Priority 1 Air Rescue Operations (Arizona), LP

Decision

DOCUMENT FOR PUBLIC RELEASE

The decision issued on the date below was subject to a GAO Protective Order. This version has been approved for public release.

Matter of: Priority 1 Air Rescue Operations (Arizona), LP

File: B-424708

Date: October 29, 2026

Katherine B. Burrows, Esq., Jacqueline K. Unger, Esq., Abigail H. Finan, Esq., and Kristine E. Crallé, PilieroMazza PLLC, for the protester.
Gabriel D. Soll, Esq., Department of Homeland Security, for the agency.
Nathaniel S. Canfield, Esq., and Evan D. Wesser, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.

DIGEST

Protest challenging combination of requirements for flight simulator and hoist training devices into a single solicitation as unduly restrictive of competition is denied where the record shows that the combination of requirements is reasonably necessary to meet the agency's legitimate needs.

DECISION

Priority 1 Air Rescue Operations (Arizona), LP, a small business of Mesa, Arizona, protests the terms of request for proposals (RFP) No. 70Z02326R93150001, issued by the Department of Homeland Security, United States Coast Guard, for advanced training devices. The protester contends that the RFP unduly restricts competition by unnecessarily combining requirements.

We deny the protest.

BACKGROUND

The agency issued the RFP pursuant to Revolutionary Federal Acquisition Regulation Overhaul parts 12 and 15 on June 18, 2026, and has amended it seven times. Contracting Officer's Statement and Memorandum of Law (COS/MOL) at 5 & n.5, 6. The RFP, which is set aside for small business concerns, seeks proposals for the design, fabrication, delivery, installation, and support of three advanced training devices, described below. COS/MOL at 5; Agency Report (AR), Tab A.8, RFP Amendment No. 0007 at 1.

First, the RFP seeks an MH‑60T[1] level 7 flight training device, which is a high‑fidelity simulator replicating the MH‑60T cockpit, avionics, and mission systems for pilot and aircrew training. AR, Tab A.7.a, Statement of Work (SOW) Amendment No. 0006 at 1. Second, the RFP seeks a hoist training simulator, which is a full‑size, immersive, mixed‑reality hoist trainer for rear‑crew search and rescue and hoist operations training. Id. Finally, the RFP seeks a deployable hoist training simulator, which is a transportable, modular hoist trainer enabling mobile and distributed search and rescue and hoist training. Id. To support comprehensive crew training, all three devices are to be interoperable with each other and with existing or future agency training infrastructure, supporting open standards for networking, and are to be “capable of operating in a linked, real‑time, and fully synchronized mode via a low‑latency network utilizing a common protocol and shall not exceed a latency of 50 [milliseconds].” Id. at 24.

On August 3, prior to the time set for receipt of proposals, the protester filed this protest with our Office challenging the combination of these requirements under a single solicitation.

DISCUSSION

The protester alleges that the RFP unduly restricts competition because it unnecessarily combines the requirements for all three simulator types, which the protester argues limits competition to only offerors that can supply all of the unique simulators.[2] Protest at 16‑22; Comments at 2‑18. The protester contends that the combination of requirements in this manner violates the provisions of the Competition in Contracting Act of 1984 (CICA) regarding competition and restrictive solicitation provisions. Id. The agency responds that combining the simulator requirements under one solicitation is reasonable in light of the agency's redesign of its approach to flight crew training, and critical to the increased safety and effectiveness of operators. COS/MOL at 7‑11.

As pertinent here, CICA generally requires that solicitations permit full and open competition and contain restrictive provisions only to the extent necessary to satisfy the procuring agency's needs. 41 U.S.C. § 3306(a)(2). An allegation that an agency's combination of requirements violates this provision reflects a claim that a contract combines separate requirements beyond what is necessary to meet the agency's needs, thereby unreasonably limiting competition by excluding offerors that can perform only a portion of the requirement, a concept often referred to as “CICA bundling.”[3] See, e.g., Manus Med. LLC, B‑412331, Jan. 21, 2016, at 5; Major Contracting Servs., Inc., B‑406980, Oct. 10, 2012, at 3‑4.

Because procurements conducted on a bundled or total package basis can restrict competition, we will sustain a challenge to the use of such an approach where it is not necessary to satisfy the agency's needs. Kaiterra Fire Sys., LLC, B‑423952.2, B‑423952.4, Feb. 4, 2026, at 5. The determination of a contracting agency's needs and the best method for accommodating them are matters primarily within the agency's discretion, and we have sustained protests only where no reasonable basis is demonstrated. Id.; Nautical Eng'g, Inc., B‑309955, Nov. 7, 2007, at 13. Of particular relevance here, where a requirement relates to national defense or human safety, an agency has discretion to define the solicitation requirements to achieve not just reasonable results, but the highest possible reliability and effectiveness. Kaiterra, supra at 6.

