MEMORANDUM OPINION
[Dkt. # 33, # 37]
On December 1, 2010, plaintiff International Internship Programs (“IIP” or “plaintiff’) filed its second amended complaint against the Secretary of the U.S. Department of Homeland Security, Janet Napolitano; the U.S. Citizenship and Immigration Services (the “USCIS”); the Director of the USCIS; the Chief of the USCIS Administrative Appeals Office; the Director of the Vermont Services Center; the Attorney General of the United States; and the United States (collectively, “defendants”), alleging violations of the Administrative Procedure Act (“APA”), 5 U.S.C. § 551, et seq., and the Regulatory Flexibility Act (“RFA”), 5 U.S.C. § 601, et seq. Second Am. Compl., Dec. 1, 2010 [Dkt. # 9] ¶¶ 7-11, 158-201. On December 3, 2010, plaintiff filed a Motion for Preliminary Injunctive Relief. Mot. for Prelim. Inj. [Dkt. #10]. A hearing was held on December 21, 2010, and this Court denied the motion on July 19, 2011. Mem. Op. (“Prelim.Inj.Op.”), July 19, 2011 [Dkt. # 29] at 2.
On February 21, 2012, our Circuit Court dismissed the plaintiffs appeal as moot because the “intended period of employment [to which the Q-l visas applied] ended on January 24, 2012,” and “[t]he parties no longer h[ad] a legally cognizable interest in the determination of whether the preliminary injunction was properly denied.” Int’l Internship Programs v. Napolitano, et al., 463 Fed.Appx. 2, 4 (D.C.Cir.2012) (citation and internal quotation marks omitted). The Court of Appeals “express[ed] no opinion on the merits of HP’s claims.” Id.
On August 16, 2011, defendants filed a Partial Motion to Dismiss and Partial Motion for Summary Judgment (“Defs.’ Mot.”) [Dkt. # 33]. Plaintiff, in turn, filed a Cross-Motion for Summary Judgment (“Pl.’s Mot.”) [Dkt. # 37]. Upon review of the pleadings,1 the applicable law, and the entire record herein, the Court GRANTS defendants’ motion and DENIES plaintiffs motion.
BACKGROUND
1. International Internship Program
IIP is an I.R.C. § 501(c)(3) non-profit corporation that sponsors a cultural exchange program in which visitors from Japan, Korea, Thailand, and China travel to the United States. Second Am. Compl. ¶¶ 6, 44. Program participants are nonresident alien visitors2 who work in primary, secondary, and other educational institutions (the “host schools”) instructing on “the attitude, the customs, history, heritage and traditions of the [participants’] home country.” Id. ¶¶ 42, 45. Each host school determines the exact curriculum offered, but IIP monitors the programs to ensure compliance with IIP guidelines. Id. ¶¶ 48-64. The program typically lasts for an academic “semester.” Id. ¶¶ 72, 85. Participants pay between $5,400 and $8,600 to participate in the program, Certi*90fied Administrative Record (“CAR”), Aug. 16, 2011 [Dkt. # 35] at 2498, and in exchange, IIP places the participants in host schools and applies for and secures Q-l cultural visas3 for them. Second Am. Compl. ¶¶ 42, 65. IIP also provides a $100 per-month stipend for incidentals to each participant plus $200 per month to a host family that provides the participants with board, meals, and other expenses.4 Id. ¶¶ 87, 115; Pl.’s Mot. at 11; CAR at 73, 2505. Importantly, neither IIP nor the host schools pay the program participants for their work. Second Am. Compl. ¶¶ 43, 116; Pl.’s Mot. at 26.
