Full opinion text
OPINION RIDGWAY, Judge: In this consolidated action, the plaintiff Chinese producers and exporters of iresh garlic (“the Chinese Producers”) challenged the final results of the U.S. Department of Commerce’s ninth administrative review of the antidumping duty order covering fresh garlic from the People’s Republic of China. See generally Taian Ziyang Food Co. v. United States, 33 CIT -, 637 F.Supp.2d 1093 (2009). Taian Ziyang analyzed each of the 10 issues that the Chinese Producers raised, sustaining Commerce’s determination as to three of the issues, and remanding the remaining seven to the agency for further consideration. See generally id., 33 CIT at-, -, 637 F.Supp.2d at 1100-02, 1166. Now pending before the court is Commerce’s Second Remand Determination, filed pursuant to Taian Ziyang. See generally Final Results of Redetermination Pursuant to Court Remand (“Second Remand Determination”). Although they raise no objections to Commerce’s redeterminations as to four of the issues addressed in the Second Remand Determination, Plaintiffs Zhengzhou Harmoni Spice Co., Ltd. (“Harmoni”), Jinan Yipin Corporation, Ltd. (“Jinan Yipin”), Linshu Dading Private Agricultural Products Co., Ltd. (“Linshu Dading”), and Sunny Import & Export Co., Ltd. (“Sunny”) — collectively referred to as the “GDLSK Plaintiffs”— continue to contest the agency’s treatment of three issues. See generally GDLSK Plaintiffs’ Comments Regarding the Department’s Remand Redetermination (“GDLSK Comments”); GDLSK Plaintiffs’ Reply Comments Regarding the Department’s Remand Redetermination (“GDLSK Reply Comments”). The Government seeks a voluntary remand to allow Commerce to recalculate the surrogate value for the Chinese Producers’ labor costs, but contends that the Second Remand Determination should be sustained in all other respects. See Defendant’s Response to Comments Upon the Remand Redetermination (“Def. Response”) at 1-2, 19. Jurisdiction lies under 28 U.S.C. § 1581(c) (2000). For the reasons detailed below, Commerce’s Second Remand Determination is sustained in part, and this matter is remanded to the agency for further consideration not inconsistent with this opinion. I. Background Seven Chinese producers and exporters of fresh garlic (the “Chinese Producers”) brought this action to contest various aspects of the Final Results of Commerce’s ninth administrative review of the anti-dumping duty order on fresh garlic from China, which covered the period from November 1, 2002 through October 31, 2003. See generally Taian Ziyang, 33 CIT-, 637 F.Supp.2d 1093; Fresh Garlic from the People’s Republic of China: Final Results of Antidumping Duty Administrative Review, 70 Fed.Reg. 34,082 (June 13, 2005) (“Final Results”); Notice of Amended Final Results of Antidumping Duty Administrative Review: Garlic from the People’s Republic of China, 70 Fed.Reg. 56,639 (Sept. 28, 2005) (“Amended Final Results”); Final Results of Redetermination Pursuant to Court Remand (Dec. 5, 2005) (First Remand Pub. Doc. 10) (“First Remand Determination”). Taian Ziyang sustained Commerce’s use of “adverse facts available” in calculating the dumping margins for Taian Ziyang Food Company, Ltd. (“Ziyang”) and Taian Fook Huat Tong Kee Foodstuffs Co., Ltd. (“FHTK”). See Taian Ziyang, 33 CIT at -, -, 637 F.Supp.2d at 1124, 1166. Taian Ziyang similarly sustained Commerce’s valuation of cold storage (challenged by the GDLSK Plaintiffs), as well as Commerce’s calculation of surrogate financial ratios (challenged by Jinxiang Dong Yun Freezing Storage Co., Ltd. (“Dong Yun”)). See id., 33 CIT at-, -, 637 F.Supp.2d at 1144, 1166. In contrast, Taian Ziyang remanded for further consideration Commerce’s valuation of certain “factors of production” necessary for the cultivation and export of fresh garlic — specifically, (1) garlic seed, (2) irrigation water, (3) labor, (4) leased land, (5) cardboard cartons, (6) plastic jars and lids, and (7) ocean freight. See id., 33 CIT at -, 637 F.Supp.2d at 1127, 1133, 1138, 1141,1151-52,1157,1162,1166. In its Second Remand Determination, Commerce revalued irrigation expenses, leased land, ocean freight, and labor. See Second Remand Determination at 1-2, lile, 16-40, 40-41, 50-53, 60-73, 78-79. On the other hand, Commerce continued to value garlic seed, cardboard cartons, and plastic jars and lids as it did in the Final Results. See id. at 1-2, 4-11, 41^6, 46-50, 54-60, 73-76, 76-78. As a result of its reconsideration in the course of the second remand, Commerce recalculated the weighted-average anti-dumping duty margin for Harmoni as 0.00% (down from 8.79%), for Jinan Yipin as 1.04% (down from 13.21 %), for Linshu Dading as 4.34% (down from 7.97%), for Sunny as 4.22% (down from 9.17%), and for Dong Yun as 15.49% (down from 31.26%).. See Second Remand Determination at 79; Final Results, 70 Fed.Reg. at 34,085; First Remand Determination at 19. FHTK’s margin remains unchanged at 15.75%. See Second Remand Determination at 79; First Remand Determination at 19. The GDLSK Plaintiffs contend that Commerce’s wage rate calculation and its valuation of cardboard cartons and plastic jars and lids do not comply with the instructions in Taian Ziyang. See generally GDLSK Comments; GDLSK Reply Comments. The GDLSK Plaintiffs maintain that this matter therefore should be remanded to the agency for further consideration. See GDLSK Comments at 2-3, 9, 14; GDLSK Reply Comments at 7. The Government seeks a voluntary remand to allow Commerce to recalculate the labor wage rate, but maintains that the Second Remand Determination otherwise should be sustained. See Def. Response at 1-2, 19. II. Standard of Review In an action reviewing an anti-dumping determination by Commerce, the agency’s determination must be upheld except to the extent that it is found to be “unsupported by substantial evidence on the record, or otherwise not in accordance with law.” 19 U.S.C. § 1516a(b)(l)(B)(i); see also NMB Singapore Ltd. v. United States, 557 F.Sd 1316, 1319 (Fed.Cir.2009). Substantial evidence is “more than a mere scintilla”; rather, it is “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Universal Camera Corp. v. Nat’l Labor Relations Bd., 340 U.S. 474, 477, 71 S.Ct. 456, 95 L.Ed. 456 (1951) (quoting Consol. Edison Co. v. Nat’l Labor Relations Bd., 305 U.S. 197, 229, 59 S.Ct. 206, 83 L.Ed. 126 (1938)); see also Mittal Steel Point Lisas Ltd. v. United States, 548 F.3d 1375, 1380 (Fed.Cir.2008) (same). Moreover, any evaluation of the substantiality of evidence “must take into account whatever in the record fairly detracts from its weight,” including “contradictory evidence or evidence from which conflicting inferences could be drawn.” Suramerica de Aleaciones Laminadas, C.A. v. United States, 44 F.3d 978, 985 (Fed.Cir.1994) (quoting Universal Camera Corp., 340 U.S. at 487-88, 71 S.Ct. 456); see also Mittal Steel, 548 F.3d at 1380-81 (same). That said, the mere fact that it may be possible to draw two inconsistent conclusions from the record does not prevent Commerce’s determination from being supported by substantial evidence. Am. Silicon Techs, v. United States, 261 F.3d 1371, 1376 (Fed.Cir.2001); see also Consolo v. Federal Maritime Comm’n, 383 U.S. 607, 620, 86 S.Ct. 1018, 16 L.Ed.2d 131 (1966). Finally, while Commerce must explain the bases for its decisions, “its explanations do not have to be perfect.” NMB Singapore, 557 F.3d at 1319. Nevertheless, “the path of Commerce’s decision must be reasonably discernable,” to support judicial review. Id. (citing Motor Vehicle Mfrs. Ass’n v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43, 103 S.Ct. 2856, 77 L.Ed.2d 443 (1983)); see also Timken U.S. Corp. v. United States, 421 F.3d 1350, 1355 (Fed.Cir.2005) (explaining that “it is well settled that an agency must explain its action with sufficient clarity to permit ‘effective judicial review,’ ” and that “[failure to provide the necessary clarity requires the agency action be vacated”) (quoting Camp v. Pitts, 411 U.S. 138, 142-43, 93 S.Ct. 1241, 36 L.Ed.2d 106 (1973)); see generally 19 U.S.C. § 1677f(i)(3)(A) (requiring Commerce to “include in a final determination ... an explanation of the basis for its determination”). III. Analysis Dumping occurs when goods are imported into the United States and sold at a price lower than their “normal value,” resulting in material injury (or the threat of material injury) to the U.S. industry. See 19 U.S.C. §§ 1673, 1677(34), . 