As explained in the RFP, the agency historically “has relied on a combination of classroom instruction, part‑task trainers, and operational flight time” to train its aircrews. AR, Tab A.7.a, SOW Amendment No. 0006 at 1. The RFP explains that “these methods . . . are limited in their ability to safely and cost‑effectively replicate the full range of mission scenarios, emergency procedures, and complex [search and rescue] operations encountered in the field.” Id. Consequently, the agency is undertaking an effort “to establish an organic, ground‑based hoist simulation and rear‑crew training capability for . . . rotary‑wing flight mechanics and aircrews[,]” as detailed further below. Id. at 2.

The agency states that the instant procurement stems from an appropriation in support of the agency's rotary wing aircraft programs. COS/MOL at 2 (citing 14 U.S.C. § 1181(2)). Pursuant to that appropriation, the agency issued a request for information (RFI) regarding the acquisition of MH‑60T full flight simulators and operational training devices to meet growing pilot training demands. Id.; AR, Tab B.1, RFI. The RFI, which noted that the current training system at the agency's Aviation Training Center (ATC) in Mobile, Alabama, is insufficient, sought to identify capable sources and gather other data to support acquisition planning. AR, Tab B.1, RFI at 1. As set forth in the RFI, the simulators would be required to support missions including search and rescue and hoist operations. Id. In response to the RFI, the agency received one question from a potential source as to whether it would be “acceptable for rear crew member operations such as hoist and sling loads to be trained in a rear cabin simulator that is separate from the flight deck simulator[,]” with both simulators being able to “interoperate in the same exercise as one aircraft.” AR, Tab B.1.a, RFI Questions and Answers at 1. The agency responded that such a solution would be acceptable. Id.

As part of its planning process, the agency examined its training program for flight mechanics, who are the individuals on an aircraft's flight crew who are not pilots but perform other duties in support of mission assignments. COS/MOL at 3 & n.4. To that end, the ATC reviewed the agency's flight mechanic training, currently provided through a contract with the protester, and concluded that it would be beneficial for the agency to acquire its own hoist simulators and provide training through agency personnel at the ATC. AR, Tab C.1, ATC Issue Paper at 1‑2. The ATC cited a number of factors in support of that conclusion, including reduced instruction costs that would offset the simulator acquisition costs, a reduced need for instruction flights that would enable the agency to direct flight time to other missions, and better training outcomes resulting from standardization, technical mastery of the aircraft hoist system, and confidence in high‑risk emergency scenarios. Id. at 2.

Following the ATC's review of the agency's flight mechanic training, a separate agency working group completed a report on the agency's flight simulator acquisitions, including the acquisition of “at least three H‑60” simulators funded by the appropriation noted above. AR, Tab C.2, Simulator Working Group Report at 4. The working group recommended procurement of three such simulators and, consistent with the ATC's review discussed above, “a hoist trainer and hoist tower to support flight mechanic upgrades, proficiency, and training.” Id. at 15. Thereafter, based on its market research, the agency concluded that “the industry standard is for a [p]rime contractor to lead the production and integration of the primary flight training device, while subcontracting to partner vendors who specialize in niche components such as the hoist trainer.” AR, Tab B.4, Market Research Report at 5. The agency noted that “[t]his approach enables the [p]rime contractor to ensure system‑level interoperability and concurrency, while allowing specialized vendors to deliver proven, fielded hoist training solutions.” Id.

Before publishing the RFP, the Commandant of the Coast Guard submitted a memorandum to the Secretary of Homeland Security, seeking approval to award a contract for the acquisition of an MH‑60T simulator and interoperable hoist mission training systems, to be located at the ATC. AR, Tab C.3, Contract Approval Memorandum at 1. The memorandum stated that “[e]stablishing an organic flight mechanic training course, enabled by the procurement of two interoperable hoist mission training systems integrated with simulators, will reduce training flights per mechanic from 11 to 6, which equates to an approximate 45 percent decrease in required training time to qualify.” Id. at 1‑2. It further stated that the procurement would enable the agency “to provide enhanced realistic training for pilots and flight mechanics, improve readiness of the rotary wing workforce, and result in over $15 million in annual flight hour savings, which can be redirected to higher‑priority missions including securing the U.S. border, facilitating commerce, and responding to contingency or crisis.” Id. at 2. The Secretary approved the memorandum on March 12, 2026. Id. at 3.

