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Matter of: Green Valley Transportation, Inc. File: B-285283 Date: August 9, 2000

B-285283 Aug 09, 2000
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Highlights

Contracting agency's evaluation of offerors' past performance was unreasonable where (1) with respect to reports of past performance problems. Green Valley argues that the agency's evaluation of technical proposals with respect to past performance was unreasonable. MTMC awards what are. The cargo is allocated into 56 "lanes. Traffic was to be awarded to one primary carrier for each lane of traffic. Awards were to be made to the firms whose proposals were most advantageous to the government. Past performance was more important than service. Are the only aspects of the evaluation at issue here. /2/ Past performance "actions" were essentially problems that had arisen during performance. Range from letters of concern and letters of warning to letters of withdrawal and letters of removal. /3/ The RFP advised potential offerors that the technical evaluation team (TET) was to consider an offeror's past performance activity in MTMC's Optimum Benefit Negotiations.

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Matter of: Green Valley Transportation, Inc. File: B-285283 Date: August 9, 2000

DIGEST

Attorneys

DECISION

Green Valley Transportation, Inc. protests awards made under request for proposals (RFP) No. JD-5252-SH, issued by the Department of the Army, Military Traffic Management Command (MTMC), for guaranteed traffic (GT) freight transportation. Green Valley argues that the agency's evaluation of technical proposals with respect to past performance was unreasonable.

We sustain the protest.

The solicitation, issued January 25, 2000, sought to allocate cargo traffic lanes from the Defense Distribution Depot in San Joaquin, California (DDJC) to various points throughout the continental United States pursuant to the GT program. /1/ Under this program, MTMC issues a request for rate tenders for all the traffic for particular routes for a specific period of time. MTMC awards what are, in effect, requirements contracts to the successful carriers. Allstates Air Cargo, Inc., B-261266, B-261266.2, Feb. 29, 1996, 96-1 CPD Para. 138 at 2 n.3. Here, the cargo is allocated into 56 "lanes," each representing a combination of different equipment types, extent of equipment use, and destinations. The RFP anticipated the award of 56 contracts, one for each lane, to be performed between April 29, 2000 and April 28, 2001. RFP Cover Letter at 1.

Traffic was to be awarded to one primary carrier for each lane of traffic, with the possibility that alternate carrier selections might be made for each lane. Each offeror could be selected as a primary carrier or as an alternate for multiple lanes. RFP encl. 5, at 30. Awards were to be made to the firms whose proposals were most advantageous to the government, considering equally important price and technical factors. The solicitation set forth two technical evaluation factors, past performance and service; past performance was more important than service. RFP encl. 5, at 27-28. The past performance factor's two equally important subfactors--past performance "actions" and past percent on-time delivery--are the only aspects of the evaluation at issue here. /2/ Past performance "actions" were essentially problems that had arisen during performance, and range from letters of concern and letters of warning to letters of withdrawal and letters of removal. /3/

The RFP advised potential offerors that the technical evaluation team (TET) was to consider an offeror's past performance activity in MTMC's Optimum Benefit Negotiations, GT programs, and other Department of Defense (DOD) movements over the last 24 months. All performance actions, including loss and damage data and on-time delivery reports, were to be considered for the term of the current GT contracts, to include extensions. If the current GT contracts were shorter than 12 months, performance actions on the prior contracts were to be considered. /4/ The agency reserved the right to obtain and use other data pertaining to offerors' past performance in evaluating proposals. Id. at 28.

The agency received proposals from 36 carriers and conducted its evaluation. The price evaluation team input the offerors' rates into MTMC's automated system and arrived at total prices for each offeror for each lane. For each lane, the low-price offeror received the maximum number of price points, and all other offerors received prorated points. Traffic Manager's Statement of Facts Para. 5. Since prices varied from lane to lane, the points awarded for price varied for each offeror from lane to lane. Agency Memorandum of Law at 12 n.40.