II. Statutory and Regulatory Requirements For Q-l Visas
As part of the Immigration Act of 1990, Pub. L. No. 101-649, 104 Stat. 4978, Congress introduced Q-l visas to create an international cultural exchange program “to enhance the knowledge of the diversity of other cultures.” Mem. in Supp. of Defs.’ Mot. (“Defs.’ Mem.”), Aug. 16, 2001 [Dkt. # 33-1] at 4 (quoting H.R.Rep. No. 101-723(1), at 81 (1990), reprinted in 1990 U.S.C.C.A.N. 6710, 6751); 8 U.S.C. § 1101(a)(15)(Q). After a period of public notice and comment, the final Q-l rule and regulations were published in November 1992. Defs.’ Mem. at 4; Pl.’s Mot. at 25. As part of this final publication, and pursuant to the RFA, USCIS5 “certifie[d] that this rule w[ould] not have a significant adverse economic impact on a substantial number of small entities.” 57 Fed. Reg. 55056, 55060 (Nov. 24 1992) (codified at 8 C.F.R. pt. 214); Defs.’ Mem. at 10-11.
To obtain a Q-l visa, a U.S. employer must simultaneously petition USCIS for Q-l status for the cultural exchange visitor named in the petition and for approval of the employer’s international cultural exchange program. 8 C.F.R. § 214.2(q)(3)(i). The cultural exchange visitor’s petition will be accepted if, as part of an approved cultural exchange program, he or she “engage[s] in employment or training of which the essential element is the sharing with the American public, or a segment of the public sharing a common cultural interest, of the culture of the alien’s country of nationality.” Id. To gain approval of its cultural exchange program, the employer must demonstrate three elements: (1) “accessibility to the public” such that “the American public, or a segment of the public sharing a common cultural interest, is exposed to aspects of a foreign culture as part of a structured program”; (2) a cultural component “which is an essential and integral part of the international cultural exchange visitor’s employment or training”; and (3) a work component which *91“may not be independent of the cultural component of the international cultural exchange program.” Id. § 214.2(q)(3)(iii). Critical to this work component is the employer’s “financial ability to remunerate the participant(s)” and its obligation to “offer the alien(s) wages and working conditions comparable to those accorded local domestic workers similarly employed.” Id. § 214.2(q)(4)(i)(D)-(E) (emphasis added); see also Second Am. Compl. ¶¶ 35, 40; Defs.’ Mem. at 13. Once approved, the visa is valid “for the duration of the program, which may not exceed 15 months.” 8 C.F.R. § 214.2(q)(3)(ii).
III. USCIS Review of HP’s Visa Petitions
This action arises from decisions by the Vermont Services Center (“VSC”) and US-CIS Administrative Appeals Office (“AAO”), the USCIS appellate body, (together, the “USCIS”) denying, in whole or in part, three of HP’s Q-l visa petitions. PL’s Mot. at 1. In August 2009, IIP filed a Q-l petition with the VSC for eighteen visas. CAR at 2-4. After issuing a Request for Evidence (“RFE”) and receiving plaintiffs response, id. at 59-62, 68-77, the VSC approved the petition and certified its decision to the AAO, id. at 39-44; see also PL’s Mot. at 5-8. The AAO affirmed the decision but advised the VSC to reconsider the duration of the visas because IIP did not establish “that the [interns] would be performing services consistent with the program during the summer months.” CAR at 34-37; PL’s Mot. at 8-9. After issuing a second RFE, CAR at 31-32, the VSC approved the visas but limited their duration to conform to the schools’ academic calendar, id. at 1461; PL’s Mot. at 9. Plaintiff is challenging this limitation.6
In January 2010, IIP filed a second petition for Q-l visas. CAR at 1362-65; PL’s Mot. at 9. After requesting additional information and reviewing plaintiffs RFE response, CAR at 1377-90; PL’s Mot. at 9, the VSC denied the petition because, among other reasons, the interns would not “receive wages comparable to those of local domestic workers similarly employed,” CAR 1357-1361; PL’s Mot. at 10. On review, the AAO affirmed the denial, noting that the regulations require the employer to pay the interns “actual wages.” CAR at 1207-08; PL’s Mot. at 12. Plaintiff is now challenging AAO’s subsequent denial of its motion to reconsider. CAR at 791, 805-06; PL’s Mot. at 12-13.
