. In the investigation, Commerce, attempting to compensate for the deficiency in the purchasing data in the financial statement, assigned count-size-specific values to Allied Pacific’s and Yelin’s purchases of unprocessed shrimp through a complex, six-step calculation using Urner Barry data. See Allied Pacific I, 30 CIT at —, 435 F.Supp.2d at 1307-08. With respect to this calculation, the court in Allied Pacific I concluded that “Commerce has not provided a sufficient explanation of how the most reliable market average based on the record evidence could result from its complicated method of assigning a count size to the base value of $5.97 per kilogram and deriving other count-size values from that base value.” Id. at 1318. Citing the potential inaccuracies, the court also stated in Allied Pacific I that “the Final Determination lacks an adequate explanation of how this method of calculating count-size-specific prices for unprocessed shrimp could have satisfied the Department’s obligation to use the best available information.” Id. at 1320. Despite the court’s identification of the shortcomings in the Department’s method of determining count-size-specific values, Commerce retained this method in the Remand Redetermination, applying it to the new base value of $5.07 per-kilogram. Remand Redetermination 23-24. Commerce did not discuss in the Remand Redetermi-nation how this method could have satisfied the requirements of the statute. As it did in the Final Determination, Commerce assigned its base value, as calculated from the financial statement data, to the 31/40 shrimp-per-pound count size range. Id. at 23. However, the Nekkanti financial statement contains no information with respect to the count sizes of shrimp purchased by Nekkanti. Lacking such information, Commerce relied on the values derived from its calculation of the weighted average count size for shrimp purchased by Allied Pacific and Yelin to assign the Nekkanti base value to the 31/40 count size range. See id.; Decision Mem. at 16; Mem. from Alex Villanueva, U.S. Dep’t of Commerce, to The File at 2-4 (Nov. 29, 2004) (Admin.R.Doc. No. 810); Mem. from Alex Villanueva, U.S. Dep’t of Commerce, to The File at 2-4 (Nov. 29, 2004) (Admin.R.Doc. No. 819). As it had in the investigation, Commerce on remand calculated the surrogate values for count sizes greater and lesser than 31/40 shrimp per pound by adjusting the Nekkanti base price by 13.24% for successive count sizes. See Remand Redetermination 23-24. Because Commerce calculated estimated values for Nekkanti’s purchases of shrimp in various count-size ranges based on data on purchases that were not made by Nek-kanti (and instead were made by Allied Pacific and Yelin), these estimated values depend on an implied inference that the purchases reflected in the Nekkanti financial statement and those of Allied Pacific and Yelin are comparable with respect to weighted average count size. The court does not find substantial evidence in the record to support such an inference. Defendant contends, however, that the lack of count-size-specific information in the Nek-kanti financial statement “does not render [the data] less reliable than plaintiffs’ sources.” Def.’s Remand Resp. 8. According to defendant, because “the count sizes reported by Allied Pacific and Yelin would not directly correspond to the count sizes indicated in the SEAI, [ACC], and Nek-kanti/Devi ranged prices,” should Commerce use any of the alternative data sets, “any of these data sources would have required adjustments just like those required by Nekkanti [financial statement] data.” Id. (emphasis added). Commerce makes the same argument in the Remand Redetermination. Remand Redetermination 68. The court does not agree with this argument, which ignores the record evidence that each of the other data sets is grounded in information that is in some respect count-size specific. The Nekkanti and Devi ranged data sets, for example, provide data with respect to the cost and quantity of unprocessed shrimp purchased by the two companies that are specific to nearly every possible count size between 10 and 150 shrimp per kilogram. See Supplemental Resp. to Section D of Nekkanti Sea Foods Ltd. at Ex. SD-3 in Allied Pacific Second Surrogate Value Submission Attach. 1; Supplemental Resp. to Section D of Devi Sea Foods Ltd. at Ex. Supp.D-l-Supp.D-8 in Allied Pacific Second Surrogate Value Submission Attach. 2. Without resorting to the complex methodology employed by Commerce, the Nekkanti and Devi ranged data can be grouped into any number of count size ranges and analyzed so as to correspond to the ranges provided by Allied Pacific and Yelin. See Allied Pacific Comments, Attach. 2 at 4-10 (grouping purchases of unprocessed shrimp made by Devi and Nekkanti into the Department’s standard count sizes without using the Department’s six-step methodology). Although the SEAI and ACC data would require some adjustment to create count-size ranges that correspond to those reported by plaintiffs, such an adjustment would be notably less extensive than the one employed by Commerce in the Remand Redetermination to adjust the financial statement data and would not rely on an unsupported inference regarding the count-size composition of Nekkanti’s financial statement shrimp purchases because the SEAI and ACC data already have a relationship to count size. See Allied Pacific First Surrogate Value Submission at Ex. 3; Allied Pacific Second Surrogate Value Submission at Ex. 3. In summary, the adjustment Commerce made to the Nekkanti financial statement data for count size ranges is flawed. The flaw in the adjustment method