1677b(a). The difference between the normal value of the goods and the U.S. price is the “dumping margin.” See 19 U.S.C. § 1677(35). When normal value is compared to the U.S. price and dumping is found, antidumping duties equal to the dumping margin are imposed to offset the dumping. See 19 U.S.C. § 1673. Normal value is typically calculated using either the price in the exporting market (i.e., the price in the “home market” where the goods are produced) or the cost of production of the goods, when the exporting country is a market economy eountry. See generally 19 U.S.C. § 1677b. However, where — as here — the exporting country has a non-market economy (“NME”), there is often concern that the factors of production used to produce the goods at issue are under state control, and that home market sales may not be reliable indicators of normal value. See 19 U.S.C. § 1677(18)(A). In cases such as this, where Commerce concludes that concerns about the sufficiency or reliability of the available data do not permit the normal value of the goods to be determined in the typical manner, Commerce “determine^] the normal value of the subject merchandise on the basis of the value of the factors of production,” including “an amount for general expenses and profit plus the cost of containers, coverings, and other expenses.” See 19 U.S.C. § 1677b(c)(l); see generally Ningbo Dafa Chem. Fiber Co., Ltd. v. United States, 580 F.3d 1247, 1250-51 (Fed.Cir.2009) (briefly summarizing “factors of production” methodology). The antidumping statute requires Commerce to value factors of production “based on the best available information regarding the values of such factors” in an appropriate surrogate market economy country — in this case, India. See 19 U.S.C. § 1677b(c)(l) (emphasis added); see also Shakeproof Assembly Components v. United States, 268 F.3d 1376, 1382 (Fed.Cir.2001); Ningbo, 580 F.3d at 1254 (emphasizing that statute mandates that Commerce “shall” use “best available information” in valuing factors of production). In determining which data constitute the “best available information,” Commerce generally looks to the criteria set forth in its “Policy Bulletin 04.1,” also known as the “NME Surrogate Country Policy Bulletin.” Policy Bulletin 04.1 explains: In assessing data and data sources, it is [Commerce’s] stated practice to use investigation or review period-wide price averages, prices specific to the input in question, prices that are net of taxes and import duties, prices that are contemporaneous with the period of investigation or review, and publicly available data. See Import Administration Policy Bulletin 04. 1, “Non-Market Economy Surrogate Country Selection Process,” at “Data Considerations” (March 1, 2004); see also Second Remand Determination at 42 (quoting Policy Bulletin, and stating that it reflects agency’s “well-established practice for determining the reliability and appropriateness of surrogate values”); id. at 47, 53; Issues and Decision Memorandum for the Administrative Review of the Anti-dumping Duty Order on Fresh Garlic from the People’s Republic of China (June 6, 2005) (Admin. Record Pub. Doc. 348) (“Issues and Decision Memorandum”) at 26, 39, 41. Within this general framework, the statute “accords Commerce wide discretion in the valuation of factors of production in the application of [the statute’s] guidelines.” See Shakeproof, 268 F.3d at 1381 (internal quotation marks and citation omitted); see also Ad Hoc Shrimp Trade Action Committee v. United States, 618 F.3d 1316, 1320 (Fed.Cir.2010) (same); Nation Ford Chem. Co. v. United States, 166 F.3d 1373, 1377 (Fed.Cir.1999) (same). Commerce is recognized as the “master of antidumping law.” See The Thai Pineappie Public Co. v. United States, 187 F.3d 1362, 1365 (Fed.Cir.1999); see also Shakeproof, 268 F.3d at 1381 (acknowledging “Commerce’s special expertise”). And “[t]he process of constructing foreign market value for a producer in a non-market economy country is difficult and necessarily imprecise.” Shakeproof, 268 F.3d at 1381. Nevertheless, Commerce’s discretion is not boundless. In exercising its discretion, Commerce is constrained by the purpose of the antidumping statute, which is “to determine antidumping margins ‘as accurately as possible.’ ” See Shakeproof, 268 F.3d at 1382 (quoting Lasko Metal Products, Inc. v. United States, 43 F.3d 1442, 1446 (Fed.Cir.1994)). And, Commerce’s discretion notwithstanding, “a surrogate value must be as representative of the situation in the [non-market economy] country as is feasible.” See Nation Ford, 166 F.3d at 1377 (internal quotation marks and citation omitted). Thus, “[i]n determining the valuation of ... factors of production, the critical question is whether the methodology used by Commerce is based on the best available information and establishes antidumping margins as accurately as possible.” See Ningbo, 580 F.3d at 1257 (emphases added) (quoting Shakeproof 268 F.3d at 1382) (internal quotation marks omitted). In the present case, pursuant to the instructions in Taian Ziyang, Commerce reconsidered various aspects of the agency’s valuation of the factors of production in the final results of the ninth administrative review of the antidumping duty order covering fresh garlic from China. As discussed in greater detail below, Commerce’s valuation of garlic seed (including retained garlic seed), irrigation costs, land lease costs, and ocean freight costs must be sustained. On the other hand, Commerce’s valuation of labor expenses, cardboard cartons, and plastic jars and lids must be remanded to the agency for further consideration. A. Valuation of Garlic Seed 'Taian Ziyang sustained challenges by FHTK and the GDLSK Plaintiffs to the data that Commerce selected to value garlic seed in its Final Results. See generally Taian Ziyang, 33 CIT at-,-, 637 F.Supp.2d at 1124-27, 1166. Two of the GDLSK Plaintiffs — Harmoni and Jinan Yipin — went even further. Specifically, Harmoni and Jinan Yipin asserted that it was improper for Commerce to assign to them any surrogate value for purchased garlic seed, because they do not use purchased seed and instead use seed retained from their prior years’ harvests. Taian Ziyang addressed that claim as well. See generally id., 33 CIT at-,-, 637 F.Supp.2d at 1124-27, 1166. In the Final Results, Commerce had rejected two sources of data provided by the respondent Chinese producers — (1) prices reflected in Indian import data published by the World Trade Atlas (“WTA”) for