B-181336, SEP 13, 1974

B-181336: Sep 13, 1974

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GAO DOES NOT BELIEVE AIR FORCE'S REQUIREMENT THAT AIRCRAFT SIMULATORS BE EQUIPPED WITH 24-BIT OR LONGER MEMORY WORD LENGTH COMPUTERS IS UNREASONABLE SINCE A SMALLER COMPUTER REPORTEDLY HAS NO PROVEN CAPABILITY IN SIMULATION OF SUPERSONIC AIRCRAFT AND 24-BIT OR LONGER COMPUTERS ARE EASIER TO SUPPORT THAN SMALLER COMPUTERS. DETERMINATION OF GOVERNMENT'S NEEDS AND METHOD OF MEETING THEM IS PRIMARILY FOR PROCURING AGENCY. ESPECIALLY WHEN EQUIPMENT IS HIGHLY SPECIALIZED. GAO WILL NOT QUESTION SUCH DETERMINATION WHERE. THERE IS NO EVIDENCE OF ABUSE OF DISCRETION. 2. THEREBY RESULTING IN VIRTUAL SOLE SOURCE PROCUREMENT FROM MANUFACTURER OF 24-BIT COMPUTER IS DENIED SINCE AIR FORCE REPORTS THAT OTHER FIRMS DO PRODUCE 24-BIT COMPUTERS.

B-181336, SEP 13, 1974

1. GAO DOES NOT BELIEVE AIR FORCE'S REQUIREMENT THAT AIRCRAFT SIMULATORS BE EQUIPPED WITH 24-BIT OR LONGER MEMORY WORD LENGTH COMPUTERS IS UNREASONABLE SINCE A SMALLER COMPUTER REPORTEDLY HAS NO PROVEN CAPABILITY IN SIMULATION OF SUPERSONIC AIRCRAFT AND 24-BIT OR LONGER COMPUTERS ARE EASIER TO SUPPORT THAN SMALLER COMPUTERS. DETERMINATION OF GOVERNMENT'S NEEDS AND METHOD OF MEETING THEM IS PRIMARILY FOR PROCURING AGENCY, ESPECIALLY WHEN EQUIPMENT IS HIGHLY SPECIALIZED, AND GAO WILL NOT QUESTION SUCH DETERMINATION WHERE, AS HERE, THERE IS NO EVIDENCE OF ABUSE OF DISCRETION. 2. PROTEST THAT ONLY ONE COMPUTER FIRM MAKES 24-BID COMPUTER AND THAT NO OTHER FIRM CAN BE PRICE COMPETITIVE, THEREBY RESULTING IN VIRTUAL SOLE SOURCE PROCUREMENT FROM MANUFACTURER OF 24-BIT COMPUTER IS DENIED SINCE AIR FORCE REPORTS THAT OTHER FIRMS DO PRODUCE 24-BIT COMPUTERS. FURTHERMORE, EVEN FIRMS MANUFACTURING LONGER WORD LENGTH COMPUTER COULD BE PRICE COMPETITIVE SINCE RFP ALLOWS ANY COMPUTER CONFIGURATION CONSISTENT WITH PROCESSING LOAD REQUIREMENTS. 3. PROTEST THAT PROVISION IN RFP FOR AIRCRAFT SIMULATORS REQUIRING THAT COMPUTERS BE OF 24-BIT OR LONGER WORD LENGTH VIOLATES OMB CIRCULAR A-54, DOD DIRECTIVE 4105.55, AND FPMR 101-32.4 IN THAT IT PRECLUDES COMPETITION ON THE BASIS OF A WORKLOAD SPECIFICATION DENIED, SINCE THESE REGULATIONS APPLY SOLELY TO PROCUREMENT OF ADPE, AND AIRCRAFT SIMULATORS, BEING SPECIALLY DESIGNED FOR A SPECIFIC APPLICATION ARE NOT ADPE. MOREOVER, GAO HAS NO BASIS TO DISAGREE WITH AIR FORCE POSITION THAT RFP METHOD OF EXPRESSING COMPUTER NEEDS ALLOWED OFFERORS GREATER FLEXIBILITY IN SIMULATOR DESIGN THAN METHOD URGED BY PROTESTER.