The RFP itself also states the reasons the agency seeks to acquire a flight simulator, hoist training simulator, and deployable hoist training simulator as an interoperable solution. The RFP discusses “mishaps within the H‑60 fleet--resulting in two destroyed aircraft and one fatality” that “underscore[] the inherent hazards of hoist operations and amplif[y] the urgency to mitigate risk through enhanced training.” AR, Tab A.7.a, SOW Amendment No. 0006 at 2. The RFP explains that “an interoperable, synthetic environment where pilots and flight mechanics can train simultaneously will enable crews to safely rehearse complex hoisting operations, review recent real‑world cases, and build a more robust safety culture for missions executed in the most dangerous and remote environments.” Id. Among the aims stated in the RFP is to “produc[e] the safest, most capable aviation workforce possible.” Id. In support of that aim, as discussed above, the RFP requires that the simulators be “capable of operating in a linked, real‑time, and fully synchronized mode” in order “[t]o enable comprehensive [c]rew [r]esource [m]anagement . . . training[.]” Id. at 24.

Finally, the agency has submitted a sworn declaration from the commanding officer for the ATC that provides further context for the agency's requirement. See Supp. MOL, attach., Decl. of ATC Commanding Officer. As the commanding officer explains, the agency's requirement that the flight simulator and hoist training devices be interoperable stems from the need to train pilots and flight mechanics in simultaneous scenarios. In that regard, he states that a rescue hoist operation “is a single, highly synchronized, and potentially hazardous team maneuver” that requires “intricate crew coordination” and “split‑second, shared decision‑making” as the flight mechanic navigates and directs the pilot into “a safe, stable, and maneuverable position to execute the hoist.” Id. at 1. As examples of the challenges that arise, he points to communications between flight mechanics and pilots regarding positioning, which require real‑time translations due to the differing orientations of the flight mechanic and pilot; emergency decisions in the event of catastrophes such as cable shear, engine failure, or vessel collision; and the need for pilots to adjust to the pendulum swing and weight shifts of the hoist basket while flight mechanics observe aircraft reactions to their commands. Id. at 1‑2.

The ATC commanding officer states that, under the agency's current training model, the first time pilots and flight mechanics experience the environment described above is “in a high‑noise, high‑vibration helicopter.” Id. at 1. By moving that training to “an interoperable, linked simulator system that leverages modern [m]ixed [r]eality technology,” he explains, “flight mechanics under instruction . . . and pilots [will be able] to develop [the skills discussed above] over time in a reduced risk environment that mimics/simulates the same environment that they will be executing in.”[4] Id. The ATC commanding officer avers that “[s]tandalone simulators cannot teach crew coordination communication, and they cannot simulate the physical and verbal dynamics of joint decision‑making” that are required in a rescue hoist operation. Id. at 2. Thus, he states, interoperable flight simulators and hoist training devices “are the only means of creating a training environment where a full crew can experience these emergencies, make mistakes, and practice coordinated survival procedures safely.” Id.

The ATC commanding officer further details the potential negative consequences if these simulator requirements were not combined under a single solicitation, stating that “several severe technical and training failures would foreseeably occur” if “the simulators are procured separately, without considering their interoperability from the design[.]” Supp. MOL, attach., Decl. of ATC Commanding Officer at 2. As an example, he states that “[t]he software engines governing flight aerodynamics and hoist cable physics could use different, incompatible mathematical models[,]” resulting in “split visual and sensory realities between the cockpit and cabin, undermining the common scenario/stress aspect of the simulation[.]” Id. Additionally, “[a] communication delay, or latency lag, greater than 50 milliseconds . . . could be inherent in separately procured simulators[,]” and a greater latency would “fracture[] the shared mental model of the aircraft's physical state[,]” with the resulting “physical desynchronization destroy[ing] the shared situational awareness required to learn and practice safe hover operations.” Id. at 2‑3. This would “teach[] dangerous negative habits--ingraining incorrect, unsafe muscle memory that directly compromises flight safety, increases spatial disorientation, and can lead to catastrophic rotor‑strike or cable‑parting incidents in a live aircraft.” Id. at 3. The ATC commanding officer points to two instances where the agency has split training simulator requirements into separate procurements and the agency has been required to expend resources to resolve interoperability failures--in one case, still unsuccessfully--as informing the agency's procurement strategy here. Id. at 3.