In a similar fashion, the TET input such service subfactors as the offerors' proposed transit times and on-time delivery and refund percentages into MTMC's system and assigned points on a predetermined basis. Traffic Manager's Statement of Facts Paras. 7-8. The evaluation of past performance required a more subjective evaluation. For each proposal, each TET member assigned ratings of Outstanding, Excellent, Good, Fair, Poor, or Unsatisfactory to each past performance subfactor. The TET subsequently developed "caucus" ratings for each proposal; these ratings were converted into points. Id. Paras. 9-10. The ratings, and points, assigned to the two past performance subfactors remained constant for each offeror from lane to lane. For each proposal, the technical subfactor points were totaled, and the total was weighted by assigning [DELETED] points to the offeror with the most technical points and prorating the points for the remaining offerors. VT at 12:49. The weighted technical ratio was added to the total cost points to determine the total points for each offeror in each lane. The offeror with the most total points was ranked as the potential prime carrier, and alternate positions were identified for those offerors with the next highest totals. Awards were generally to be made on that basis. /5/ Traffic Manager's Statement of Facts Para. 11. All of the proposed awards and evaluation results were reviewed by an evaluation review panel (ERP) to ensure that all evaluations were made fairly and consistently. Id. at Para. 12.

On April 20, MTMC notified all offerors of the 56 awards, which had a total value of $14,463,108. Green Valley, whose proposal was rated [DELETED] for the past performance actions subfactor and [DELETED] for the past percent on-time delivery subfactor, was awarded contracts as the primary carrier on 8 lanes, and was named an alternate on 28 other lanes. After award, some primary carriers withdrew and the firm was awarded two additional lanes as the primary carrier.

In its protest of all of the awards, Green Valley argued that MTMC's past performance evaluation was faulty. In its comments, the firm specifically argued that MTMC improperly failed to consider all of the information available to it when evaluating proposals under the past performance actions and past percent on-time delivery subfactors, and narrowed its protest to the six lanes where it believed it was prejudiced by the agency's actions. /6/

Evaluation of an offeror's past performance is a matter within the discretion of the contracting agency, and we will not substitute our judgment for reasonably based past performance ratings. However, we will question such conclusions where they are not reasonably based or are undocumented. GTS Duratek, Inc., B-280511.2, B-280511.3, Oct. 19, 1998, 98-2 CPD Para. 130 at 16; PMT Servs., Inc., B-270538.2, Apr. 1, 1996, 96-2 CPD Para. 98 at 6. Here, we have reviewed the pleadings, the evaluation materials, the proposals, and explanations provided by the agency during a hearing conducted by our Office, and we conclude that MTMC's evaluation of technical proposals with respect to the two past performance subfactors was unreasonable.

Past Performance Actions

Each offeror was required to submit copies of any corrective measure it had taken in response to disciplinary actions against it by the shippers /7/ or MTMC over the relevant time period. This would ensure that any previous actions indicated in the offeror's performance file had been satisfactorily addressed. The TET planned to look for reasons, explanations, and clarifications for previous or current performance actions, such as withdrawals from awarded lanes as the primary carrier, and corrective actions on letters of concern, warnings, or suspensions. The TET was to assess the overall past performance actions, paying particular attention to those past performance actions and corrective measures that specifically pertained to DDJC. RFP encl. 6, at 32-33.

In addition to considering the information provided in proposals, the agency also considered materials it received from DDJC. These included on-time delivery statistics and DDJC assessments of offeror performance; copies of performance actions; loss and damage reports; and statistics on shipments moved by the offerors DOD-wide.

On their individual evaluation forms, the TET members summarized the [DELETED] negative performance actions received by Green Valley during the period 1997-99, as well as its [DELETED] letters of appreciation from DDJC. They also cited DDJC's comment that the firm had [DELETED], and the fact that Green Valley carried 27,184 shipments for DDJC and 39,441 shipments--approximately 155 million pounds--for DOD overall during the period 1997-99.

The TET's caucus evaluation form stated that Green Valley's proposal failed to meet the requirements for this subfactor. The TET stated that the firm had "numerous performance actions, many of which occurred at DDJC, which were taken into consideration. Volume of freight handled over past 3 years was considered. Moderate volume of DDJC shipments was also considered." The TET rated Green Valley's proposal as [DELETED] for this subfactor.

The Deputy Director of the Joint Traffic Management Office (JTMO), in his capacity as chair of the ERP, reviewed the evaluation results and raised the firm's rating from [DELETED] to [DELETED] because he believed that Green Valley's "past performance problems, [DELETED], and [DELETED] certificates of appreciation from DDJC, are more consistent with the [DELETED] of the other carriers. In addition, the letter from DDJC depot was very positive and carried some weight regarding past performance." AR, Tab 11, at 1.