Plaintiff admits that it considers the cultural exchange visitors to be unpaid volunteers, CAR at 814, and argues that the most comparable local domestic workers are unpaid interns or Americorps volunteers, PL’s Mot. at 11-12. However, the AAO, relying on the Department of Labor’s Occupational Outlook Handbook, found the cultural exchange visitors’ responsibilities to be comparable to teacher assistants, requiring equivalent wages. CAR at 798-99. The AAO noted that, under the program’s current design, the “[interns] may have a greater financial obligation to [IIP] than [IIP] does to the [interns]” because the interns must pay various fees and travel expenses in order to even participate in the program.7 Id. at 1206. Accordingly, the AAO concluded that the structure of the program “is contrary to the regulatory requirements that *92must be adhered to by qualified employers.” Id. at 1207.
In October 2010, IIP filed a third petition for Q-l visas. Id. at 2258-60. Again, the VSC issued an RFE to which plaintiff responded. Id. at 2497-2500, 2502-11. The VSC rejected the petition because “the regulations require that [IIP] pay the [interns] actual wages commensurate with their duties,” id. at 2255-56, and plaintiff amended its complaint to challenge this denial.
Plaintiff now contends: (1) that the USCIS’s denials of HP’s Q-l visa petitions were “arbitrary, capricious, not in accordance with law, in excess of statutory limitations, short of statutory right, ... contrary to Constitutional Right and Privilege, [and] not supported by substantial evidence,” Second Am. Compl., Prayer for Relief ¶ 1 (Counts I-IV, together, the “APA claims”); (2) that USCIS effectively amended the Q-l regulation through its instant decisions and, in violation of the APA, did not publish the amendment for notice and comment, Second Am. Compl. ¶¶ 194-97 (Count V); and (3) that USCIS violated the RFA by not conducting a new small-entity impact analysis “in association[ ] with its changed views” and “revised gloss on the regulation,” PL’s Opp’n to Defs.’ Mot. (“PL’s Opp’n”), Oct. 2, 2011 [Dkt. #39] at 2-3; Second Am. Compl. ¶¶ 198-201 (Count VI). Plaintiff seeks declaratory and injunctive relief in addition to costs and expenses.8 Second Am. Compl., Prayer for Relief ¶¶ 1-4.
STANDARD OF REVIEW
Defendants move to dismiss plaintiffs claims for failure to state a claim upon which relief can be granted, for lack of subject-matter jurisdiction, as barred by the statute of limitations, and on grounds of mootness. Defs.’ Mem. at 1-2. Defendant additionally moves, in the alternative, for summary judgment on plaintiffs APA claims. Id. at 3.
“While a complaint attacked by a Rule 12(b)(6) motion to dismiss does not need detailed factual allegations, a plaintiffs obligation to provide the grounds of his entitle[ment] to relief requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555, 127 S.Ct. 1955, 167 L.Ed.2d 929 (2007) (citations and internal quotation marks omitted) (alteration in original). The “complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’ ” Ashcroft v. Iqbal, 556 U.S. 662, 129 S.Ct. 1937, 1949, 173 L.Ed.2d 868 (2009) (citation omitted). “[T]he court need not accept inferences drawn by plaintiff[ ] if such inferences are unsupported by the facts set out in the complaint.” Kowal v. MCI Commc’ns Corp., 16 F.3d 1271, 1276 (D.C.Cir.1994). The court may, however, consider “any documents either attached to or incorporated in the complaint and matters of which [the court] may take judicial notice.” EEOC v. St. Francis Xavier Parochial Sch., 117 F.3d 621, 624 (D.C.Cir.1997).
A court may also dismiss a complaint, or any portion of it, that does not fall within the court’s subject-matter jurisdiction. *93Fed.R.Civ.P. 12(b)(1). Article III, Section 2 of the Constitution limits the jurisdiction of the federal courts to “actual [cjases and [controversies.” Utah v. Evans, 536 U.S. 452, 459, 122 S.Ct. 2191, 153 L.Ed.2d 453 (2002) (citing U.S. Const. art. 111, § 2, cl. 1) (internal quotation marks omitted). Thus, if an event occurs that renders it impossible for the Court to “grant any effectual relief whatever to a prevailing party,” the case must be dismissed as moot. Beethoven.com LLC, et al. v. Librarian of Congress, 394 F.3d 939, 950 (D.C.Cir.2005) (citations and internal quotation marks omitted).