the Indian Harmonized Tariff Schedule (“HTS”) subheading covering “Garlic Fresh or Chilled,” and (2) price data from the Indian Agricultural Marketing Information Network (“Agmarknet”). Instead, the Final Results valued garlic seed using prices for varieties of Indian garlic as listed in newsletters of the Indian National Horticultural Research and Development Foundation (“NHRDF”). See generally Taian Ziyang, 33 CIT at-, 637 F.Supp.2d at 1124-27; Issues and Decision Memorandum at 14-22. In the Final Results, Commerce concluded, in essence, that the NHRDF data were the best available information for valuing the respondent Chinese producers’ garlic seed, because — according to Commerce — the NHRDF data are more product-specific than the other two potential sources of data on the record. See Taian Ziyang, 33 CIT at-, 637 F.Supp.2d at 1125; Issues and Decision Memorandum at 19-21. However, Taian Ziyang faulted Commerce’s determination, emphasizing that “[njeither Commerce nor the Domestic Producers [who supplied the NHRDF data to the agency] ... provided a complete description of the ‘high-yield’ varieties [of garlic] represented in the NHRDF data” for comparison to the respondent Chinese producers’ garlic seed input. See Taian Ziyang, 33 CIT at -, 637 F.Supp.2d at 1126. Taian Ziyang therefore remanded the matter to Commerce, instructing the agency to reconsider which of the three data sets constitutes the best available information. See id., 33 CIT at--, 637 F.Supp.2d at 1127. On remand, in accordance with Taian Ziyang, Commerce re-evaluated all three data sets on the record and reaffirmed its determination that the NHRDF data are the most product-specific, and therefore the best available information with which to value the Chinese producers’ gar-lie seed. See generally Second Remand Determination at 4-8, 54-58. In reaching its Second Remand Determination, Commerce again dismissed both the Indian import statistics and the Agmarknet data as insufficiently product-specific, pointing to the general, non-descriptive nature of categories used in the Agmarknet data, and explaining that the tariff heading used for the Indian import statistics is “extremely broad, encompassing all garlic imported into India.” See generally id. at 7-8. The Second Remand Determination observed that “with a bulb size well in excess of 5 cm in diameter, the garlic bulb grown by respondents is far larger than typical native Indian garlic strains, which usually have bulb diameters between 2 and 4 cm.” See Second Remand Determination at 5; see also id. at 5-6 (surveying individual respondents’ questionnaire responses, reporting bulb diameters ranging from 5 cm to 7 cm). To establish the similarity of the relevant NHRDF varieties, Commerce placed on the administrative record for the first time a June 2003 Market Research Report on Fresh Whole Garlic in India, which was compiled by the Domestic Producers and included in the records of the eighth and tenth administrative reviews. See id. at 5; Market Research Report on Fresh Whole Garlic in India (June 2003) (Second Remand Pub. Doc. 2) (“Market Research Report”). Relying on the Market Research Report, Commerce explained in the Second Remand Determination that “the typical bulb diameter of the Agrifound Parvati and Yamuna Safed-3 high yield garlic varieties [that Commerce] used to value respondents’ inputs falls within a similar range with a bulb diameter of 3.5 to 6.5 cm.” See Second Remand Determination at 5-7 (citing Market Research Report at 14); see also id. at 56-57. By supplementing the administrative record with the Market Research Report, Commerce has now “directly tie[d] the physical characteristics of respondents’ input [i.e., the Chinese producers’ garlic] to those of particular NHRDF varieties,” demonstrating that “[Commerce’s] surrogate value data source [i.e., the NHRDF data] approximates the large, high-quality bulb grown by respondents.” See Second Remand Determination at 7. Commerce has thus responded to the concerns raised in Taian Ziyang. See Taian Ziyang, 33 CIT at -, 637 F.Supp.2d at 1124-27. Moreover, no party has filed comments on the Second Remand Determination on this issue. Cf. Recording of Oral Argument at 32:05-32:22 (explaining that the GDLSK Plaintiffs are “now happy with [Commerce’s garlic seed valuation], or at least [they are] not challenging it further”). As to the surrogate value for purchased garlic seed, Commerce’s Second Remand Determination therefore must be sustained. Taian Ziyang granted the Government a voluntary remand to permit Commerce to respond to the request of Jinan Yipin and Harmoni that, in calculating their dumping margins, the agency value garlic seed based on their reported company-specific growing factors of production for garlic seed (rather than using the surrogate value for purchased garlic seed that the agency employed for the other respondent Chinese producers), to properly reflect the fact that Jinan Yipin and Harmoni grow their garlic crop using seed retained from harvests in prior years. See Taian Ziyang, 33 CIT at- & n. 33, -,-, 637 F.Supp.2d at 1124 & n. 33, 1127, 1166. In the Final Results, Commerce had rejected the approach advocated by Jinan Yipin and Harmoni. See id., 33 CIT at -, 637 F.Supp.2d at 1127; Issues and Decision Memorandum at 21-22. But, in the Second Remand Determination, Commerce reversed course and has now acceded to their request. See generally Second Remand Determination at 8-11, 58-60. The Second Remand Determination reaffirmed Commerce’s practice of “valuing] self-produced inputs by valuing the inputs used to create the relevant self-produced inputs,” and stated that, in the present case, the agency “is again using its standard ‘inputs-to-inputs’ methodology in valuing self-produced garlic seed based upon the actual inputs used to create Jinan Yipin’s and Harmoni’s self-produced garlic seed.” See Second Remand Determination at 59. Under that methodology, Commerce calculated surrogate values for the two respondents’ reported inputs for growing garlic seed {e.g., fertilizer; herbicide; pesticide; plastic film; skilled, unskilled, and indirect labor; and electricity), multiplying each factor by the per metric ton consumption rates for that factor, and adding up the results. See id. at 59-60. Commerce thus valued Jinan Yipin’s and Harmoni’s retained garlic seed based on the costs that they incurred to grow the retained seed, reasoning that “this method more accurately reflects Jinan Yipin’s and Harmoni’s production methodology and, thus, results in a more accurate normal value calculation.” See id. at 59-60; see also id. at 11. Because no party has filed comments on the Second Remand Determination on the issue, and because Commerce’s valuation of the garlic seed retained by Jinan Yipin and Harmoni is supported by substantial evidence and is otherwise in accordance with law (as well as Taian Ziyang), this determination by Commerce also must be sustained. B. Valuation of Irrigation Costs Taian Ziyang sustained challenges by the GDLSK Plaintiffs and Dong Yun to the surrogate value that Commerce assigned for the irrigation water used in cultivating their garlic crops. See generally Taian Ziyang, 33 CIT at-, -, -, 637 F.Supp.2d at 1101-02, 1127-33, 1166. As Taian Ziyang explained, the undisputed record evidence shows that the GDLSK Plaintiffs and Dong Yun did not pay for irrigation water (because they drew water from nearby rivers or wells on the land that they