Green Valley argues that the TET improperly discounted its volume of shipments in rating its proposal. The protester asserts that it had fewer negative performance actions relative to its number of shipments than one offeror with a higher rating and fewer than another offeror with the same rating. /8/ The protester contends that it performed better than either of those offerors and should have been rated [DELETED] and not [DELETED]. Our review of the evaluation record shows that the evaluation was unreasonable in this regard and several others.

First, the record shows that, while the TET "considered" the volume of freight the offerors carried over the past 3 years, there is no indication of how that consideration factored into the overall ratings. When asked about this during the hearing conducted by our Office, the TET chairperson merely repeated the statements made on the TET's caucus evaluation form for Green Valley and asserted that the TET felt it gave the right rating. VT at 13:42-44, 52-53. She confirmed the protester's assertion that the TET did not consider the number of performance actions received by an offeror as a proportion of the number of shipments it made over the relevant time period. VT at 13:44.

In our view, it was unreasonable for MTMC to compare the absolute number of negative performance actions an offeror received, without considering that number in the context of the number of shipments the offeror had made over the relevant time period.

The differences between the protester and one of the offerors to which it refers demonstrate the irrationality of the agency's approach. DOD-wide statistics for the 3-year period show that Green Valley made 39,441 shipments of approximately 155 million pounds and received [DELETED] negative performance actions. The other offeror, which was given the same [DELETED] rating, made only 760 shipments of approximately 12 million pounds and received [DELETED] negative performance actions. AR, Tab 10 attach. 8; Agency Post-Hearing Comments at 10 nn.8, 11.

We view it as irrational to focus only on the absolute number of performance problems and not to take into account the size of the universe of performance in which those problems occurred. The protester would apparently have the agency simply calculate the number of negative performance actions a carrier received as a percentage of its overall number of shipments. Such a mathematical comparison might be reasonable as a general matter, but it is inadequate here because the RFP clearly contemplated a reasoned analysis of the substance of the performance actions that might neutralize any potential distortions between the carriers. This fact leads directly to the second problem with the evaluation.

The RFP required the TET to "look for reasons, explanations and clarifications for previous or current performance actions." RFP, encl. 6, at 33. During the hearing, the TET chairperson stated that, if a proposal set forth reasonable justifications for a performance action, the action was weighed less heavily against the offeror. VT at 14:07. The contemporaneous evaluation documentation contains no evidence that the TET performed this reasoned analysis of the past performance information at its disposal. There is no indication that the performance actions were reviewed to ascertain whether it was the offeror, rather than the shipper, that was at fault; whether the offerors had taken corrective actions to resolve problems; whether certain problems were recurring; or whether inclement weather or another factor beyond the offerors' control was a factor. In this regard, while Green Valley's proposal set forth explanations for various performance actions, none of them appear to have been considered. As to all the proposals, there is no indication as to which justifications offered, if any, were considered to be reasonable or which performance actions, if any, were weighed less heavily against an offeror.

In fact, the record suggests that such a qualitative assessment was not the basis for the ultimate ratings. The Deputy Director of the JTMO stated during the hearing that, in his capacity as the chairperson of the ERP, he considered whether the offerors received a minimal, moderate, or excessive number of performance actions in reviewing and revising the ratings. He considered that a minimal number of actions would be zero, one, or perhaps two, if the second action was not "major"; a moderate number of actions would be three, four, or five; and actions in the "upper digits" would be significant. VT at 13:40-41.

His reference to a "major" performance action is the only evidence that a qualitative assessment was made, and refers to the fact that some performance actions are considered to be more serious than others. In this regard, along the spectrum of performance actions, letters of concern are considered to be minor and letters of warning are considered to be more critical, followed by withdrawals and, then, removals. VT at 14:06-07. However, to the extent that the TET did consider the minor or major nature of the offerors' performance actions, there is no indication in the record as to how such a consideration related to the ratings. Moreover, the fact that the TET equated one letter of withdrawal from one lane to one letter of withdrawal from five lanes, VT at 14:05-09, raises the question whether any qualitative evaluation that did occur was meaningful.