When deciding a motion for summary judgment in a case involving a review of final agency action, “the Court’s role is limited to reviewing the administrative record.” Air Transport Ass’n of Am., Inc. v. Nat’l Mediation Bd., 719 F.Supp.2d 26, 32 (D.D.C.2010). “[T]he function of the district court is to determine whether or not as a matter of law the evidence in the administrative record permitted the agency to make the decision it did.” Stuttering Found. of Am. v. Springer, 498 F.Supp.2d 203, 207 (D.D.C.2007) (quoting Occidental Eng’g Co. v. INS, 753 F.2d 766, 769-70 (9th Cir.1985)); see also Fed.R.Civ.P. 56(a).
ANALYSIS
Plaintiff alleges that the defendants violated the procedural requirements of the RFA and APA when they limited and denied HP’s petitions for Q-l visas. In addition to procedural issues, plaintiff alleges that defendants’ decisions should be found unlawful under the APA for (1) requiring actual wages to be paid; (2) finding the interns’ working conditions comparable to teaching assistants; and (3) limiting HP’s program to the schools’ academic calendar. Plaintiff contends that its program complies with all of the Q-l regulation requirements and the interns, as unpaid volunteers, are sufficiently compensated. Defendants argue that their decisions to deny plaintiffs visa petitions are supported by substantial evidence and subject to highly deferential judicial review. Defendants additionally argue that plaintiffs APA claims are moot. Unfortunately for the plaintiff, I agree with the defendants and, for the reasons that follow, GRANT defendants’ Partial Motion to Dismiss and Partial Motion for Summary Judgment.
I. Plaintiff Fails to State a Claim Under the RFA.
Under the Regulatory Flexibility Act, when an agency proposes or promulgates a new rule, it is required to conduct a “regulatory flexibility analysis ... describing] the impact of the ... rule on small entities” (the “small-entity impact analysis”). 5 U.S.C. §§ 603(a), 604. However, no such analysis is required “if the head of the agency certifies that the rule will not ... have a significant economic impact on a substantial number of small entities.”9 Id. § 605(b). An agency’s compliance with § 605(b) may be reviewed if “a small entity ... is adversely affected or aggrieved by final agency action” — that is, the issuance of a final rule or regulation. Id. § 611(a)(1); U.S. Telecom Ass’n v. FCC, 400 F.3d 29, 42, 42 n. 27 (D.C.Cir.2005) (agency order adopting proposed rule was a legislative rule and therefore subject to *94judicial review for compliance with the RFA). The parties agree that the statute of limitations for this cause of action is one year. Pl.’s Opp’n at 2; Defs.’ Reply to PL’s Opp’n (“Defs.’ Reply”), Oct. 31, 2011 [Dkt. # 42] at 8; see also 5 U.S.C. § 611(a)(3)(A) (“A small entity may seek ... review during the period beginning on the date of final agency action and ending one year later.”).
Plaintiff concedes that USCIS complied with the RFA when it first promulgated the Q-l visa regulations.10 Second Am. Compl. ¶¶ 198-99; PL’s Mot. at 34. Plaintiff contends only that the USCIS effectively amended the Q-l visa regulations when it denied HP’s petitions, thereby violating the RFA by not conducting a small-entity impact analysis at that time. PL’s Mot. at 34-35; PL’s Opp’n at 3.1 disagree.
