Centerra-Parsons Pacific, LLC

Decision

Matter of:  Centerra-Parsons Pacific, LLC

File:  B-414686; B-414686.2

Date:  August 16, 2017

DIGEST

1.  Protest that the agency's assignment of adjectival ratings was unreasonable is denied where the record shows that the agency's evaluation complied with the solicitation's evaluation criteria.

2.  Protest that the agency engaged in unequal treatment by assigning the two offerors the same adjectival ratings is denied, where the source selection official reasonably looked behind the adjectival ratings to consider the relative merits of the proposals.

3.  Protest that the agency failed to consider the performance risk associated with the awardee's lower labor rates is denied, where the agency reasonably evaluated the awardee's proposal under the non-price evaluation factors and the solicitation did not provide for a price realism analysis.

4.  Protest that the source selection decision was unreasonable is denied, where the record shows that the source selection official considered the strengths and weaknesses of the offerors' proposals and determined that the protester's proposal did not merit paying a price premium. 

Centerra-Parsons Pacific, LLC (CPP), of Palm Beach Gardens, Florida, protests the award of a contract to KBR Diego Garcia, LLC (KBR), of Houston, Texas, under request for proposals (RFP) No. N62742-16-R-3600, issued by the Department of the Navy, Naval Facilities Engineering Command, for base operations support services.  CPP challenges the evaluation of its and KBR's proposals as well as the agency's tradeoff decision.

We deny the protest.

BACKGROUND

The RFP, issued on May 6, 2016, provided for the award of an indefinite-delivery, indefinite-quantity contract (IDIQ) for base operations support services for the Navy Support Facility in Diego Garcia, British Indian Ocean Territory.  Agency Report (AR), Tab 1, RFP, at 1, 2, 16; Combined Contracting Officer's Statement/Memorandum of Law (COS/MOL) at 2.  The support services included port operations, passenger terminal and cargo handling, information technology services, telecommunications services, fire and emergency services, health care support services, housing, custodial services, and utilities, which were addressed in 32 annexes and sub-annexes in the performance work statement (PWS).  AR, Tab 4, RFP amend. 3, PWS, at 1.  The RFP contemplated a 1-year mobilization and base period, seven option years, and a 6-month extension of services option.  See AR, Tab 5, RFP amend. 4 at 3-6; COS/MOL at 3.  The RFP provided for recurring and non-recurring work.  RFP at 2.  The recurring work pertained to the work performed pursuant to the PWS annexes and sub-annexes and was to be performed for a fixed price.  See, e.g., id. at 2; Exh. B, Base Period Exhibit Line Item Numbers.  The non-recurring work was to be priced on labor-hour basis, with materials and equipment to be reimbursed up to a specified dollar amount.  Id.

The RFP stated that award would be made on a best-value basis, considering price and the following non-price evaluation factors:  past performance, corporate experience, safety, management, and technical approach/methods.  RFP at 94-97.  The RFP further stated that the corporate experience, safety, management, and technical approach/methods factors were equally weighted, and when combined, were equal to the past performance factor.  Id. at 94.  The non-price factors, when combined, were considered approximately equal to price.  Id.

With respect to the corporate experience factor, the RFP stated that offerors would be evaluated on relevant experience, performed within the past 5 years, to determine indicators of expected performance, taking into consideration the complexity and quantity of experiences.  Id. at 95.  Offerors were required to identify a minimum of three relevant projects with a minimum value of $50 million.  AR, Tab 6, RFP Amend. 5, at 13.  In addition, the RFP stated that the evaluation of corporate experience would consider the depth (extent of experience in each annex and sub-annex), breadth (expertise across all annexes and sub-annexes), and multi-function management (experience managing/coordinating work across multiple functional annexes and sub-annexes).  RFP at 95.  The RFP also stated that lack of experience in one or more annexes or sub-annexes may result in a lower rating.  Id.

With respect to the management factor, the RFP stated that each offeror's management approach would be evaluated for the ability to provide effective and efficient management, control, communication, and interfaces with workforce, subcontractors, and government personnel.  Id. at 97.  The RFP also stated that each offeror's planned approach would be evaluated on its demonstrated ability to effectively recruit and retain qualified key personnel.  Id.