Overall, MTMC's failure to fully analyze the substance of the past performance data at the agency's disposal, including the volume of freight carried, was inconsistent with the solicitation's evaluation criteria. The agency's factual assessment of offerors' performance is devoid of the qualitative analysis that this RFP required, and the agency's approach may have yielded evaluation results that were distorted by differing levels of performance. To the extent that the TET performed a qualitative analysis here, it is not documented. In order for our Office to perform a meaningful review of an agency's selection determination, an agency is required to have adequate documentation to support its evaluation of proposals and its selection decision. Biospherics Inc., B-278508.4 et al., Oct. 6, 1998, 98-2 CPD Para. 96 at 4. In the absence of such documentation, we cannot conclude that the evaluation was reasonable.

Past Percent On-Time Delivery

Each offeror was required to submit a summary of its delivery reports with DDJC. Offerors without prior shipments from DDJC could submit a summary of their delivery reports from other DOD, non-DOD government, or commercial customers. The TET was to evaluate proposals "based on all available information," giving emphasis to the performance achieved specifically at DDJC. RFP encl. 6, at 33. The agency considered a [DELETED] percent on-time rate to be the minimum requirement. VT at 12:53-54.

The record shows that, in evaluating proposals under this subfactor, the TET reviewed the past percent on-time delivery information set forth in the offerors' proposals and statistics and comments provided by DDJC. At issue here is the evaluation of that data with respect to Green Valley and another carrier. The protester contends that the two offerors had "nearly identical" past percent on-time delivery rates, but that its proposal was rated [DELETED] while the other carrier's proposal was rated [DELETED]. Green Valley argues that its rating should be raised to [DELETED] and/or the other carrier's rating reduced to [DELETED].

Green Valley's proposal stated that its on-time delivery percentage for several velocity lanes /9/ from DDJC and another depot ranged between [DELETED] and [DELETED] percent, and noted that it had received an award for its on-time delivery record for one of those lanes. Protester's Proposal, Tab 4. Green Valley made no representations as to its on-time delivery percentage for non-velocity lanes, but statistics provided by DDJC indicated that the firm delivered 8,621 shipments in 1997 with a [DELETED]-percent on-time rate; 14,825 shipments in 1998 with a [DELETED]-percent on-time rate; and 3,738 shipments in 1999 with a [DELETED]-percent on-time rate. AR, Tab 10, attach. 4. DDJC advised the TET that, under its current contracts, Green Valley was delivering at [DELETED] percent for velocity lanes and at [DELETED] percent and above for four other lanes. AR, Tab 10, attach. 5.

The only comment on the TET's caucus evaluation form for Green Valley noted that DDJC documents reflected an average above the [DELETED]-percent on-time requirement. The firm's proposal was rated [DELETED] for this subfactor.

The other carrier's proposal stated that, under its prior DDJC GT contract, it delivered [DELETED] percent of its shipments on time and, under the current GT contract, it had delivered 172 shipments with a [DELETED]-percent on-time rate. AR, Tab 9, attach. B. Statistics provided by DDJC showed that the carrier delivered 169 shipments in 1997 with a [DELETED]-percent on-time rate; 734 shipments in 1998 with a [DELETED]-percent on-time rate; and 174 shipments in 1999 with a [DELETED]-percent on-time rate. AR, Tab 10, attach. 4. DDJC advised the TET that, under its current contract, the firm was delivering at [DELETED] percent. AR, Tab 10, attach. 5.

The TET's caucus evaluation form for the carrier noted the DDJC statistics for 1997-99 and, referring to a notation on DDJC's monthly on-time statistics, stated that the low on-time rate for 1997 was due to a humanitarian project that resulted in increased volume for which the carrier was not prepared. The TET stated that, since the carrier's on-time rate was usually [DELETED] percent, its on-time performance would have exceeded the [DELETED] percent standard without the humanitarian project. The firm's proposal was rated [DELETED] for this subfactor.

In its comments, Green Valley contended that if the rates for the years 1997-99 are averaged, its on-time delivery rate is [DELETED] percent as compared with the other carrier's [DELETED] percent. The protester contends that there was thus no rational basis for rating the two other firm's performance higher than Green Valley's.

MTMC did average the rates over the years 1997-99 to arrive at an overall past on-time delivery rate. VT at 13:04, 13:12. By the agency's calculation, this meant that the protester's average rate was somewhat more than [DELETED] percent. VT at 13:03-04. Since this rate slightly exceeded the minimum requirement of [DELETED] percent, Green Valley's proposal received a [DELETED] rating instead of the [DELETED] rating reserved for proposals where the response "[DELETED]." VT at 13:03, 22-23; AR, Tab 10, attach. 1.