DIGITAL EQUIPMENT CORPORATION:

ON DECEMBER 21, 1973, REQUEST FOR PROPOSALS (RFP) NO. F33657-74-R 0253 WAS ISSUED BY AIR FORCE, AERONAUTICAL SYSTEMS DIVISION (AFSD), FOR THE PROCUREMENT OF T-37 AND T-38 INSTRUMENT FLIGHT SIMULATORS, INCLUDING COCKPITS, MOTION SYSTEMS, TV PROBE/TERRAIN MODEL BOARD IMAGE GENERATORS AND OTHER EQUIPMENT, FOR UNDERGRADUATE PILOT TRAINING (UPT). THE PROCUREMENT ALSO INCLUDES A REQUIREMENT FOR A DIGITAL COMPUTATION SYSTEM TO ACTIVATE AND SUPPORT EACH SIMULATOR COMPLEX. THE TOTAL ESTIMATED PROCUREMENT VALUE INCLUDING AN OPTION IS $60.2 MILLION.

DIGITAL EQUIPMENT CORPORATION (DIGITAL), A COMPUTER MANUFACTURER, TIMELY PROTESTS AGAINST THE INCLUSION OF A PROVISION IN THE RFP WHICH ESTABLISHES A MINIMUM MEMORY WORD LENGTH FOR COMPUTERS IN THE SIMULATOR COMPLEXES. SPECIFICALLY, DIGITAL CONTENDS THAT THE SECTION OF THE RFP WHICH CALLS FOR COMPUTERS WITH A MINIMUM MEMORY WORD LENGTH OF 24-BITS IS UNDULY RESTRICTIVE.

FOR REASONS DISCUSSED BELOW THE PROTEST IS DENIED.

DIGITAL CONTENDS THAT MEMORY WORD LENGTH IS NOT A RELEVANT CONSIDERATION IN DETERMINING WHETHER A COMPUTER CAN ADEQUATELY PERFORM THE TASKS IN THE SIMULATOR COMPLEXES. DIGITAL MAINTAINS THAT ITS OWN 16-BIT MEMORY LENGTH COMPUTER CAN ADEQUATELY MEET THE REQUIREMENTS OF ANY AIRCRAFT SIMULATOR, REGARDLESS OF WHETHER THE AIRCRAFT BEING SIMULATED IS OF HIGH OR MEDIUM PERFORMANCE. IN SUPPORT OF THESE CONTENTIONS, DIGITAL NOTES THAT NUMEROUS COMMERCIAL AND MILITARY AIRCRAFT FLIGHT SIMULATORS (INCLUDING THOSE FOR THE 737, DC-8, DC-9, 727, F-28, P3C, S3A AND T2C) HAVE SUCCESSFULLY UTILIZED 16-BIT COMPUTERS. FROM THIS, DIGITAL CONCLUDES THAT SIMULATORS BASED ON 16 BIT COMPUTERS ARE AVAILABLE, PROVEN, AND OFFER A LOW RISK FACTOR.

IN RESPONSE, THE AIR FORCE STATES THAT COMPUTER MEMORY WORD LENGTH IS DEFINITELY RELEVANT TO THE SIMULATION OF A HIGH PERFORMANCE AIRCRAFT AND THAT TECHNICALLY VALID REASONS EXIST FOR REQUIRING A 24-BIT MINIMUM COMPUTER RATHER THAN A 16-BIT COMPUTER.

FIRST, THE AIR FORCE STATES THAT THE KEY CONSIDERATION IN ITS DETERMINATION TO REQUIRE A 24-BIT MINIMUM MEMORY LENGTH COMPUTER IS THE RISK INVOLVED IN USING A 16-BIT COMPUTER IN THIS APPLICATION. THE UPT PROCUREMENT IS A PRODUCTION PROGRAM. THE AIR FORCE CONTENDS, THEREFORE, THAT IT IS IMPERATIVE THAT ALL ASPECTS OF THE UPT PROCUREMENT BE AT THE LOWEST OBTAINABLE RISK. IN THIS REGARD, THE AIR FORCE NOTES THAT THE T-38 AIRCRAFT, WHICH THE PROPOSAL PROCUREMENT WILL SIMULATE, IS HIGH PERFORMANCE, HIGHLY MANEUVERABLE, SUPERSONIC TWIN ENGINE JET AIRCRAFT. PROVEN CAPABILITY TO SIMULATE THIS CLASS OF AIRCRAFT PERFORMANCE WITH COMPUTERS OF LESS THAN 24-BIT WORD LENGTH DOES NOT EXIST. IN ADDITION, THE AIR FORCE POINTS OUT THAT A VISUAL SYSTEM IS BEING INCORPORATED INTO THE SIMULATOR WHICH WILL REQUIRE HIGHER MATH MODEL IMPLEMENTATION, THUS IMPOSING ADDITIONAL AND MORE EXTENSIVE REAL-TIME PROCESSING DEMANDS ON THE FLIGHT SIMULATOR COMPUTATION SYSTEM. CONSIDERING THE NATURE OF THE AIRCRAFT BEING SIMULATED AND THE PROCESSING DEMANDS OF THE COMPTUER SYSTEM, THE AIR FORCE CONSIDERS IT TO BE AN UNACCEPTABLE RISK TO EMPLOY LESS THAN A WELL-ESTABLISHED AND PROVEN COMPUTATIONAL SYSTEM.