With respect to the technical approach/methods factor, the RFP stated that each offeror would be evaluated on its understanding of, and approach to, accomplishing the complexity and magnitude of the requirements set forth in the PWS.  Id.  The RFP also stated, in relevant part, that the proposal would be evaluated on the clarity and reasonableness of the staffing approach to accomplish the work and mitigate risks.  Id.  In addition, the RFP stated that proposals would be evaluated on the offeror's demonstrated understanding of the entire scope of work through a comprehensive and realistic allocation of resources by annex and sub-annex that achieves efficient and effective performance.  Id.

The RFP stated that price would be evaluated for completeness and reasonableness.  RFP at 94.  The RFP further stated that, with respect to completeness, proposed prices would be evaluated to ensure that all information required by the RFP was submitted, tracked to the PWS, and supported the offer.  Id.  With respect to price reasonableness, the RFP stated that proposed prices/costs and IDIQ labor rates would be evaluated to ensure that they were fully justified, supported, and considered fair and reasonable to the government.  Id.

CPP and KBR submitted the only proposals.  COS/MOL at 15.  A technical evaluation team (TET) evaluated proposals; identified strengths, weaknesses, significant weaknesses, and deficiencies;[1] and assigned adjectival ratings under each non-price evaluation factor.  See, e.g., AR, Tab 11, TET Report, Sept. 15, 2016.  The Navy engaged in discussions with offerors, and after evaluation of final proposal revisions, the offerors received the following ratings:[2]

	CPP	KBR
Past Performance	Substantial Confidence	Substantial Confidence
Corporate Experience	Good	Good
Safety	Outstanding	Outstanding
Management	Good	Good
Technical Approach/Methods	Good	Good
Price	$552,152,051	$514,947,109

AR, Tab 31, Source Selection Authority (SSA) Report, at 3.

The TET assigned strengths, weaknesses, and significant weaknesses, as follows:

	CPP	KBR
Past Performance	5 strengths	7 strengths
Corporate Experience	5 strengths	5 strengths 1 significant weakness
Safety	3 strengths	3 strengths
Management	4 strengths	6 strengths
Technical Approach/Methods	12 strengths	3 strengths
Total	29 strengths	24 strengths 1 significant weakness

AR, Tab 28, Final TET Report, at 10, 16, 19, 21, 23, 26, 33, 37, 39, 41.

As relevant here, under the corporate experience factor, the TET assigned KBR a significant weakness because the relevant contracts KBR identified did not demonstrate experience in [DELETED], one of the 32 annexes and sub-annexes provided in the RFP.  Id. at 35.  The TET noted that one of the contracts KBR identified contained some experience in [DELETED] but that the contract was not relevant and could not be considered because the contract value was below the $50 million threshold.  Id.  The TET concluded that the lack of experience in [DELETED] was a flaw that appreciably increased the risk of unsuccessful contract performance, but that the proposal's 5 strengths outweighed the significant weakness and assigned KBR a good rating under this factor.  Id. at 33, 35.

Also relevant here, under the technical approach/methods factor, the TET assigned 12 strengths to CPP's proposal, noting that 5 of the strengths impacted multiple annexes, while the other 7 strengths impacted specific annexes and sub-annexes, such as fire and emergency services, facility management, and facility investment.  Id. at 23-25.  The TET concluded that, overall, CPP's proposal met all of the solicitation requirements, indicated a thorough approach and understanding of the requirements, and presented a low risk of unsuccessful performance.  Id. at 23.  On this basis, the TET assigned a good rating under this factor.  Id.

The source selection evaluation board (SSEB) considered the proposals and the evaluation reports, and although recognizing the significant weakness assigned to KBR, concluded that the risk of unsuccessful performance was low with respect to both CPP's and KBR's proposals.  AR, Tab 29, Final SSEB Report, at 64. 

The source selection advisory council (SSAC) also reviewed the revised proposals, the evaluation reports, and the SSEB's report.  AR, Tab 30, Final SSAC Report, at 3.  The SSAC conducted a comparative analysis of CPP's and KBR's proposals and recommended that the contract be awarded to KBR as providing the best value to the government.  Id. at 10.  As relevant here, in conducting the comparative analysis, the SSAC recognized that KBR was assigned a significant weakness under the corporate experience factor for its lack of experience in [DELETED], but also noted the breadth and depth of KBR's experience with respect to other annexes.  Id. at 6.  As a result, in comparing CPP's and KBR's proposals under the corporate experience factor, the SSAC concluded that CPP had a slight advantage over KBR in this factor.  Id. at 7.  The SSAC recognized that, although KBR offered stronger past performance than CPP, KBR's proposal was not as strong as CPP's in the other non-price factors, and considered the two proposals to be equal under the non-price factors.  Id. at 9.  After considering price, the SSAC recommended award to KBR.  Id. at 10.