A “rule” under the RFA is any rule requiring notice and comment pursuant to § 553(b) of the APA.11 5 U.S.C. § 601(2). “[I]f an agency adopts ‘a new position inconsistent with ’ an existing regulation, or effects ‘a substantive change in the regulation,’ ” the agency must comply with the notice and comment requirements of the APA and, in turn, the small-entity analysis requirements of the RFA. U.S. Telecom Ass’n, 400 F.3d at 35, 42 (quoting Shalala v. Guernsey Mem’l Hosp., 514 U.S. 87, 100, 115 S.Ct. 1232, 131 L.Ed.2d 106 (1995)) (emphasis in original). The APA specifically exempts from its notice and comment requirements “interpretive rules, general statements of policy, or rules of agency organization, procedure, or practice.” Id. § 553(b)(A). An interpretive rule is an “agency’s reading of a statute or rule. It does not intend to create new rights or duties, but only reminds affected parties of existing duties.” Orengo Caraballo v. Reich, 11 F.3d 186, 195 (D.C.Cir.1993) (citation and internal quotation marks omitted). “A statement seeking to interpret a statutory or regulatory term is, therefore, the quintessential example of an interpretive rule,” particularly “in the course of an adjudication.” Id.
To the extent plaintiff contends that the USCIS’s denial of its visa petitions “repudiate^]” or “amend[ed] the Q-l regulation” such that the USCIS promulgated a “rule” under the RFA requiring a small-entity impact analysis, PL’s Mot. at 34-35; see also PL’s Opp’n at 3, I completely reject this contention.12 Plaintiff has put forth no case law to support its assertion. USCIS’s denials of HP’s petitions are neither “inconsistent with” nor “a substantive change in” the Q-l visa regulation; at most, the denials represent an interpretive rule. Here, USCIS interpret*95ed each statutory component as part of its review of HP’s visa petitions. See, e.g., CAR at 43 (AAO referring to the application and approval process as a “proceeding”). USCIS’s interpretation that the regulations required employers to pay “actual wages” imposed no new duties on IIP. Since its promulgation, the Q-l regulations have required employers to pay “wages ... comparable to those accorded local domestic workers.” 8 C.F.R. § 214.2(q)(4)(i)(D). Similarly, the regulations have always required the work component to “serve as the vehicle to achieve the objectives of the cultural component.” Id. § 214.2(q)(3)(iii). USCIS’s decisions were not “rules” under the RFA; therefore, plaintiff fails to state a claim for relief under the RFA.13
II. Plaintiffs APA Claims Are Moot.
On the face of its complaint, plaintiffs APA claims are indisputably moot. Plaintiff sought injunctive and declaratory relief for visas valid through January 24, 2012.14 CAR at 2260. As this date has long since passed, the Court is unable to grant any effectual relief. Beethoven.com LLC, et al., 394 F.3d at 950. Undaunted, plaintiff argues that this case falls within the “capable of repetition but evading review” exception to the mootness doctrine.15 PL’s Opp’n to Defs.’ Suggestion of Mootness (“PL’s Opp’n Mootness”), Feb. 24, 2012 [Dkt. # 45] at 4. This exception, however, only applies in “exceptional situations,” where both “(1) the challenged action [is] in its duration too short to be fully litigated prior to cessation or expiration, and (2) there [is] a reasonable expectation that the same complaining party [will] be subject to the same action again.” Spencer v. Kemna, 523 U.S. 1, 17, 118 S.Ct. 978, 140 L.Ed.2d 43 (1998) (alterations in original) (citations and internal *96quotation marks omitted). “[B]oth Supreme Court and circuit precedent hold that orders of less than two years’ duration ordinarily evade review.” Burlington N. R.R. Co. v. Surface Transp. Bd., 75 F.3d 685, 690 (D.C.Cir.1996). To be capable of repetition, “there must be a reasonable expectation or demonstrated probability that the same controversy will recur involving the same complaining party.” Spirit of the Sage Council v. Norton, 411 F.3d 225, 230 (D.C.Cir.2005) (citation and internal quotation marks omitted).
The plaintiffs instant action may “evade review” because Q-l visas are valid for, at most, a period of fifteen months, 8 C.F.R. § 214.2(q)(3)(iii)(A), but there is no reasonable expectation or probability that this same controversy will recur. Before 2009, USCIS had a seventeen-year history of approving plaintiffs visa petitions. Pl.’s Opp’n at 2. In fact, one of the petitions currently before the Court was approved by USCIS.16 Second Am. Compl. ¶ 72. Although plaintiff declared that it will file future Q-l visa petitions, Declaration of Frederic W. Schwartz, Jr., Ex. 1 to Pl.’s Opp’n Mootness, Feb. 23, 2012 [Dkt. # 45-1] ¶ 7, this alone is insufficient to show probability or reasonable expectation of denial in light of the long history of approvals. See, e.g., Spencer, 523 U.S. at 17, 118 S.Ct. 978 (finding petitioner’s habeas claim challenging allegedly unconstitutional parole revocation procedures not capable of repetition, and therefore moot, because petitioner has not “demonstrated a reasonable likelihood that he will once again be paroled and have that parole revoked”). Because plaintiffs APA claims are moot, they must be dismissed for a lack of subject-matter jurisdiction.