farm), and further indicates that the situation of Indian garlic growers was no different. See id., 33 CIT at-, -, 637 F.Supp.2d at 1128-29, 1131. In addition, Taian Ziyang acknowledged the concerns expressed by Dong Yun, among others, who asserted that separately valuing irrigation water resulted in double-counting because the cost of water is already reflected in the financial statements that Commerce used to calculate the surrogate financial ratios in this case. See id., 33 CIT at -, -, 637 F.Supp.2d at 1128, 1132. Taian Ziyang further noted that, in the Final Results, Commerce not only assigned a value to irrigation water, but, in doing so, actually relied upon higher “industrial” water rates, rather than “agrarian” rates (which the agency determined were highly subsidized by the Indian government). See id., 33 CIT at -, -, 637 F.Supp.2d at 1128, 1132-33; see generally Issues and Decision Memorandum at 22-26. Taian Ziyang rejected Commerce’s claim that, as a legal matter, Pacific Giant required the agency to assign a value for irrigation water in the Final Results, without regard to whether or not Indian garlic growers actually pay for such water. See Taian Ziyang, 33 CIT at -, 637 F.Supp.2d at 1129-31 (discussing, inter alia, Pacific Giant, Inc. v. United States, 26 CIT 894, 896, 904-05, 223 F.Supp.2d 1336, 1339, 1346 (2002) (addressing agency’s treatment of water usage in production of freshwater crawfish tail meat in China)). Taian Ziyang criticized the Final Results for failing to “reconcile [Commerce’s] reading of Pacific Giant, and [the agency’s] determination on the valuation of water in this case, with the plain language of [the statute],” which requires, among other things, that factors of production be valued based upon “the prices or costs of [the] factors” of production in the relevant surrogate market economy country, and on “the best available information regarding the values of such factors” in the surrogate market economy country. See Taian Ziyang, 33 CIT at-, 637 F.Supp.2d at 1129-30 (emphases omitted; alteration in original). Taian Ziyang also observed that, even if (as the agency’s interpretation of Pacific Giant suggests) Commerce is required to value irrigation water in a case such as this, there is nothing in Pacific Giant to indicate that the value assigned must necessarily be a positive value. See id., 33 CIT at-, 637 F.Supp.2d at 1130. Taian Ziyang concluded that, as a matter of law, “[i]f the record establishes that farmers in India — like the Chinese garlic producers in this case — do not pay for irrigation water drawn from nearby rivers or wells on their land, it is not clear how Commerce here can assign to water a surrogate value greater than zero. Any other outcome would appear to contravene both the plain language and the basic intent of the statute.” See Taian Ziyang, 33 CIT at-, 637 F.Supp.2d at 1130; see generally id., 33 CIT at-, 637 F.Supp.2d at 1130-31. In addition, Taian Ziyang found that “Commerce failed to adequately evaluate the record evidence on the cost of water in India — including the evidence on the nature and extent of government subsidization, if any.” See id., 33 CIT at-, 637 F.Supp.2d at 1133. Taian Ziyang therefore remanded the issue to Commerce, with instructions to “reconsider [the agency’s] surrogate value analysis for water use ..., ... [to] detail its rationale for selecting from among the possible methods of valuing this factor (as supported by substantial evidence in the record), [and to] explain[ ] why the valuation method [chosen] ... yields the most accurate dumping margin possible.” See id., 33 CIT at -, 637 F.Supp.2d at 1133. In the most recent remand, Commerce has changed its fundamental approach to calculating the costs that the GDLSK Plaintiffs and Dong Yun incurred in irrigating their garlic crops. See generally Second Remand Determination at 11-16. Specifically, Commerce has determined that “valuing the pumping cost of water, rather than valuing the water itself, yields the most accurate [dumping] margins because it most closely matches the irrigation practices of producers in the surrogate country [ie., India],” and because it fulfills the agency’s obligation to value factors of production based on the prices or costs of the factors in the surrogate market economy country and based on “the best available information.” See id. at 15-16. In reaching its decision on remand, Commerce reviewed the undisputed record evidence, which indicates that Jinan Yipin used diesel fuel to pump irrigation water into its fields, and that Dong Yun, Harmoni, Linshu Dading, and Sunny used electricity for that purpose. See Second Remand Determination at 13. Commerce similarly surveyed the ample and uncontroverted record evidence demonstrating that — much like the GDLSK Plaintiffs and Dong Yun — Indian farmers also do not pay for irrigation water that is drawn from their own wells. See id. at 14. Based on the record evidence, Commerce determined that “farmers in India who have access to wells on their property do not pay for irrigation water.” See id. at 15. As a result, Commerce further determined that — as to the Chinese garlic producers here — “it is not reasonable to separately value the consumption of water for farmers who, having access to well or river water, are not otherwise obligated to pay either civil or private authorities for irrigation water.” See id. Based on the record evidence and the legal analysis as summarized above, Commerce’s Second Remand Determination does not calculate a surrogate value for irrigation water itself, but — instead—calculates a surrogate value for the energy used to pump the irrigation water from its source into the field (i.e., diesel fuel for Jinan Yipin, and electricity for the other GDLSK Plaintiffs and Dong Yun), and then applied that surrogate value to the actual quantity of diesel fuel or electricity consumed in pumping irrigation water as reported by each of :the companies. In addition, Commerce accounted for freight expenses incurred in transporting the diesel fuel from the diesel supplier to Jinan Yipin. See Second Remand Determination at 16; see also Jinan Yipin Corp. v. United States, 35 CIT -, -, 774 F.Supp.2d 1238, 1240-42 (2011) (“Jinan Yipin III”) (in eighth administrative review, sustaining agency’s surrogate valuation of irrigation costs as calculated in second remand determination in that case, where agency adhered to same basic approach used here). No party has filed comments on the Second Remand Determination on this issue. As discussed above, the Second Remand Determination’s valuation of the irrigation costs incurred by the GDLSK Plaintiffs and Dong Yun is supported by substantial evidence and is otherwise in accordance with law. In addition, the Second Remand Determination on this issue complies with the remand instructions in Taian Ziyang. Commerce’s determination therefore must be sustained. C. Valuation of Labor Expenses The antidumping statute provides that, in non-market economy cases such as this, the surrogate data used to calculate the value of factors of production must, to the extent possible, come from market economy countries that are at “a level of economic development comparable to that of the non-market economy country” at issue — in this case, China. See 19 U.S.C. § 1677b(c)(4)(A). The antidumping statute further provides that, in such cases, the surrogate data must, to the extent possible, come from market economy countries that