The SSA reviewed the SSAC and SSEB reports in making the final decision.  AR, Tab 31, Final SSA Report, at 3.  The SSA considered all of the strengths assigned to CPP's and KBR's proposals, as well as the significant weakness assigned to KBR's proposal under the corporate experience factor.  Id. at 10-11.  In this regard, the SSA concluded that the strengths in KBR's proposal for corporate experience outweighed the significant weakness, and that the risk of unsuccessful performance was low.  Id. at 5.  With respect to the technical approach/methods factor, the SSA acknowledged the 12 strengths assigned to CPP's proposal and concluded that the risk of unsuccessful performance was low.  Id. at 9.  The SSA found that KBR's proposal was stronger under the past performance factor, but that CPP's proposal was stronger under the other four non-price factors, and in view of the relative weighting of the factors provided in the RFP, the SSA concluded that the two proposals were equally advantageous with respect to the non-price factors.  Id. at 11.  The SSA noted that KBR's proposal was $37.2 million less than CPP's proposal, and concluded that CPP's proposal did not include additional benefits that would justify paying such a price premium.  Id.  Accordingly, the SSA selected KBR for contract award.  Id.

After a debriefing, CPP protested to our Office.

DISCUSSION

CPP raises various challenges to the assessment of adjectival ratings to its and KBR's proposals under the technical approach/methods and corporate experience evaluation factors.  CPP argues that had the agency properly evaluated proposals and considered CPP's assigned strengths, CPP would have been rated higher than KBR.  CPP also argues that the Navy failed to properly consider the performance risk inherent in KBR's proposal and that the agency's tradeoff decision was unreasonable.  Although our decision does not specifically discuss each and every argument, we have considered all of the protester's arguments, and find no basis to sustain the protest.

Technical Approach/Methods

CPP argues that it should have received an outstanding rating under the technical approach/methods factor because of the 12 strengths that were assigned to its proposal and the lack of weaknesses, significant weaknesses, or deficiencies.  Protest at 12; CPP Comments/Supp. Protest at 23.  CPP contends that of the 12 strengths assigned, several of them exceeded the requirements in a manner that best supports a rating of outstanding rather than good.  CPP Comments/Supp. Protest at 23.

The Navy states that the assignment of a good rating was consistent with the evaluation criteria in the RFP.  COS/MOL at 19.  The agency explains that many of the individual strengths it assigned CPP under the technical approach/methods factor specifically state that CPP's proposal demonstrated an adequate understanding of the requirement and a thorough approach to meeting the requirements.  Id. at 21.  The Navy states that the SSAC concurred with the strengths assigned to CPP's proposal and concluded that CPP's proposal did not provide benefits that were characterized as an exceptional approach, which would warrant an outstanding rating.  Id. at 18.  Similarly, the SSA concurred with the assessment that CPP's proposal merited a good rating based on its thorough approach and understanding of the requirements.  Supp. COS/MOL at 11-12.

It is well-established that the evaluation of proposals is a matter within the discretion of the contracting agency.  ICF Inc., LLC, B-414247 et al., Apr. 7, 2017, 2017 CPD ¶ 118 at 7.  In reviewing protests challenging the evaluation of proposals, we do not conduct a new evaluation or substitute our judgment for that of the agency but will examine the record to determine whether the agency's judgment was reasonable and in accord with the RFP evaluation criteria.  Watts-Obayashi, Joint Venture; Black Constr. Corp., B-409391 et al., Apr. 4, 2014, 2014 CPD ¶ 122 at 9.  In this regard, an offeror's disagreement with the agency's judgment, without more, is insufficient to establish that the agency acted unreasonably.  MicroTechnologies, LLC, B-413091, B-413091.2, Aug. 11, 2016, 2016 CPD ¶ 219 at 7. 