However, in evaluating the other offeror's proposal, MTMC "set aside" the firm's low 1997 rate as an anomaly. VT at 14:00-01; 13:12. As noted above, the TET cited DDJC's comment that the low rate resulted from a humanitarian project that presented the offeror with unexpected volume. The TET concluded that, since DDJC said that the offeror normally maintained a [DELETED] percent on-time rate, the low rate was not representative of the firm's performance and need not be considered. Instead, the TET averaged the offeror's remaining on-time rates to obtain a rate of approximately [DELETED] percent. VT at 13:04, 12, 14:00-01. Since the other offeror's rate was [DELETED] points above the minimum requirement, it received an [DELETED] rating. VT at 13:22-23, 56. The [DELETED] rating was reserved for proposals where the response "[DELETED]." AR, Tab 10, attach. 1.

Green Valley objects that the agency's "setting aside" of the other offeror's low 1997 rate was improper because the humanitarian project was only one reason why the carrier's on-time percent delivery rate for the year was low.

We think that MTMC properly considered the effect of the humanitarian project on the other offeror's past on-time percent delivery rate, and that its effort to avoid penalizing the offeror for an unexpected surge in its requirements that was beyond its control was reasonable. On the other hand, the protester is correct that the humanitarian project is not the sole reason for the low rate. The humanitarian project occurred in August and September 1997 but, prior to that time, the offeror had monthly ratings on these lanes of [DELETED], [DELETED], and [DELETED] percent. There is no explanation for these low rates in the record, and we cannot conclude that it was reasonable for MTMC to ignore them. In its post-hearing comments, the agency appears to recognize this problem and has calculated the other offeror's 1997 on-time percent delivery rate absent the humanitarian projects. Agency's Post-Hearing Comments at 6 n.3. The rate is [DELETED] percent. Using the agency's methodology of averaging the annual ratings for the period at issue, the other offeror's rate would be [DELETED] percent, essentially equal to Green Valley's overall rate ([DELETED] percent).

Moreover, as MTMC acknowledges in its post-hearing comments, the evaluation was not based on a straight percentage of past on-time deliveries; the RFP's instruction to consider "all available information" gave the TET the broad discretion to consider more information than simply straight on-time delivery percentage rates. In this regard, Green Valley complains that the TET failed to give it any credit for performing at a high-volume level. The other offeror's proposal was rated [DELETED] when its on-time rate was [DELETED] percent for 1,077 shipments over the 3-year period, and Green Valley's proposal was rated [DELETED] when its on-time rate was [DELETED] percent for 27,184 shipments over the same 3-year period.

The TET chairperson confirmed that the TET did not consider the volume of shipments made when evaluating proposals under this subfactor, but went only by the percentages provided by DDJC. VT at 13:06-07. The Deputy Chief of the JTMO states that the ERP did consider volume in making the final determination as to ratings by looking at the volume of shipments to ensure that an offeror had made enough shipments to show regular service. If the number of shipments made in a year showed monthly or even weekly service, the percentages were deemed to be reliable. VT at 13:57. The other offeror's number of shipments worked out to approximately 100 per month and 25 per week, and that was deemed to be significant enough to rely on the percentages. Id. at 13:59-14:00.

While the agency's use of shipping volume in this narrow context is reasonable, we believe that, in light of the terms of this RFP, the agency's failure to consider the implications of shipping volume was improper. In our view, the RFP's explicit instruction to consider "all available information" included the volume of freight shipped by each offeror. Such consideration could become particularly important when the vast difference between the numbers of shipments made by these two offerors may suggest a difference in the reliability of their past on-time percent delivery rates. See DDD Co., B-276708, July 16, 1997, 97-2 CPD Para. 44 at 5-6 n.4. We do not know if a consideration of the relative volume of freight carried would have made a difference here, or that, as a general matter, an on-time percent delivery rate for an offeror that has shipped a large volume of freight should be given more credence than the rate of an offeror that has shipped considerably less freight. It is clear, however, that in this case the agency did not consider the volume of freight carried by the various offerors. In its post-hearing comments, MTMC takes one of the lanes on which Green Valley has performed and argues that the fact the destination point is near DDJC could mean that its on-time percent delivery rate is inflated. Agency's Post-Hearing Comments at 8-9. This type of analysis is precisely that contemplated by the RFP and absent from the contemporaneous documentation for all of the offerors, including these two.