are “significant producers of comparable merchandise.” See id. For most factors of production, Commerce typically uses values from a single market economy country (known as the “surrogate country”' — -here, India) that Commerce has determined to be both (a) economically comparable to the non-market economy country in question and (b) a significant producer of the goods at issue. See 19 C.F.R. § 351.408(c)(2). But Taian Ziyang explained that Commerce treats the cost of labor quite differently than other factors of production. See Taian Ziyang, 33 CIT at-, 637 F.Supp.2d at 1134; see generally Dorbest Ltd. v. United States, 604 F.3d 1363, 1368 (Fed.Cir.2010). Concerned about “wide variances in wage rates between comparable economies,” Commerce historically has valued the cost of labor in an NME country case by using a regression-based wage rate “reflective of the observed relationship between wages and national income in a variety of market economy countries.” See Taian Ziyang, 33 CIT at -, 637 F.Supp.2d at 1134 (internal quotation marks and citations omitted); see also id., 33 CIT at - n. 44, 637 F.Supp.2d at 1134 n. 44 (summarizing history of 19 C.F.R. § 351.408(c)(3)). Thus, “[ujnlike its valuation of other factors of production in [a non-market economy country] case, Commerce [has based] its surrogate wage rate on data from a broad ‘basket’ of countries, and [has] not limit[ed] itself to market economy countries at a level of economic development comparable to the NME country in question.” See id., 33 CIT at-, 637 F.Supp.2d at 1134. In the Final Results, Commerce calculated the respondent Chinese producers’ labor costs using the agency’s regression-based wage rate calculation methodology, as set forth in the agency’s regulations, to establish a surrogate wage rate for China. See Taian Ziyang, 33 CIT at --, 637 F.Supp.2d at 1134-35; 19 C.F.R. § 351.408(c)(3). After correcting several clerical errors in the initial calculations in the Final Results (which yielded a surrogate wage rate of $0.93), Commerce’s First Remand Results recalculated the applicable wage rate at $0.85. See Taian Ziyang, 33 CIT at -, 637 F.Supp.2d at 1135. The GDLSK Plaintiffs and Dong Yun challenged both the facial validity of Commerce’s regression-based methodology and the agency’s application of that methodology in the instant administrative review. See id., 33 CIT at-, 637 F.Supp.2d at 1133-35. Specifically, the GDLSK Plaintiffs and Dong Yun argued, inter alia, that Commerce designated India as the primary surrogate market economy in this case, but — rather than using the Indian surrogate wage rate — Commerce used the regression-based methodology established in its regulations to calculate a wage rate that is “more than 500 percent higher than that of India.” See Taian Ziyang, 33 CIT at-, 637 F.Supp.2d at 1135 (internal quotation marks and citation omitted). The GDLSK Plaintiffs and Dong Yun asserted, inter alia, that Commerce’s regulation and its application in this case were in conflict with the statutory requirement that Commerce value factors of production using surrogate values from market economy countries that are both economically comparable and significant producers of the goods comparable to those at issue. See id., 33 CIT at -, -, 637 F.Supp.2d at 1133-34, 1135; see generally id., 33 CIT at -, 637 F.Supp.2d at 1133-38. Relying heavily on Allied Pacific II (which held Commerce’s regulation to be inconsistent with the statute), Taian Ziyang remanded the issue of the valuation of the labor factor of production to Commerce for further consideration. See Taian Ziyang, 33 CIT at-,-,-, 637 F.Supp.2d at 1134, 1135-36, 1138; Allied Pacific Food (Dalian) Co. v. United States, 32 CIT-,-, 587 F.Supp.2d 1330, 1351-61 (2008) (“Allied Pacific II”). On remand, Commerce nevertheless continued to use a regression-based methodology, albeit one that was slightly revised. See generally Second Remand Determination at 16-40, 60-73. According to Commerce, the agency “analyzed all of the information on the administrative record, revised its methodology to be consistent with its [then-]current practice, concluded that its revised methodology [produced] the ‘best available information’ on the record,” and sought to “explain[] how its methodology [was] consistent with the requirements of [the statute].” See Second Remand Determination at 17. Besides limiting the data set to just two years of wage data (2001 and 2002), Commerce also modified the data set on remand “to include all countries for which suitable data are available, rather than limiting the[] data to the fifty-six countries utilized in the Final Results.” See id. at 17 n. 18. The resulting calculation produced a regression-based surrogate wage rate of $0.77 for China. See id. Commerce’s Second Remand Determination also took strong exception to Taian Ziyang’s conclusion that the agency’s regulation prescribing the regression-based wage rate calculation methodology was inconsistent with the statute. See Second Remand Determination at 18 n. 19. Indeed, the agency devoted more than 30 pages of the Second Remand Determination to attempts to explain and defend the agency’s regression-based methodology and its resulting determination in this case. See generally id. at 17-40, 63-69, 70-73. In the meantime, however, the Court of Appeals handed down its decision in Dorbest, striking down Commerce’s regulation as inconsistent with the plain language of the statute. See generally Dorbest, 604 F.3d at 1366, 1369-73. The Court of Appeals concluded that the agency’s regulation “improperly requires using data from both economically comparable and economically dissimilar countries, and ... improperly uses data from both countries that produce comparable merchandise and countries that do not.” See Dorbest, 604 F.3d at 1372 (discussing 19 C.F.R. § 351.408(c)(3)). The Court therefore held Commerce’s regulation to be invalid on its face: To the extent that 19 C.F.R. § 351.408(c)(3) requires or at least permits the use of labor value data from countries that are not economically comparable to the non-market economy country in question or are not significant producers of merchandise comparable to the merchandise in question when data from countries meeting both criteria are available, the regulation is facially invalid as noncompliant with [the statute]. Dorbest, 604 F.3d at 1377. Armed with Dorbest, the GDLSK Plaintiffs have renewed their plea for the court to “reject Commerce’s continued use of the invalidated regression-based wage rate calculation and remand this issue to Commerce with instructions to use available wage rate information that satisfies both requirements of 19 U.S.C. § 1677b(c)(4).” See GDLSK Comments at 2-3. The Government generally concurs, requesting a voluntary remand to allow Commerce to recalculate the surrogate value for labor expenses in a manner consistent with Dorbest. See Def. Response at 18. No other party has filed comments on this issue. In light of the arguments of the GDLSK Plaintiffs and the Government’s request for a voluntary remand, this matter must be remanded. On remand, Commerce shall recalculate labor expenses in accordance with Dorbest and the plain language of the statute; and Commerce shall allow sufficient time for the submission of comments on the agency’s draft results of the remand. D. Valuation of Leased Land Taian Ziyang sustained Dong Yun’s challenge to Commerce’s decision to calculate a separate surrogate