BNUMBER:  B-262181.3
DATE:  June 4, 1996
TITLE:  Northrop Worldwide Aircraft Services, Inc.--Reconsideration

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Matter of:Northrop Worldwide Aircraft Services, Inc.--Reconsideration

File:     B-262181.3

Date:June 4, 1996

J. William Eshelman, Esq., and Michael C. Poliner, Esq., Feith and 
Zell, for the protester.
Devon E. Hewitt, Esq., and R. Timothy Hanlon, Esq., Shaw, Pittman, 
Potts & Trowbridge, for Loral Training and Technical Services, Inc., 
an interested party.
Tania L. Calhoun, Esq., and Christine S. Melody, Esq., Office of the 
General Counsel, GAO, participated in the preparation of the decision.

DIGEST

Request for reconsideration of decision denying protest on ground that 
protester was not prejudiced by agency's failure to hold meaningful 
discussions is denied where the record showed that there was no 
reasonable possibility that protester was prejudiced; protester's 
attempt in request for reconsideration to demonstrate prejudice 
provides no basis for reconsidering decision given that protester had 
available to it during the course of the initial protest information 
that would have allowed it to present specific and credible support 
for its position, but failed to do so.

DECISION

Northrop Worldwide Aircraft Services, Inc. requests reconsideration of 
our decision in Northrop Worldwide Aircraft Servs., Inc., B-262181, 
Oct. 27, 1995, 95-2 CPD  para.  196, denying its protest of the award of a 
contract to Loral Training and Technical Services under request for 
proposals (RFP) No. F26600-94-R-0172, issued by the Department of the 
Air Force for the operation and maintenance of electronic threats and 
targets on the U.S. Air Force Weapons and Tactics Center Range Complex 
at Nellis Air Force Base, Nevada.

We deny the request for reconsideration.

Proposals were evaluated with respect to technical merit, current and 
past performance, and cost, listed in descending order of importance.  
The technical merit factor and its subfactors were evaluated using 
both color/adjectival ratings and proposal risk ratings.  The 
color/adjectival ratings represented the evaluators' views as to an 
offeror's understanding of and compliance with the requirements, as 
well as the soundness of its approach.  The proposal risk ratings 
represented the risks associated with each proposal.[1]  Offerors' 
current and past performance proposals were evaluated using these same 
color/adjectival ratings, as well as performance risk ratings of high, 
moderate, low, or not applicable.  Cost proposals were evaluated for 
realism and reasonableness.  Award was to be made to the offeror whose 
proposal was most advantageous to the government.

The evaluation of the best and final offers (BAFO) of Loral and 
Northrop yielded the following results:

                                 Loral             Northrop

Technical Merit      Green\Low            Green\High

Operations           Blue\Low             Green\High

Maintenance          Green\Low            Green\Moderate

Management           Green\Low            Blue\Low

Logistics            Green\Low            Green\Low

Technical Innovation Blue\Low             Blue\Low

Current\Past
Performance          Blue\Low             Green\Moderate

Evaluated Cost       $85.8 million        $69.7 million
The source selection authority (SSA) determined that, while Northrop 
offered the lowest cost with an acceptable technical approach, its 
"aggressive manning posture" presented a risk to schedule, cost and 
performance, especially in the two most important technical areas of 
operations and maintenance.  Further, while Northrop had an acceptable 
performance history, it posed a moderate risk to schedule, cost and 
management.  The SSA stated that, given its aggressive manning, 
Northrop might require significant, serious intervention in terms of 
money and management oversight.  The SSA concluded that Northrop's 
lower cost was not worth the high proposal risk and moderate 
performance risk,[2] and that Loral's proposal represented the best 
value to the government.  

In its protest, Northrop argued that the Air Force improperly failed 
to discuss with the firm the concerns over its "aggressive manning 
posture" which led to its high risk technical merit rating.  We 
agreed.  The record showed that Northrop's proposal was downgraded 
under the risk element of the operations and maintenance subfactors 
for its "aggressive manning posture"--or low staffing levels--and that 
this criticism was a significant factor in the selection decision.  We 
concluded, however, that Northrop was not prejudiced by the Air 
Force's failure to raise these issues with the firm.  Northrop's 
request for reconsideration disagrees with this conclusion.  
Specifically, Northrop argues that we failed to apply the presumption 
of prejudice that follows from a finding of inadequate discussions, 
and that the record establishes that there was a reasonable 
possibility that its proposal's technical rating would have improved 
had adequate discussions been held.