IN RESPONSE TO DIGITAL'S CONTENTION THAT THE 16-BIT COMPUTER HAS PERFORMED SUCCESSFULLY IN NUMEROUS MILITARY AND COMMERCIAL AIRCRAFT SIMULATOR COMPLEXES, THE AIR FORCE NOTES THAT THE LIST SUPPLIED BY DIGITAL OF SIMULATORS BASED ON 16-BIT COMPUTERS DOES NOT INCLUDE A SIMULATOR OF EQUIVALENT OR EVEN NEAR EQUIVALENT AIRCRAFT PERFORMANCE AND MANEUVERABILITY TO THE T-38. FURTHERMORE, THE ONLY SIMULATOR LISTED THAT INCORPORATES A VISUAL SYSTEM IS THE MUCH LOWER PERFORMANCE 727. ON THE OTHER HAND, THE AIR FORCE POINTS OUT THAT OVER 60 SUPERSONIC SIMULATORS ARE PRESENTLY IN OPERATION UTILIZING 24-BIT OR LONGER WORD LENTH COMPUTERS, SEVERAL OF WHICH CONTAIN VISUAL SYSTEMS.

SECONDLY, THE AIR FORCE STATES THAT 16-BIT COMPUTERS ARE NOT TECHNICALLY EQUAL TO 24-BIT COMPUTERS OR LONGER WORD LENGTH COMPUTERS IN EASE OF PROGRAMMING. EASE OF PROGRAMMING A COMPUTER DIRECTLY AFFECTS LIFE CYCLE SUPPORTABILITY CONSIDERATIONS. IN THIS CONNECTION, THE AIR FORCE STATES IN ITS REPORT:

"SIXTEEN-BIT COMPUTERS ARE LESS POWERFUL IN TERMS OF LIMITED COMPUTER INSTRUCTION SET CAPABILITY, LESS CAPABILITY PER INSTRUCTION, MEMORY ADDRESSING AND EXPANSION LIMITATIONS, SIGNIFICANTLY RESTRICTED PRECISION PER DATA WORD, AND RESTRICTED PRECISION AND ACCURACY OF SINGLE WORD NUMERICAL CALCULATIONS. IN REAL-TIME TRAINING SIMULATOR APPLICATIONS OF 16-BIT COMPUTERS, THE NECESSITY FOR MULTIPLE WORD INSTRUCTIONS AND DOUBLE PRECISION INSTRUMENTS UNNECESSARILY COMPLICATES THE SOFTWARE PROGRAM. THE SOFTWARE WRITTEN FOR LONGER WORD LENGTH COMPUTERS IS EASIER TO DOCUMENT DUE TO THE MORE POWERFUL ARCHITECTURE AND INSTRUCTION DOCUMENT DUE TO THE MORE POWERFUL ARCHITECTURE AND INSTRUCTION CAPABILITIES INHERENT WITH 24- BIT AND LONGER WORD LENGTH COMPUTERS."