value for leased land. See generally Taian Ziyang, 33 CIT at --•, -, -, 637 F.Supp.2d at 1101-02, 1138-41, 1166. Taian Ziyang explained that, in the Final Results, Commerce had determined that “land lease costs were not accounted for in the surrogate financial ratios in this case because the [Indian surrogate companies’] financial statements [used to calculate those ratios] included a line item for land in their ‘fixed assets’ schedules, and because the surrogate companies listed zero depreciation for land”' — indications which Commerce interpreted to mean that the Indian surrogate companies did not lease land but, rather, cultivated their crops on land that they owned. See id., 33 CIT at -, 637 F.Supp.2d at 1140-41; see generally Issues and Decision Memorandum at 26-29. As Taian Ziyang noted, however, Dong Yun maintained that Commerce was, in effect, double-counting land lease costs. According to Dong Yun, the Indian surrogate companies’ financial statements already included rent and lease payments as part of “selling, general, and administrative” expenses. See Taian Ziyang, 33 CIT at -, -, -, 637 F.Supp.2d at 1138-39, 1140, 1141. Highlighting several line items in the Indian companies’ financial statements that would appear to indicate that those companies in fact did lease at least some portion of the land that they cultivated (reflecting costs for, inter alia, “leasehold land” and “Land (leasehold) and Development”), Taian Ziyang faulted Commerce for failing to reconcile its determination that the Indian companies did not lease land with record evidence to the contrary. See id., 33 CIT at-, -, 637 F.Supp.2d at 1140, 1141. In addition, Taian Ziyang questioned Commerce’s failure to acknowledge and explain its apparent departure from past agency practice. See id., 33 CIT at -, -, 637 F.Supp.2d at 1139, 1141. Taian Ziyang therefore remanded the matter to the agency for further consideration. See id., 33 CIT at-, 637 F.Supp.2d at 1140-41. In the Second Remand Determination, Commerce reversed course and determined that — as Dong Yun has maintained — land lease costs indeed already were accounted for in the “selling, general and administrative” costs of the surrogate financial companies. See generally Second Remand Determination at 40-41. Specifically, upon reconsideration, Commerce found record evidence “in the form of certain broad line items [in the financial statements of the Indian surrogate companies], such as ‘rent,’ ‘leasehold land,’ and ‘lease rent,’ that indicates that the surrogate companies may have leased land.” See Second Remand Determination at 41. The Second Remand Determination also conceded that, as Taian Ziyang observed, “prior decisions by [Commerce] have assumed that, where a surrogate’s financial statements contain a broad line item encompassing a [factor of production], that [factor of production] is accounted for, and valuing the [factor of production] separately would result in double-counting the cost.” See Second Remand Determination at 41 (citing Taian Ziyang, 33 CIT at -, 637 F.Supp.2d at 1140). Commerce therefore “[did] not use a separate calculated surrogate value for leased land” in its Second Remand Determination. See Second Remand Determination at 41. No party has filed comments on this matter. Because Commerce’s Second Remand Determination on this issue complies with the remand instructions in Taian Ziyang, and because it is supported by substantial evidence and is otherwise in accordance with law, Commerce’s determination must be sustained. E. Valuation of Cardboard Packing Cartons In Taian Ziyang, the GDLSK Plaintiffs prevailed on their challenge to Commerce’s surrogate value for the cardboard cartons that the Chinese producers used to pack and ship garlic. See generally Taian Ziyang, 33 CIT at-, -, -, 637 F.Supp.2d at 1101-02,1144-52, 1166. Taian Ziyang explained that, in the Final Results, Commerce valued cardboard cartons based on Indian import statistics taken from the World Trade Atlas (“WTA”) for Indian HTS subheading 4819.1001, covering cartons, boxes, and cases made of corrugated paper and paperboard. See Taian Ziyang, 33 CIT at --•,-, 637 F.Supp.2d at 1144, 1147-52; see generally Issues and Decision Memorandum at 37-41. In so doing, the Final Results rejected the other alternative source of data on the record — four domestic price quotes submitted by the GDLSK Plaintiffs, which were obtained within the period of review from four different Indian box vendors in four different cities for basic cardboard packing cartons like those used by the Chinese producers. See Taian Ziyang, 33 CIT at-, 637 F.Supp.2d at 1144; see generally Issues and Decision Memorandum at 37-41; GDLSK Respondents’ Surrogate Value Submission (Admin. Record Pub. Doc. 157), Exh. 16 (domestic price quotes for cardboard packing cartons). The Final Results rejected the domestic price quotes because they do not constitute “publicly available information” and because, according to Commerce, they do not reflect prices throughout the period of review. See Taian Ziyang, 33 CIT at-, 637 F.Supp.2d at 1145-46; Issues and Decision Memorandum at 39-40. As Taian Ziyang noted, however, although the price quotes are “not without problems,” the Final Results significantly “overstated any potential concerns as to the reliability of the domestic Indian box price quotes that the agency rejected, [and] significantly understated the patent flaws and defects in the Indian import statistics on which the agency relied.” See Taian Ziyang, 33 CIT at-,-, 637 F.Supp.2d at 1144, 1151 (emphases omitted). 1. The Final Results’ Treatment of the Domestic Pnce Quotes Taian Ziyang explained that Commerce’s concerns about the lack of “public availability” of the price quotes are based on the potential for manipulation. See Taian Ziyang, 33 CIT at -, 637 F.Supp.2d at 1146; Issues and Decision Memorandum at 39 (referring to “possible manipulation”). But, as Taian Ziyang pointed out, the administrative record does not include even a scintilla of evidence of distortion or manipulation, or evidence of any affiliation tainting the price quotes at issue here. See Taian Ziyang, 33 CIT at -, 637 F.Supp.2d at 1146-47. Thus, in the Final Results, Commerce — in effect— presumed distortion and affiliation, based on nothing more than speculation and conjecture. See id., 33 CIT at -, 637 F.Supp.2d at 1147. Moreover, most of the concerns that the Final Results raised visa-vis the price quotes in this case are inherent in price quotes, as well as other types of non-publicly available information. Yet, as Taian Ziyang observed, Commerce does not reject such information across the board. To the contrary, Commerce has relied on non-publicly available information — including price quotes — in numerous other cases in the past. See id., 33 CIT at-, 637 F.Supp.2d at 1147. Taian Ziyang was equally skeptical about Commerce’s second basis for rejecting the domestic price quotes. Taian Ziyang noted that the Final Results indicated that all four domestic price quotes are dated “within one week of one another” and referred to Commerce’s general preference for price data that “reflect broad market averages” covering “a substantial period of time” rather than price data that reflect a more limited period of time, due to concerns about “temporary market fluctuations.” See Taian Ziyang, 33 CIT at -, 637 F.Supp.2d at 1145; see also Issues and Decision Memorandum at 38, 40. However, as Taian Ziyang pointed out, the two