The record shows that Green Valley might have been in line to receive a contract as primary carrier, or to be named as the first alternate on the protested lanes, if the agency had reasonably evaluated technical proposals under these two subfactors. See Agency Post-Hearing Comments at exh. 1. As a result, the firm was prejudiced by MTMC's failure to do so. We recommend that the agency reevaluate the proposals with respect to these two subfactors. If the reevaluation shows that previously made award decisions should be revised, the agency should terminate the appropriate contracts at that time and make award to Green Valley or other appropriate offerors. /10/ We also recommend that the protester be reimbursed the reasonable costs of filing and pursuing the protest, including attorneys' fees. 4 C.F.R. Sec. 21.8(d)(1). The protester should submit its certified claim for such costs, detailing the time expended and the costs incurred, directly to the contracting agency within 60 days after receipt of this decision.

The protest is sustained.

Robert P. Murphy General Counsel

1. This procurement is a resolicitation of these requirements following the termination for convenience of awards made under the prior solicitation. The termination of the prior awards was the result of corrective action taken in response to a protest filed in this Office.

2. Green Valley contended that, under the service factor, MTMC should have analyzed the specific on-time percentage rates and refunds it proposed for each lane, and not used a constant factor for all lanes. This issue is untimely. MTMC advised the firm on March 6 that the rates for each lane had to be the same because the agency's automated system would not accept different rates. MTMC asked the firm to choose a percentage it would like to propose and to permit MTMC to make this change on all of its tenders. Green Valley granted MTMC this permission on March 8. Agency Report (AR), Tab 8. If Green Valley was concerned with MTMC's evaluation methodology, it was required to raise this concern prior to the closing date. Bid Protest Regulations, 4 C.F.R. Sec. 21.2(a)(1) (2000). Given the clear language in its communications with MTMC on this subject, Green Valley's assertion that it "understood" MTMC would consider the multiple rates is unpersuasive. In addition, numerous other issues raised in the protest were addressed by the agency report and unrebutted in the comments. We deem those issues to have been abandoned. TMI Servs., Inc., B-276624.2, July 9, 1997, 97-2 CPD Para. 24 at 4 n.3.

3. A carrier may advise the government by letter that it is withdrawing its service on a lane or lanes because it is unable or unwilling to do so, and the government may advise a carrier by letter that it is removing that carrier from service on a lane or lanes due to various service failures. MTMC Guaranteed Traffic Rules Publication No. 50, at 1-5, 1-6.

4. Since the current GT contracts were shorter than 12 months, the TET considered performance actions and on-time delivery reports dating back to the previously awarded contract, or 1997. Videotape of Hearing (VT) at 12:51.

5. The RFP stated that the government might choose to pay a higher price to an offeror whose performance risk and price reasonableness gave the government greater confidence in that offeror's ability to keep its commitments. RFP encl. 5, at 30.

6. These lanes are 35 (Southwest Sub-Region 1, California); 43 (Northwest Region, Oregon and Washington); 50 (Fort Carson, Colorado); 51 (Tinker Air Force Base, Oklahoma); 55 (Travis Air Force Base, California); and 56 (the Defense Depot at Susquehanna, Pennsylvania). AR, Tab 13.

7. The shipper is the government entity whose freight is being shipped. See generally RFP encl. 2.

8. We do not agree with Green Valley's assertion that the agency had to give higher ratings to offerors who had made substantial numbers of shipments for DDJC. The RFP expressed no preference for shipping experience with DDJC, and specifically stated that the agency would consider an offeror's past performance activity in "other DOD movements." RFP encl. 5, at 28.

9. Velocity lanes are those where shipments are made directly from the depot to an Army installation and must be delivered immediately. VT at 13:26.

10. While the reevaluation may ultimately affect only the six lanes to which Green Valley limited its protest, the improper evaluation methodology under these two subfactors extended to all 56 lanes covered by the solicitation since the ratings and points assigned to the two past performance subfactors remained constant for each carrier for all lanes bid.

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