DIGITAL ALLEGES THAT PROGRAMMING FOR THIS PROJECT WILL BE DONE BY THE SIMULATOR CONTRACTOR RATHER THAN BY THE AIR FORCE, AND THAT, THEREFORE, EASE OF PROGRAMMING IS NOT A RELEVANT CONSIDERATION IN THE TYPE OF COMPUTER TO BE USED IN SIMULATOR COMPLEXES. DIGITAL FURTHER STATES THAT ANY AIR FORCE PROGRAMMING WILL BE MINIMAL AND WILL ONLY INVOLVE SYSTEM MAINTENANCE WHERE, AGAIN, THE VENDOR WOULD HAVE AN ONGOING CONCERN. THE AIR FORCE DISAGREES WITH DIGITAL'S POSITION, STATING THAT ALTHOUGH INITIAL PROGRAMMING WILL BE ACCOMPLISHED BY THE SIMULATOR CONTRACTOR, THE AIR FORCE WILL SUPPORT THE SYSTEM INCLUDING SOFTWARE CHANGES AND DEVELOPMENT OF NEW SOFTWARE. THESE CHANGES WILL NOT INVOLVE MAINTENANCE ALONE BUT WILL INCLUDE THE DEVELOPMENT AND IMPLEMENTATION OF NEW PROGRAMS SUCH AS STUDENT SCORING ALGORITHMS.

AS A GENERAL RULE, WE HAVE HELD THAT A DETERMINATION OF THE NEEDS OF THE GOVERNMENT AND THE METHOD OF ACCOMMODATING SUCH NEEDS IS PRIMARILY THE RESPONSIBILITY OF THE PROCURING AGENCY, AND IN THE ABSENCE OF CONVINCING EVIDENCE THAT ADMINISTRATIVE DISCRETION WAS ABUSED, WE HAVE NO BASIS FOR FURTHER INQUIRY, ESPECIALLY WHERE, AS HERE, THE PROCUREMENT IS FOR EQUIPMENT OF A HIGHLY SPECIALIZED NATURE AND THE DETERMINATION MUST BE BASED ON EXPERT TECHNICAL OPINION. SEE 49 COMP. GEN. 463, 471 (1970). THEREFORE, BASED ON AIR FORCE'S STATED RATIONALE FOR SPECIFYING 24-BIT OR LONGER WORD LENTH COMPUTERS, WE DO NOT HAVE ANY LEGAL OBJECTIONS TO THIS REQUIREMENT.

DIGITAL ALSO CONTENDS THAT SINCE ONLY ONE COMPUTER MANUFACTURER, DATACRAFT, MAKES A 24-BIT COMPUTER, THE REQUIREMENT IN THE RFP VIRTUALLY ASSURES THAT DATACRAFT'S 24-BIT COMPUTER WILL BE INCLUDED IN ALL PROPOSALS. IT IS DIGITAL'S POSITION THAT EVEN THOUGH 24-BIT OR LONGER WORD LENGTH COMPUTERS ARE REQUIRED, FIRMS OTHER THAN DATACRAFT CANNOT BE PRICE COMPETITIVE ON THIS PROJECT. DIGITAL STATES THAT "THIS CAN ONLY BE CONSIDERED AS A VIRTUAL SOLE SOURCE PROCUREMENT FOR A DATACRAFT COMPUTER."

HOWEVER, THE AIR FORCE STATES THAT DATACRAFT IS NOT THE ONLY FIRM WHICH MANUFACTURES A 24-BIT WORD LENGTH COMPUER. FURTHERMORE, THE AIR FORCE ARGUES THAT EVEN IF DATACRAFT WERE THE ONLY MANUFACTURER OF A 24 BIT MACHINE, IT CANNOT BE AUTOMATICALLY ASSUMED THAT THE DATACRAFT COMPUTER WOULD BE THE MOST ECONOMICAL IN TERMS OF THE TOTAL SIMULATOR COMPLEX. THIS IS SO BECAUSE THE UNIT PROCUREMENT QUANTITY OF THE RFP IS A COMPLEX MADE UP OF FOUR COCKPITS. THE AIR FORCE DID NOT SPECIFY THE COMPUTER CONFIGURATION FOR A COMPLEX OF FOUR COCKPITS. SECTION 3.7.3.1.1. OF THE RFP LEAVES THE DECISION ON THE OPTIMUM COMPUTER CONFIGURATION TO THE SIMULATOR MANUFACTURER. THEREFORE, THE AIR FORCE STATES THAT IT IS POSSIBLE FOR AN OFFEROR TO PROPOSE ONE OR TWO 32-BIT COMPUTERS TO HANDLE ALL FOUR COCKPITS, OR ONE 24-BIT COMPUTER FOR EACH COCKPIT, OR ANY OTHER CONFIGURATION CONSISTENT WITH PROCESSING LOAD REQUIREMENTS. ACCORDINGLY, THE COST ADVANTAGE OF A 24-BIT SYSTEM CANNOT BE DETERMINED BY COMPARING THE RELATIVE COSTS OF ONE 24-BIT COMPUTER WITH ONE 32-BIT COMPUTER, AND THEREFORE, IT CANNOT BE SAID THAT THE RFP DICTATES THAT A DATACRAFT COMPUTER BE USED IN ANY PROPOSAL SIMULATOR COMPLEX.