cases that the Final Results cited to support Commerce’s preference— Shrimp from Vietnam and Synthetic Indigo from the PRC — are readily distinguished from this case. See Taian Ziyang, 33 CIT at-, 637 F.Supp.2d at 1145-46 (discussing Notice of Preliminary Determination of Sales at Less Than Fair Value, Negative Preliminary Determination of Critical Circumstances and Postponement of Final Determination: Certain Frozen and Canned Warmwater Shrimp From the Socialist Republic of Vietnam, 69 Fed.Reg. 42,672 (July 16, 2004); Synthetic Indigo From the People’s Republic of China: Final Results of Antidumping Duty Administrative Review, 68 Fed.Reg. 53,711 (Sept. 12, 2003)); Issues and Decision Memorandum at 40. Specifically, in Shrimp from Vietnam, Commerce rejected price quotes for shrimp which were from only one week of the period of investigation. But the record in that case included affirmative evidence of price fluctuations. See Taian Ziyang, 33 CIT at -, 637 F.Supp.2d at 1146 (discussing Shrimp from Vietnam, 69 Fed. Reg. at 42,684). As Taian Ziyang noted, the record here .is devoid of any such evidence. See Taian Ziyang, 33 CIT at -, 637 F.Supp.2d at 1146. Similarly, in Synthetic Indigo from the PRC, Commerce rejected price quotes for plastic bags that were dated anywhere from seven to ten months after the end of the period of review. See id., 33 CIT at-, 637 F.Supp.2d at 1146 (citing Issues and Decision Memorandum at 40); Issues and Decision Memorandum for Final Results of the Antidumping Duty Administrative Review on Synthetic Indigo from the People’s Republic of China — June 1, 2001, through May 31, 2002, 2003 WL 24153859 (ITA), at Comment 11 (Sept. 12, 2003). In contrast, as Taian Ziyang explained, the price quotes in this case are contemporaneous, entirely from within the period of review. See Taian Ziyang, 33 CIT at -, 637 F.Supp.2d at 1146; see also Issues and Decision Memorandum at 40. Even more to the point, Taian Ziyang noted that, as the GDLSK Plaintiffs observed, all other things being equal, it makes sense for Commerce to privilege prices that reflect broad market averages and cover a substantial period of time over price data from a more limited time frame. See Taian Ziyang, 33 CIT at -, 637 F.Supp.2d at 1145. But, here, all other things clearly are not equal. See id., 33 CIT at-, 637 F.Supp.2d at 1145. As the GDLSK Plaintiffs put it, Commerce here was faced with a choice between, on the one hand, “four domestic, product-specific, contemporaneous price quotes” and, on the other hand, “overly broad trade data which is inclusive of air freight.” See id., 33 CIT at-, 637 F.Supp.2d at 1145 (quoting GDLSK Plaintiffs’ brief) (internal quotation marks omitted). 2. The Final Results’ Treatment of the Indian Import Statistics Taian Ziyang observed that the Final Results not only sought to emphasize the potential shortcomings of the domestic price quotes (as discussed above), but, in addition, sought to minimize the evident and admitted flaws in the Indian import statistics on which the Final Results relied (as set forth in greater detail below). As a threshold matter, Taian Ziyang highlighted Commerce’s longstanding policy favoring the use of domestic data, rather than import statistics (all other things being equal) — a general policy that the agency did not honor here. See Taian Ziyang, 33 CIT at-&. nn. 60-61, 637 F.Supp.2d at 1148 & nn. 60-61. And Taian Ziyang also took note of two basic problems specific to the Indian import statistics that Commerce used, which have the effect of distorting the surrogate value for cardboard cartons in this case. Taian Ziyang first noted that it is undisputed that the domestic price quotes are much more “product specific” than the Indian import statistics on which Commerce here relied. See Taian Ziyang, 33 CIT at-,-, 637 F.Supp.2d at 1149, 1151-52. HTS subheading 4819.1001 — the subheading for which Commerce has import statistics — covers gift, specialty, and many other types of non-packing boxes, in addition to the sort of plain cardboard packing cartons that the Chinese producers here use to ship their garlic. See id., 33 CIT at --, 637 F.Supp.2d at 1149. Taian Ziyang noted that the Final Results acknowledged that the Indian import statistics include “many different types of boxes.” See Issues and Decision Memorandum at 38. But, rather incredibly, the Final Results then asserted that “that fact alone does not undermine the use of the value.” See id. As Taian Ziyang pointedly observed, Commerce’s statement “simply defies logic.” See Taian Ziyang, 33 CIT at-, 637 F.Supp.2d at 1149. It is beyond cavil that the inclusion of these other more expensive products drives up the price data captured in the Indian import statistics that Commerce used in this case. See id., 33 CIT at -, 637 F.Supp.2d at 1149. The only question is the extent of that inflation. The Final Results attempted to address the over-breadth of the Indian import statistics, asserting that “the total quantity of gift boxes was less than ten percent of the total carton imports,” and that “more than fifty percent of the entries ... [made under HTS subheading 4819.1001] are simply categorized as boxes or cartons, with no other specifications.” See Issues and Decision Memorandum at 38-39. But, as Taian Ziyang noted, trade intelligence data from Infodrive India and other information submitted by the GDLSK Plaintiffs belies Commerce’s efforts to downplay the many products included in the Indian import statistics that are much more expensive than the cardboard packing cartons at issue here. See Taian Ziyang, 33 CIT at-, 637 F.Supp.2d at 1149-50 (and authorities cited there). The trade intelligence data indicate, for example, that the vast majority of entries reflected in the Indian import statistics on which Commerce relies are, in fact, more expensive gift and specialty boxes — products that are not comparable to the basic cardboard packing cartons used by the Chinese producers here. See id., 33 CIT at-, 637 F.Supp.2d at 1149-50. As such, Taian Ziyang rejected “Commerce’s glib conclusion — that ‘the fact that different boxes for different purposes have entered ... under [HTS subheading 4819.1001] does not, in and of itself, call this value into question’ ” — as a determination that “simply cannot be credited.” See id, 33 CIT at-, 637 F.Supp.2d at 1150 (quoting Issues and Decision Memorandum at 39) (alteration in original). Quite apart from the fact that the Indian import statistics are distorted by apparently vast quantities of gift and specialty boxes that are clearly more expensive than the basic cardboard packing cartons that the Chinese garlic producers used, Taian Ziyang explained that the Indian import statistics are even further distorted by the inclusion of boxes that were shipped by air. See generally Taian Ziyang, 33 CIT at -, 637 F.Supp.2d at 1150-51. As Taian Ziyang noted, the Final Results failed to directly confront this issue. See id., 33 CIT at-, 637 F.Supp.2d at 1150. The analysis in the Final Results totaled a single brief paragraph, which was silent on the substantive merits of the effect of the inclusion of air freight charges in the Indian import statistics on which Commerce relied: Some companies may import cartons in to the PRC by air, others may not.... This point alone, however, does not undermine the [agency’s] rationale.... Furthermore, the respondents have not submitted on the record of this review anything that demonstrates that their own domestic carton suppliers did not import some [cartons] into the PRC by air. See Issues and Decision Memorandum at 40 (quoted in Taian Ziyang, 33 CIT at -, 637 F.Supp.2d at 1150). Taian Ziyang observed that, “[r]ather than grappling with the merits of the GDLSK Plaintiffs’ concerns about the distortive effects of air freight charges,” the Final Results “summarily dismissed them” by stating that “[m]ere allegations of facts, absent any record evidence for support of such claims, cannot be a basis for undermining the use of publicly available, contemporaneous valuation data from Indian HTS categories in this case.” See Taian Ziyang, 33 CIT at-, 637 F.Supp.2d at 1150 (quoting Issues and Decision Memorandum at 40). But, as Taian Ziyang noted, nothing in the record supports the Final Results’ suggestion that the Chinese garlic producers or their Indian counterparts “used packing cartons that were imported — much less imported by air.” See Taian Ziyang, 33 CIT at -, 637 F.Supp.2d at 1150. 