III. USCIS’s Decisions to Deny HP’s Q-l Visa Petitions Were Not Arbitrary, Capricious, Contrary to Law, Contrary to Constitutional Right, or Unsupported by Substantial Evidence.
Even if this Court were to find jurisdiction over plaintiffs APA claims, the claims would not survive defendants’ motion for summary judgment, because the defendants’ decisions easily withstand review under the APA. How so?
Review of final agency action under the APA is highly deferential. AT & T Corp. v. FCC, 86 F.3d 242, 247 (D.C.Cir.1996). The APA requires a court to set aside final agency action that it finds to be “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law”; or “contrary to constitutional right, power, privilege, or immunity”; or “in excess of statutory jurisdiction, authority, or limitations, or short of statutory right.” 5 U.S.C. § 706(2)(A)-(C). A court must also set aside an agency decision if it is “unsupported by substantial evidence” in the record. 5 U.S.C. § 706(2)(E); AT&T Corp., 86 F.3d at 247. But agency action is unsupported by “substantial evidence” only when it lacks what “a reasonable mind might accept as adequate to support a conclusion.”17 Schoenbohm v. FCC, 204 *97F.3d 243, 246 (D.C.Cir.2000) (quoting Consolo v. Fed. Mar. Comm’n, 383 U.S. 607, 619-20, 86 S.Ct. 1018, 16 L.Ed.2d 131 (1966)) (internal quotation marks omitted). “Because this standard is ‘something less than the weight of the evidence, ... the possibility of drawing two inconsistent conclusions from the evidence does not prevent an administrative agency’s finding from being supported by substantial evidence.’ ” Id. (quoting Consolo, 383 U.S. at 620, 86 S.Ct. 1018). Indeed, section 706 of the APA requires this Court to consider the administrative record in its entirety to determine the factors the agency considered in making its decision. 5 U.S.C. § 706; see Citizens to Pres. Overton Park, Inc. v. Volpe, 401 U.S. 402, 419-20, 91 S.Ct. 814, 28 L.Ed.2d 136 (1971).
As noted in my earlier opinion denying plaintiffs request for a preliminary injunction, because plaintiff invites the Court to review USCIS’s construction of the Q-l visa statute and the application of its relevant regulations, see 8 U.S.C. § 1101(a)(15)(Q); 8 C.F.R. § 214.2(q), US-CIS is entitled to due deference under Chevron, U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837, 104 S.Ct. 2778, 81 L.Ed.2d 694 (1984). Prelim. Inj. Op. at 8. Such deference is appropriate here, of course, because US-CIS interpreted and applied the relevant statutory and regulatory provisions to deny plaintiffs Q-l visa petitions. See Citizens Exposing Truth about Casinos v. Kempthorne, 492 F.3d 460, 466 (D.C.Cir.2007) (Chevron deference applies even in the absence of formal rulemaking or adjudication when agency action has the force of law).
Chevron analysis, of course, is a two-step framework that requires the court to first determine “whether Congress has directly spoken to the precise question at issue,” and then, if the intent of Congress is unclear, requires the court to review whether the interpretation offered by the agency is “based on a permissible construction of the statute.”18 Chevron, 467 U.S. at 842-43, 104 S.Ct. 2778. Here, although Congress raised the issue of the conditions of, and wages due to, cultural exchange programs participants, it did not speak directly to the meaning of several of the terms used in 8 U.S.C. § 1101(a)(15)(Q). Thus, the limited inquiry for this Court is whether USCIS’s position is “permissible” — that is, whether US-CIS offered a reasonable construction or application of the Q-l visa statute and its relevant regulations. For the following reasons, I believe the USCIS’s positions are, in fact, quite permissible.