FINALLY, DIGITAL ARGUES THAT THE REQUIREMENT IN THE RFP FOR COMPUTERS WITH A MINIMUM MEMORY WORD LENGTH OF 24-BITS IS IN VIOLATION OF OFFICE OF MANAGEMENT AND BUDGET (OMB) CIRCULAR NO. A-54, DEPARTMENT OF DEFENSE (DOD) DIRECTIVE NO. 4105.55, AND FEDERAL PROPERTY MANAGEMENT REGULATIONS (FPMR) 101-32.4, IN THAT IT PRECLUDES FREE AND OPEN COMPETITION ON THE BASIS OF A WORKLOAD SPECIFICATION.

WE NOTE, HOWEVER, THAT ALL OF THE ABOVE-CITED REGULATIONS APPLY SOLELY TO THE PROCUREMENT OF AUTOMATIC DATA PROCESSING EQUIPMENT (ADPE). ADPE IS DEFINED IN FPMR 101-32.402-1 (AS IT IS IN OMB CIRCULAR NO. A-54 AND DOD DIRECTIVE NO. 4105.55) AS FOLLOWS:

"'AUTOMATIC DATA PROCESSING EQUIPMENT' (ADPE) MEANS GENERAL PURPOSE COMMERCIALLY AVAILABLE, MASS PRODUCED AUTOMATIC DATA PROCESSING COMPONENTS AND THE EQUIPMENT SYSTEMS CREATED FROM THE, REGARDLESS OF USE, SIZE, CAPACITY, OR PRICE, THAT ARE DESIGNED TO BE APPLIED TO THE SOLUTION OR PROCESSING OF A VARIETY OF PROBLEMS OR APPLICATIONS AND ARE NOT SPECIALLY DESIGNED (NOT CONFIGURED) FOR ANY SPECIFIC APPLICATION. ***"

UNDER THE ABOVE DEFINITION, IT MUST BE CONCLUDED THAT AN AIRCRAFT FLIGHT SIMULATOR IS SPECIALLY DESIGNED FOR A SPECIFIC APPLICATION AND, THEREFORE, IS NOT ADPE. SINCE THE SUBJECT PROCUREMENT IS NOT FOR ADPE, THE ABOVE- CITED REGULATIONS HAVE NO APPLICATION.

MOREOVER, WITH REGARD TO THE FEASIBILITY OF EXPRESSING THE COMPUTER REQUIREMENTS IN TERMS OF FUNCTIONAL WORKLOAD SPECIFICATIONS, THE AIR FORCE STATES:

"IT IS IMPOSSIBLE FOR THE AIR FORCE TO FUNCTIONALLY SPECIFY SIMULATOR COMPUTER PROCESSING REQUIREMENTS WITHOUT DESIGNING THE SYSTEM. THIS IS BECAUSE, IN A SIMULATOR, THE BREAK BETWEEN HARDWARE AND SOFTWARE IS A DESIGN DECISION. FOR EXAMPLE, SIMULATION OF THE CONTROL STICK FORCES FELT BY THE PILOT CAN BE ACCOMPLISHED WITH VARIOUS MIXTURES OF ANALOG HARDWARE AND COMPUTER SOFTWARE. THE AIR FORCE SPECIFIES WHAT IS TO BE SIMULATED, SUCH AS A T-38 AIRCRAFT, AND FURTHER SPECIFIES INSTRUCTIONAL FEATURES AND OTHER PERFORMANCE REQUIREMENTS."

THE AIR FORCE BELIEVES THAT THE METHOD CHOSEN IN THE RFP FOR EXPRESSING THE COMPUTER NEEDS ALLOWED OFFERORS GREATER FLEXIBILITY IN SIMULATOR DESIGN THAN EXPRESSING THOSE NEEDS IN TERMS OF FUNCTIONAL COMPUTER PROCESSING REQUIREMENTS. WE HAVE NO BASIS TO DISAGREE WITH THE AIR FORCE IN THIS RESPECT.

ACCORDINGLY, DIGITAL'S PROTEST IS DENIED.