3. The Remand in Taian Ziyang Taian Ziyang concluded that the Final Results “failed to explain how the Indian import data is the ‘best available information,’ particularly in light of the domestic Indian price quotes which represent ‘values [that] are much more specific to the cartons used for garlic packing.’ ” See Taian Ziyang, 33 CIT at -, 637 F.Supp.2d at 1151-52 (quoting GDLSK Plaintiffs’ brief); see also id., 33 CIT at -, 637 F.Supp.2d at 1144. In addition, Taian Ziyang concluded that the Final Results “failed to support [Commerce’s] selection of the Indian import statistics by reference to substantial evidence in the record.” See id., 33 CIT at -, 637 F.Supp.2d at 1152; see also id., 33 CIT at -, 637 F.Supp.2d at 1144. Taian Ziyang therefore remanded this issue to Commerce for further consideration. See id., 33 CIT at-, 637 F.Supp.2d at 1152, 1166. Unfortunately, however, Commerce’s Second Remand Determination is wholly unresponsive to Taian Ziyang. 4. The Second Remand Determination’s Treatment of the Domestic Price Quotes The Second Remand Determination adds virtually nothing to this case; and, in fact, it is incorrect as to at least one key finding. Specifically, the Second Remand Determination states (in two different places) that the four price quotes at issue were “not contemporaneous” with the period of review- — a statement that is patently false. See Second Remand Determination at 43 (stating that price quotes are “not contemporaneous”); id. at 75 (stating that “[t]he price quotes ... do not reflect prices during the [period of review]”). The magnitude of Commerce’s error calls into question the agency’s “bottom line” on this issue (i.e., the agency’s determination that the Indian import statistics are the “best available information” for use in determining the surrogate value for cardboard cartons), and, taken alone, is sufficient to necessitate another remand. In other words, the Second Remand Determination reflects a determination by Commerce that the four domestic price quotes were not the “best available information” because the price quotes (1) were not “publicly available,” and, according to Commerce, (2) were not representative of “broad market averages” covering “a substantial period of time,” and (3) were not contemporaneous with the period of review. See, e.g., Second Remand Determination at 42-43 (rejecting the four price quotes because they “are not publicly available, not contemporaneous, and are not representative of prices throughout the [period of review]”); see generally id. at 41-46, 73-76. Because Commerce itself has yet to correct its error concerning the contemporaneity of the domestic price quotes, it cannot be said with certainty that the agency would not have reached a different conclusion as to the “best available information” for use in determining the surrogate value for cardboard cartons if the agency had recognized that the price quotes in this case in fact are contemporaneous with the period of review. At the very least, the agency’s “calculus” presumably would have been considerably different. Further, the gravity of Commerce’s error raises serious questions about the degree of care taken in the preparation of the Second Remand Determination, and— even more importantly — the extent of the independence of the agency’s review of individual issues both within this proceeding and vis-a-vis other related cases. As to Commerce’s asserted concerns about the “public availability” and “representativeness” of the domestic price quotes, the Second Remand Determination does little more than rehash the exact same points that were made in the Final Results (and found wanting in Taian Ziyang). Compare Second Remand Determination at 41-46, 75-76 with Issues and Decision Memorandum at 39-40. As the GDLSK Plaintiffs aptly observe, the Second Remand Determination largely “reiterates [Commerce’s] ... concerns about the unreliability of the price quotes,” and “is comprised of virtually the identical arguments that [Taian Ziyang ] has already found to be unsupported and inadequate.” See GDLSK Comments at 3, 6. As discussed below, in the course of the most recent remand, notwithstanding the questions raised in Taian Ziyang, Commerce apparently took no action to attempt to substantiate its assumption that the domestic price quotes are not accurate or to otherwise obtain any further information to try to verify their reliability, in order to address the agency’s concerns about the potential for “manipulation” which is the basis for the agency’s preference for publicly available data. Similarly, in the course of the remand, notwithstanding the questions raised in Taian Ziyang, Commerce apparently took no action to obtain any further information to clarify the extent to which the domestic price quotes in fact reflect “broad market averages” and are sufficiently representative of prices over “a substantial period of time” — specifically, prices over the one-year period that constitutes the period of review. In addition, Commerce apparently took no action to attempt to ascertain the extent to which the price of basic cardboard packing cartons fluctuated during the period of review at issue here, or even the extent to which the price historically has fluctuated over time. As such, Commerce apparently took no action during the most recent remand to clarify the “representativeness” of the four domestic price quotes on the record. a. “Public Availability” and Potential “Manipulation” of Price Quotes In the Second Remand Determination, Commerce reiterates its preference for “publicly available information,” explaining once again that the purpose underlying that preference is “to reduce the possibility of manipulation.” See Second Remand Determination at 43; see also id. at 46 (referring to “the potential for manipulation”); id. at 76 (same); Def. Response at 7 (referring to “the possibility that ... data has been manipulated”). However, Commerce ignores Taian Ziyang’s observation that no party^ — -not even the Domestic Producers — has even alleged, much less adduced any evidence to seek to prove, that the price quotes at issue here are distorted or are the product of any manipulation, or are tainted by any affiliation between the requester of the price quotes and the supplier, or any other potential conflict of interest or collusion. See Taian Ziyang, 33 CIT at-, 637 F.Supp.2d at 1146-47; see also GDLSK Comments at 4 (arguing that “unfounded speculation” conc