Thus, as the agency sums up, “[t]he need for the simulators to be interoperable is the reason they are being procured under one solicitation.” COS/MOL at 9.

Based on these considerations, we conclude that the agency has provided a reasonable basis for its determination to purchase the flight simulator and hoist training devices from a single source. As noted above, where a requirement relates to national defense or human safety, an agency has discretion to define the solicitation requirements to achieve not just reasonable results, but the highest possible reliability and effectiveness. Kaiterra, supra at 6. Here, the agency reasonably determined that procuring these items together is needed to achieve the highest possible reliability and effectiveness in training flight crews for high‑danger missions such as search‑and‑rescue operations. As detailed above, the purpose of the procurement is to permit the simultaneous training of pilots and flight mechanics in a synchronized environment. To accomplish that, the agency has shown a reasonable need for an interoperable solution that integrates both the flight simulator and the hoist training devices. To achieve the highest possible reliability and effectiveness, the agency also has demonstrated a need for a single contractor to manage the integration of those disparate components, as acquiring these items separately poses risks that the agency will not obtain a solution that meets its training needs.

In similar circumstances, we have concluded that it was reasonable for agencies to acquire multiple types of simulator systems under a single solicitation where the agencies demonstrated a reasonable need for integration of those systems by a single contractor. See, e.g., Resource Consultants, Inc., B‑255053, Feb. 1, 1994, at 3‑5 (finding the agency reasonably combined requirements for a flight simulator and a tactics simulator where devices communicated and transmitted data through a custom interface, and the agency demonstrated that acquiring the devices separately posed an unacceptable technical risk); Titan Dynamics Simulations, Inc., B‑257559, Oct. 13, 1994, at 2‑7 (finding the agency reasonably included pyrotechnics simulators within requirement for a training system where the system required integration of multiple elements and prior agency experience showed hazards associated with procuring pyrotechnics simulators separately from an integrated system).[5] Accordingly, we conclude that the agency has demonstrated a reasonable basis for combining the flight simulator and hoist training device requirements under a single solicitation.

The protester raises several objections to the agency's justification for combining these requirements. Comments at 2‑18; Supp. Comments at 2‑14. We have examined them all and conclude that none provides a basis to sustain the protest. We address two examples here.

The protester contends that the agency's proffered need for interoperability between the flight simulator and hoist training devices does not reasonably support combining those requirements under a single solicitation, arguing that the agency nevertheless can achieve interoperability through separate procurements. Comments at 12‑15; Supp. Comments at 8‑9. The protester points in particular to the RFP's requirement that the flight simulator and hoist training devices use a common technical standard, and further argues that the agency could amend the RFP's interoperability compliance testing terms to allow for separate procurements. Comments at 13‑14; Supp. Comments at 8. These arguments, however, express only the protester's disagreement with the agency's judgment, and do not demonstrate that the agency has no reasonable basis for combining these requirements, particularly where, as here, the agency has discretion to define its requirements to achieve not just reasonable results, but the highest possible reliability and effectiveness.

The protester also argues that the ATC commanding officer's declaration, which was submitted during the pendency of this protest, is a post hoc justification for combining requirements that should be afforded no weight. Supp. Comments at 4‑6. As we have stated, however, our Office generally will consider post‑protest explanations that provide a detailed rationale for contemporaneous conclusions, and simply fill in previously unrecorded details, as long as those explanations are credible and consistent with the contemporaneous record. Booz Allen Hamilton, Inc., B‑420116.6, B‑420116.7, Aug. 22, 2022, at 9. The declaration here provides additional details that are consistent with the contemporaneous record of the agency's procurement planning. The ATC commanding officer's statements regarding the need for interoperability align with the conclusions of the agency's working groups, the expression of need provided to the Secretary of Homeland Security, and the description of the reasons for interoperability provided in the RFP. Furthermore, his statements regarding the reasons for combining the requirements for a flight simulator and hoist training devices are similarly consistent with the contemporaneous record regarding the central importance of ensuring that the agency obtains an integrated solution permitting simultaneous training of pilots and flight mechanics in unified scenarios. Thus, we find no basis to discount the commanding officer's declaration that merely provides additional, credible context for the agency's documented contemporaneous decision making.

In sum, while the protester disagrees with the agency's approach, we conclude that the agency has met its burden of showing a reasonable need to procure the flight simulator and hoist training devices in one procurement. Accordingly, we reject the protester's argument that the agency impermissibly bundled these requirements in violation of CICA.

The protest is denied.

Edda Emmanuelli Perez
General Counsel