In short, plaintiffs APA challenges focus on three issues: (1) the US-CIS’s determination that the interns were teacher assistants, Second Am. Compl. ¶¶ 169, 171, 179-80, 189-91; (2) the US-CIS’s determination that the interns were to be paid an “actual wage,” id. ¶¶ 163-164, 168, 170, 173-74, 178, 187; and (3) the USCIS’s decision to limit the visas’ validity to the schools’ academic calendar, id. ¶ 167, 177, 192.19 First, the Court must *98address again plaintiffs Department of Labor (“DOL”) argument. Plaintiff argues that the USCIS misapplied or misconstrued the DOL’s regulations in determining the comparable domestic worker and calculating the comparable wage. Pl.’s Mot. at 23-24. I disagree. As I have previously stated: Congress delegated authority to the Department of Homeland Security (and thus, to USCIS) — not the DOL — to regulate international cultural exchange programs. See 8 C.F.R. § 214.2(q)(l)(iii); Prelim. Inj. Mot. at 8 n. 8, 11. This authority undoubtedly extends not only to USCIS’s determinations of whether a nonimmigrant alien is being paid wages “comparable to ... local domestic workers,” 8 C.F.R. § 214.2(q)(4)(i)(D); Prelim. Inj. Op. at 11, but also to whether a nonimmigrant alien is experiencing “working conditions comparable to ... local domestic workers,” 8 C.F.R. § 214.2(q)(4)(i)(D), and to whether an employer “[mjaintains an established international cultural exchange program in accordance with the requirements set forth” in the Q-l regulations, id. § 214.2(q)(4)(i)(A). Furthermore, while the regulations for other nonimmigrant visas specifically require DOL involvement, the Q-l visa regulations contain no such condition. See, e.g., 8 C.F.R. § 214.2(h)(2)(i)(E) (requiring H-1C, H-1B, H-2A, or H-2B petitions to include a DOL determination). Thus, the USCIS may consider DOL regulations in reviewing petitions, but is not bound by their terms.
USCIS, both in its interpretation of the statute and in its application of the regulations, construes the “working conditions” of the interns to be “comparable to” teacher assistants, the “local domestic workers similarly employed.” 8 C.F.R. § 214.2(q)(4)(i)(D); 8 U.S.C. § 1101(a)(15)(Q); CAR at 798-99. In contrast, plaintiff argues that it “submitted considerable evidence” of the “working conditions enjoyed by the IIP cultural visitors” and those of volunteers and unpaid interns — the local domestic workers IIP argues are comparably employed, PL’s Mot. at 21; PL’s Opp’n at 10 — but that the USCIS “misconstrued [the] evidence” and “misapplied [the] DOL’s position description for [ ]teacher’s assistant” in making its determination.20 PL’s Mot. at 22. The Court finds, however, that USCIS offered a reasonable construction of the regulation supported by substantial evidence, see, e.g., CAR at 798-99 (reviewing HP’s petition, response to RFE, and motion to reconsider its petition', the AAO determined that “the level of time commitment, lesson preparation, teacher involvement and evaluation criteria present in the [HP’s] program make the position directly comparable to a paid teaching assistant rather than to those of a volunteer who offers services as a tutor or classroom helper on an informal basis”), and plaintiff has offered no evidence to show that this explanation is unreasonable.21
*99Similarly, the Court finds that in interpreting the statute and applying the regulations, USCIS permissibly construed “same wages,” 8 U.S.C. § 1101(a)(15)(Q), to presuppose the payment of some wages to recipients of Q-l visas, CAR at 1207. Plaintiff argues that, under DOL regulations, the interns are volunteers and, as such, can be and are paid zero wages. Pl.’s Mot, at 26; Pl.’s Opp’n at 14. As the Court previously stated, this argument ignores Congress’ pronounced use of the term “wages” and the reasonable implication that “wages” refers to some non-zero number. Prelim. Inj. Op. at 12. This interpretation is particularly reasonable in light of the statute’s legislative history. Congress sought to protect wages by implementing “[s]afeguards in terms of wages and working conditions ... in the bill,” see Defs.’ Mem. at 13 (quoting H.R. Rep. 101-723(1), at 81 (1990), reprinted in 1990 U.S.C.C.A.N. 6710, 6751), and the USCIS specifically noted that the program requirements “were designed to ensure that the sponsoring employer ... has the resources to ... remunerate the cultural visitors,” 57 Fed. Reg. 55056, 55058. Here, the USCIS concluded, based on the evidence, that the interns performed roles comparable to those of teacher assistants. CAR at 798-99. Based on defendants’ reasonable interpretation and plaintiffs admission that neither IIP nor the host schools pay the interns wages,22 Second Am. Compl. ¶¶ 43, 116; PL’s Mot. at 26, this Court will uphold this conclusion.