might have been acceptable were no alternate data sets available on the record, or were the alternate data sets also to require such adjustment. Although Commerce expressly concluded in the Remand Redetermination that the alternate data sets were “less reliable than the adjusted Nekkanti data and using them to value Allied Pacificas] and Yelin’s raw shrimp inputs would result in a less accurate margin,” that conclusion, for the reasons discussed below, is unsustainable on the record of this case because it is not based on findings of fact that are supported by substantial evidence. See Remand Redetermination 8-9. A The Remand Redetermination Did Not Base Its Choice of the Financial Statement Data on a Fair Comparison of the Various Data Sets The court stated in Allied Pacific I that “selecting the surrogate value data that yield the most accurate dumping margin necessarily requires Commerce to conduct a fair comparison of the data sets on the record.” Allied Pacific I, 30 CIT at —, 435 F.Supp.2d at 1313-14 (emphasis added). On remand, Commerce failed to do so. In the Remand Redetermination, Commerce rejected the Devi and Nekkanti ranged data based on its finding that “the Ranged Data is not the most accurate data set on the record.” Remand Redetermination 32. As it had in the investigation, Commerce in the Remand Redetermination pointed to the ranging process as the reason for its conclusion that the Devi and Nekkanti ranged data are less accurate than the Nekkanti financial statement data. See id. at 32-34; Decision Mem. at 13-14. Commerce stated in the Remand Redetermination as follows: Section 351.304(c) of the Department’s regulations states that numerical data will be considered adequately summarized if grouped or presented in terms of indices or figures within ten percent of the actual figure. In accordance with Section 351.304(c) of the Department’s regulations [ie., 19 C.F.R. § 351.304(c) ], Nekkanti and Devi may have chosen to range hundreds of data points either upward or downward by as much as ten percent. Thus, for example, for any particular transaction, Nekkanti and Devi may adjust the quantity, value, and count size upward or downward by ten percent without any consistency in the relationship between the figures. As a result, the differential between a given quantity and its corresponding value can be significant. Given this possibility, if the Department were to rely on the Ranged Data, it may be relying on figures that deviate substantially from the actual data by much more than 10 percent. Id. at 32-33. The Department’s findings concerning the potential extent of inaccuracies from ranging are supported by substantial record evidence only with respect to the Nek-kanti ranged data and not with respect to the Devi ranged data. The Nekkanti ranged data, unlike the Devi ranged data, do not include a unit price for each count size and are presented in a format indicating that the count sizes are ranged. See Supplemental Resp. to Section D of Nek-kanti Sea Foods Ltd. at Ex. SD-3 in Allied Pacific Second Surrogate Value Submission Attach. 1. The Devi ranged data are comprised of species-specific tables presenting, for each count size, the quantity in kilograms of shrimp purchased, data identifying the type of shrimp purchased (from which it may be ascertained whether a particular purchase was of processed or unprocessed shrimp) and the per-kilogram price. See Supplemental Resp. to Section D of Devi Sea Foods Ltd. at Ex. Supp.D-l-Supp.D-8 in Allied Pacific Second Surrogate Value Submission Attach. 2. The Devi ranged data, contrary to what Commerce states, do not indicate that the count sizes have been ranged in addition to the per-kilogram prices. See id. As Commerce acknowledges, the Devi ranged per-kilogram prices are required by the regulation to fall within ten percent of the actual figure. However, the court does not find support in the record for the Department’s finding that these ranged prices may “deviate substantially from the actual data by much more than 10 percent.” See Remand Redetermination 33. It is not apparent to the court why the ranging of the quantity would cause the per-kilogram Devi ranged prices to vary from the actual per-kilogram prices by more than ten percent. In rejecting both data sets, Commerce does not address the distinctions between the Devi ranged data set and the Nekkanti ranged data set. The court does not find substantial evidence in the record to support the Department’s finding that the ranging of the Devi data creates inaccuracies greater than those afflicting the financial statement data, which inaccuracies stem from the Department’s reliance, to some extent, on an unsupported inference rather than record evidence in adjusting for count size. Additionally, the Devi and Nekkanti ranged data, unlike the financial statement data, are partly contemporaneous with the period of investigation. The Department’s finding that the SEAI data are less reliable than the Nek-kanti financial statement data is also not supported by substantial record evidence. As in the investigation, the Department’s primary objection to the SEAI data is that the SEAI prices are not “publicly available.” See Remand Redetermination 24-26; Decision Mem. at 15; Mem. from John D.A. LaRose, U.S. Dep’t of Commerce, to The File at 4 (July 2, 2004) (Admin.R.Doc. No. 529). The court discussed at length in Allied Pacific I why overemphasizing the “public availability” criterion does not further the objective of identifying the best available information for determining surrogate values. See Allied Pacific I, 30 CIT at —, 435 F.Supp.2d at 1315-17. As