We have reviewed the evaluation record and find no basis to conclude that the agency's evaluation was unreasonable.  As discussed above, the RFP provided that a good rating would be assigned where an offeror's proposal met the solicitation requirements, indicated a thorough approach and understanding of the requirements, contained strengths that outweighed any weaknesses, and presented a low risk of unsuccessful performance.  RFP at 98.  In contrast, an outstanding rating would be assigned only where an offeror's proposal demonstrated an exceptional approach and understanding of the requirements, contained strengths that far outweighed any weaknesses, and presented a very low risk unsuccessful performance.  Id.

The record shows that the Navy undertook an extensive review of CPP's proposal, as evidenced by the numerous strengths assigned under the technical approach/methods factor, and considered the quality of the strengths assigned under the factor.  The Navy determined that although CPP's proposal presented a number of strengths, these strengths did not provide benefits that were considered exceptional.  In this regard, there is no legal requirement that an agency must award the highest possible rating, or the maximum point score, under an evaluation factor simply because the proposal contains strengths and/or is not evaluated as having any weaknesses.  Watts-Obayashi, Joint Venture; Black Constr. Corp., supra, at 12.  Accordingly, CPP's assertion that the agency was required to assign its proposal the highest possible rating simply because it contained 12 strengths and no weaknesses provides no basis to sustain the protest.

Corporate Experience

CPP argues that the Navy unreasonably assigned KBR a good rating rather than an acceptable rating under the corporate experience factor.  CPP Comments/Supp. Protest at 7-8.  CPP contends that the significant weakness the TET assigned KBR's proposal for the firm's lack of experience in [DELETED]--which the TET concluded appreciably increased the risk of unsuccessful contract performance--required the Navy to assign KBR an acceptable rather than a good rating.  Id. at 9.  CPP states that the importance of [DELETED] to the overall success of the requirement, as evidenced by the [DELETED] annex being the second-highest-priced annex, requires the Navy to lower KBR's rating.  Id. at 26-27.

The Navy states that the RFP did not place emphasis on the [DELETED] annex, but instead, treated all 32 annexes and sub-annexes equally.  COS/MOL at 27; Supp. MOL at 10.  The agency further states that the [DELETED] annex of the offerors' proposals were evaluated by individuals with extensive knowledge of the Navy's requirements for [DELETED] at Diego Garcia--the [DELETED] officer, the [DELETED] subject matter expert, and the [DELETED] leading chief petty officer--who identified the significant weakness in KBR's proposal and recognized the risks associated with the awardee's lack of experience with [DELETED].  COS/MOL at 26.  The TET considered the complexity and quantity of KBR's experiences across all annexes, including the depth, breadth, and multi-function management experience with respect to each annex and sub-annex in giving KBR a good rating for the corporate experience factor.  Id.  The Navy also states that the SSA considered the significant weakness assigned to KBR for its lack of experience in the [DELETED] annex, but also considered that KBR's corporate experience in numerous other annexes was substantial.  Id. at 26-27. 

The essence of an agency's evaluation is reflected in the evaluation record itself, not in the adjectival ratings or adjectival characterizations of proposal features as strengths or weaknesses.  Systems Eng'g Partners, LLC, B-412329; B-412329.2, Jan. 20, 2016, 2016 CPD ¶ 31 at 7.  Moreover, it is well-established that ratings, be they numerical, adjectival, or color, are merely guides for intelligent decision making in the procurement process.  One Largo Metro LLC et al., B-404896 et al., June 20, 2011, 2011 CPD ¶ 128 at 14. 

Here, the record shows that the TET recognized that KBR's lack of experience in the [DELETED] annex increased the risk of unsuccessful performance, but ultimately concluded that, given the depth and breadth of KBR's overall experience, the strengths contained in KBR's proposal outweighed the significant weakness in [DELETED].  See AR, Tab 28, Final TET Report, at 33.  The SSA also recognized KBR's lack of experience with [DELETED] as a significant weakness, but concurred with the TET's conclusion that KBR's strengths outweighed any weaknesses.  AR, Tab 31, Final SSA Report, at 5.  In conducting the tradeoff, the SSA noted that both offerors demonstrated experience managing work across multiple functional areas, working in remote locations, and providing and maintaining humane living standard and satisfactory working conditions, and that both also demonstrated a depth and breadth of experience in the PWS annexes.  Id. at 10.  The SSA concluded that CPP submitted a slightly stronger proposal under the corporate experience factor because KBR lacked [DELETED] experience.  Id.  Although CPP maintains that the Navy failed to accord KBR's significant weakness sufficient weight, based on this record, we disagree and find no basis to sustain the protest.