Finally, USCIS approves Q-l visas for the duration of time the “employer is conducting an approved international cultural exchange program ... not [to] exceed 15 months.” 8 C.F.R. § 214.2(q)(l)(in). *100Upon review of HP’s petitions, the USCIS found that HP’s program was not complying with the regulations’ cultural and work components during the summer and other extended breaks. See, e.g., CAR at 37; CAR at 32 (VSC requesting additional information from IIP “establish[ing] what the [interns] would be doing during the summer break period if the validity extends during those months and how these activities would relate to your cultural programs with the host schools”). Plaintiff offered limited evidence to support its assertion that the interns “participate in a local educational summer program or in other activities in furtherance of the [interns’] mission” during the extended breaks, see CAR at 1390, arguing that, in previous years, interns worked at summer schools or camps or enrolled in English language courses to improve their language skills, Pl.’s Mot. at 31; CAR at 2510 (“A copy of what the current participants did during the summer is attached.”); see CAR at 2724-35 (emails and surveys from past interns describing their summer activities). But, there is no guarantee that the interns will engage in these activities because summer plans are not pre-arranged; rather the interns must seek out potential summer opportunities once they arrive at their host schools. CAR at 1203-04, 2510. The USCIS, recognizing that IIP could request an extension of the visas, CAR at 32; 8 C.F.R. § 214.2(q)(10), found that based on the evidence submitted, IIP was unable to establish that the interns were engaging in cultural activities during the extended school breaks,23 CAR at 2256 (HP’s statement alone was “not sufficient to show that the [interns] will actually be participating in a cultural program during this time”). The Court finds this to be a reasonable interpretation.
Because USCIS reasonably construed the Q-l rule and regulations, and because plaintiff offers no persuasive legal explanation to show how USCIS’s interpretations of the regulations are not reasonable, the Court finds that USCIS’s denials of plaintiffs Q-l visa petitions were not contrary to law, arbitrary and capricious, contrary to constitutional right and privilege,24 or unsupported by substantial *101evidence. As such, defendants’ motion must be, and is, GRANTED.
CONCLUSION
For the reasons set forth above, defendants’ Partial Motion to Dismiss and Partial Motion for Summary Judgment [Dkt. # 33] is GRANTED and plaintiffs Cross-Motion for Summary Judgment [Dkt. # 37] is DENIED. An Order consistent with this decision accompanies this Memorandum Opinion.
SO ORDERED.
ORDER
For the reasons set forth in the Memorandum Opinion entered this 28th day of March 2012, it is hereby
ORDERED that defendants’ Partial Motion to Dismiss and Partial Motion for Summary Judgment [Dkt. # 33] is GRANTED; and it is further
ORDERED that plaintiffs Motion for Summary Judgment [Dkt. #37] is DENIED; and it is further
ORDERED that Counts I through IV in plaintiffs Second Amended Complaint [Dkt. # 9] are dismissed with prejudice for lack of subject-matter jurisdiction; it is further
ORDERED that Counts V and VI in plaintiffs Second Amended Complaint [Dkt. # 9] are dismissed without prejudice for failure to state a claim for relief.
SO ORDERED.