stated in Allied Pacific I, “Commerce must balance the interests of transparency and verifiability that are served by public availability with other considerations, including the desirability of data that are as specific as possible to the raw material being valued.” Id. at —, 435 F.Supp.2d at 1317. Even if Commerce is correct in viewing the SEAI data as insufficiently “publicly available,” Commerce is not free to ignore the record evidence showing that the SEAI data are superior to the financial statement data in pertaining directly to unprocessed shrimp, in relating to specific count sizes, in being contemporaneous with the period of investigation, and in not being confined to the purchasing experience of a single Indian producer. The Remand Redetermination concludes that the SEAI data are less reliable than the financial statement data because “SEAI prices from the Andhra Pradesh region represent raw shrimp purchase prices for only four days of the period of investigation ... making this an incomplete data source” and preventing Commerce from “determining] whether Allied Pacific and Yelin provided representative prices or whether they ‘cherry-picked’ ” favorable circulars. See Remand Redeter-mination 26-27. A comparison of the prices in the four SEAI circulars from Andhra Pradesh to the prices in the SEAI circular from the Tamil Nadu region, which cover the entire period of review, reveals that the prices from the Andhra Pradesh circulars are comparable to those in the Tamil Nadu circular, calling into question the Department’s speculation that the prices in the circulars may have been “cherry picked.” See Allied Pacific First Surrogate Value Submission at Ex. 3. Finally, with respect to the ACC data, in Allied Pacific I, the court concluded that Commerce, in rejecting the ACC data as insufficiently insulated from conflict of interest, failed to provide an adequate explanation. The court observed that the explanation given consisted of little more than a summary of the petitioner’s objection. Allied Pacific I, 30 CIT at —, 435 F.Supp.2d at 1320-21. In the Remand Redetermination, Commerce included a more detailed discussion of its reasons for rejecting the ACC data. On remand, Commerce again identified insulation from conflict of interest as a reason for rejecting the ACC data, finding that some of the ACC members were respondents in the parallel Indian investigation and that the ACC prices were posted only after publication of the Preliminary Determination on June 16, 2004. Remand Redetermination 28-31. Commerce raised a general concern about the reliability and legitimacy of the ACC data, based on a finding that the posting of raw shrimp prices on the ACC website was a one-time event and that ACC was not organized for the purpose of, nor normally engaged in the practice of, posting such prices. Id. at 29-31. Substantial record evidence supports the findings that the ACC price data were not regularly posted and that posting of such prices was not a routine ACC function. It is within the Department’s discretion to give weight to these two findings in its evaluation of the various data sets. However, the court considers it unnecessary to decide whether Commerce supported with substantial record evidence its decision to favor the financial statement data over the ACC data. As discussed previously, the court is unable to affirm Commerce in its finding that the Nekkanti financial statement data constitute the best available information on the record for valuing the raw shrimp input; the court reaches this conclusion in large part due to the availability on the record of the Devi ranged data and the SEAI data. Based on the foregoing, the court concludes that the record does not contain substantial evidence to support a finding under 19 U.S.C. § 1677b(c)(l) that the Nekkanti financial statement data are the best available information regarding the value of unprocessed shrimp in the surrogate country chosen by the Department. Therefore, on remand, Commerce may not use the Nekkanti financial statement data to value the raw shrimp input. 5. The Court Will Deny Plaintiffs’ Counter-Motions for Voluntary Remands In counter-motions for voluntary remands, plaintiffs Allied Pacific and Yelin each seek a remand order directing Commerce either to value the raw shrimp input according to the SEAI data or to provide detailed reasons that essentially would explain why Commerce concludes that the SEAI data are not the best available information. See Allied Pacific Opp’n to Voluntary Remand 1-9; Yelin Opp’n to Voluntary Remand 2-4. The court has determined that Commerce, in its redeter-mination. in response to this Opinion and Order, may not use the Nekkanti financial statement data as the basis for the valuation of unprocessed shrimp, as it did in the Remand Redetermination, because the Department’s finding that the Nekkanti financial statement data constitute the best available information is not supported by substantial evidence on the administrative record. If adopted by the court, the proposed orders sought by plaintiffs would suggest that the court has reached specific conclusions regarding a choice from among the data sets on the record other than the Nekkanti financial statement data. The court has not reached such conclusions. On remand, Commerce must consider the data on the record (other than the Nekkanti financial statement data) when determining a new surrogate value for unprocessed shrimp, support its choice with substantial record evidence, and ensure that its determination complies with all requirements in the statute and this Opinion and Order. For these reasons, the c