Unequal Treatment

CPP alleges that the Navy treated offerors unequally in assigning the same rating to both offerors where the number of strengths differed.  Protest at 18-19.  In this regard, the protester alleges that if the agency properly assigned a good rating to KBR under the corporate experience factor where KBR received 5 strengths and 1 significant weakness, then the agency should have assigned an outstanding rating to CPP, given CPP's 5 strengths and no weaknesses or significant weaknesses.  CPP Comments/
Supp. Protest at 29. 

As we noted above, adjectival ratings are merely guides for intelligent decisionmaking.  One Largo Metro LLC et al., supra.  Moreover, the evaluation of proposals and assignment of adjectival ratings should not be based upon a simple count of strengths and weaknesses, but on a qualitative assessment of the proposals consistent with the evaluation scheme.  Epsilon Sys. Solutions, Inc., B-409720, B-409720.2, July 21, 2014, 2014 CPD ¶ 230 at 8.  Where the evaluation record and source selection decision reasonably consider the underlying basis for the ratings, a protester's disagreement over the actual numerical, adjectival, or color ratings is essentially inconsequential in that it does not affect the reasonableness of the agency's judgments.  A&T Systems, Inc., B-410767, Feb. 10, 2015, 2015 CPD ¶ 95 at 4.  The relevant inquiry, therefore, is whether the agency's evaluation of the relative merits of each proposal was reasonable.  Id.  We conclude that it was.

Here, the SSA looked behind the adjectival ratings to recognize the strengths and any weaknesses of each proposal for each factor.  In this regard, the SSA recognized that CPP's proposal was slightly stronger with respect to the corporate experience, safety, management, and technical approach/methods factors, but that KBR's proposal was stronger under the past performance factor.  AR, Tab 31, Final SSA Report, at 10-11.  Since the past performance factor was essentially equal to the corporate experience, safety, management, and technical approach/methods factors combined, the SSA concluded that the proposals were essentially equal.  Id. at 11.  Based on the record before us, we find no basis to conclude that the agency acted unreasonably. 

Performance Risk

CPP argues that the Navy failed to properly evaluate the performance risk associated with KBR's proposal under the management and technical approach/methods factors in accordance with the terms of the solicitation.  CPP Comments/Supp. Protest at 16, 20-21.  CPP contends that language in KBR's proposal suggests that the awardee plans to retain only a portion of the incumbent third country national (TCN) staff and replace the rest with less-experienced, lower-paid personnel.  Id. at 16.  CPP argues that this performance risk should have negatively affected KBR's ratings under the management and technical approach/methods factors. 

The Navy states that the assumption that KBR plans to replace a significant portion of the incumbent TCN staff is unsubstantiated by KBR's technical proposal.  Supp. MOL at 20.  The Navy further states that numerous statements concerning the awardee's intention to retain incumbent staff appeared throughout KBR's proposal and that nothing in KBR's non-price proposal triggered any concern with respect to performance risk due to staffing concerns.  Id. at 21.  The Navy also states that the price evaluation team evaluated KBR's wage rates and fringe benefit costs for TCN staff and determined that they were based on historical and market rates for each position.  Id. at 20. 

Based on the record before us, we find no basis to conclude that the agency's evaluation of KBR's proposal under the management and technical approach/methods factors was unreasonable.  As noted by the Navy, KBR's proposal indicated that it planned to retain incumbent personnel.  For example, in its roadmap to the technical approach, KBR's proposal stated that it plans to retain incumbent personnel where their experience meets the contract requirements.  AR, Tab 9, KBR Initial Non-Price Proposal, at 115.  Elsewhere in its proposal, KBR stated that it planned to "retain the high performing incumbent personnel based on their [Diego Garcia] experience, level of customer satisfaction, and their history of successful operations . . . ."  See, e.g., id. at 171, 190.  The protester's interpretation of the meaning behind the awardee's proposal does not render the agency's understanding of the proposal unreasonable.

Moreover, we disagree with CPP that the solicitation requires the Navy to consider KBR's proposed labor rates under the management and technical approach/methods factors.  With respect to the management factor, CPP relies on the following language in the instructions to offerors:  "Offerors shall demonstrate its proposed methodology for controlling, planning and executing the work while minimizing performance risk in meeting performance objectives and standards."  CPP Comments/Supp. Protest at 21 citing RFP amend. 5 at 14.  With respect to the technical approach/methods factor, CPP relies on the following:  "proposal will be evaluated on the clarity and reasonableness of the staffing approach to accomplishing the complexity and magnitude of service requirements, including lines of management authority, supervision, span of control, and accountability. . . .  The proposal will also be evaluated on the demonstration of an efficient and effective technical approach to accomplishing the work and mitigating risks."  Id. citing RFP at 97.  In short, we see nothing in the language identified by the protester--nor elsewhere in the RFP--that requires the Navy to consider KBR's proposed labor rates under the non-price factors.

In this regard, to the extent CPP is arguing that KBR's proposal presents high performance risk because KBR's labor rates are too low to retain incumbent staff, the protester is in essence arguing that the agency was required to conduct a price realism analysis.  See SITEC Consulting, LLC et al., B-413526.4 et al., Apr. 3, 2017, 2017 CPD ¶ 164 at 13 (protest that agency was required to assess performance risk resulting from awardee's low prices describes a price realism analysis); GlobalOpal, LLC, B-408414.7; B-408414.8, Mar. 19, 2014, 2014 CPD ¶ 140 at 4 (complaint that the agency failed to account for the risk involved in labor rates that are allegedly too low is a challenge to the agency's failure to conduct a price realism analysis); Emergint Techs., Inc., B-407006, Oct. 18, 2012, 2012 CPD ¶ 295 at 5. 

Where, as here, a solicitation anticipates award of a fixed-price contract with fixed labor rates, there is no requirement that an agency conduct a price realism analysis in the absence of a solicitation provision requiring such an analysis.  See Lynxnet, LLC, B-409791, B-409791.2, Aug. 4, 2014, 2014 CPD ¶ 233 at 4.  An agency may, however, at its discretion, provide for the use of a price realism analysis in a solicitation for the award of a fixed-price contract, or a fixed-price portion of a contract, to assess the risk inherent in an offeror's proposal.  Puglia Eng'g of Cal.,Inc., B-297413 et al., Jan. 20, 2006, 2006 CPD ¶ 33 at 6.  Absent a solicitation provision providing for a price realism evaluation, agencies are neither required nor permitted to conduct one in awarding a fixed-price contract.  STG, Inc., B-411415; B-411415.2, July 22, 2015, 2015 CPD ¶ 240 at 14.  Here, the solicitation did not provide for a price realism analysis, and accordingly the protester's arguments are unavailing in this regard.

Tradeoff Decision

Finally, CPP argues that the SSA's tradeoff analysis is based largely on the erroneous ratings for the corporate experience and technical approach/methods factors.  CPP Comments/Supp. Protest at 14.  CPP contends that the SSA should have conducted additional analysis in making the award determination, rather than relying on the SSEB's conclusions.  Id. at 15.

In making a source selection decision, the SSA need not review the proposals or complete evaluation documentation, but instead can rely upon a briefing that presents the results of the evaluation.  ManTech TSG-1, Joint Venture, B-411253.7, B-411253.8, Mar. 1, 2017, 2017 CPD ¶ 81 at 10.  Furthermore, a source selection decision need not address and discuss every evaluated strength and weakness of the competing proposals; rather, the decision must sufficiently document the rationale for business judgments and tradeoffs made by the SSA, and any benefits associated with additional costs.  See General Dynamics, American Overseas Marine, B-401874.14, B-401874.15, Nov. 1, 2011, 2012 CPD ¶ 85 at 16; see also FAR § 15.308.

CPP's assertion is predicated on its contention that the agency erred in its evaluation of offerors' proposals under the corporate experience and technical approach/methods factors.  As discussed above, we find no merit in this contention.  Moreover, the record shows that the SSA acknowledged the various strengths in the offerors' proposals, as well as the significant weakness assigned to KBR's proposal, but considered that the protester's proposal did not provide additional benefits that would merit the $32.7 million price premium.  See AR, Tab 31, Final SSA Report, at 11.  Therefore, based on the record before us, we find no basis to question the agency's tradeoff analysis and selection decision.[3]

The protest is denied.

Susan A. Poling
General Counsel

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