Competitive prejudice is an essential element of every viable protest.  
Lithos Restoration, Ltd., 71 Comp. Gen. 367 (1992), 92-1 CPD  para.  379.  
Where improper discussions were held, we will resolve any doubts 
concerning the prejudicial effect of the agency's actions in favor of 
the protester; a reasonable possibility of prejudice is a sufficient 
basis for sustaining the protest.  National Medical Staffing, Inc., 
B-259402; B-259402.2, Mar. 24, 1995, 95-1 CPD  para.  163.  On the other 
hand, where no reasonable possibility of prejudice is shown or is 
otherwise evident from the record, our Office will not sustain a 
protest, even if a deficiency in the procurement is apparent.  
MetaMetrics, Inc., B-248603.2, Oct. 30, 1992, 92-2 CPD  para.  306.

As stated in our decision, we concluded that the record failed to show 
a reasonable possibility of prejudice to the protester due to the lack 
of discussions.  First, we found no evidence that discussions might 
have enabled Northrop to improve its proposal's technical merit rating 
from green to blue.  The technical evaluators' negative comments as to 
operations and maintenance were specifically linked to proposal risk, 
not to the considerations reflected in the color rating (the offeror's 
understanding of and compliance with the requirements, as well as the 
soundness of its approach).[3]  Thus, even if Northrop had been 
apprised of the Air Force's concerns with its "aggressive manning 
posture," and improved its proposal's risk rating as a result, the 
maximum rating its proposal would have received had it alleviated 
these concerns is green/low, the same as Loral's.  Second, the record 
showed that the current and past performance ratings were pivotal in 
the SSA's source selection decision, and Loral's ratings in this 
regard significantly exceeded those of Northrop.  Finally, we were not 
persuaded by Northrop's argument that the cost difference between the 
two proposals supported a finding of prejudice, as the cost difference 
unquestionably would be narrowed by any addition of personnel to 
Northrop's proposal.

In sum, we did not consider this to be an instance where prejudice was 
evident from the record.  Accordingly, this was not an appropriate 
case in which to presume prejudice from the lack of discussions.  On 
the contrary, where, as here, prejudice is not otherwise evident and 
the protester has sufficient information to show a reasonable 
possibility of prejudice and fails to do so, relying solely on general 
allegations of prejudice, our Office will deny the protest.  Compare 
Colonial Storage Co.--Recon., B-253501.8, May 31, 1994, 94-1 CPD  para.  
335; Labrador Airways Ltd., B-241608, Feb. 13, 1991, 91-1 CPD  para.  167.

Counsel for Northrop had at its disposal (pursuant to a protective 
order issued in this case) voluminous information related to proposal 
evaluation and source selection, including the complete evaluation 
documentation of its initial and revised proposals, as well as its 
BAFO, and all documentation related to the award decision.  Northrop 
did not use this information to show how appropriate discussions could 
have improved its proposal's technical merit rating from green to 
blue.  Instead, Northrop relied on the generalized statement that, 
"[t]he presumption [of prejudice] is hardly necessary in this case 
because the prejudice is so manifest."  The bulk of Northrop's 
arguments with respect to prejudice concerned the subject of its 
supplemental protest challenging its current and past performance 
rating, a protest which we dismissed as untimely during the pendency 
of the initial protest.  That the Air Force's pleadings with respect 
to prejudice also focused on this issue did not relieve the protester 
of the burden of arguing that it was prejudiced here.  The protester 
was clearly aware of the two distinct aspects of the technical merit 
evaluation, and should have been cognizant of the need to show why its 
proposal could have improved with respect to the non-risk aspect.

Under the Bid Protest Regulations applicable to this matter, a request 
for reconsideration must specify alleged errors of law made or 
information not previously considered by our Office.  4 C.F.R.  sec.  
21.12(a) (1995).  In order to provide a basis for reconsideration, 
information not previously considered must have been unavailable to 
the party seeking reconsideration when the initial protest was being 
considered.  Department of the Army--Recon., B-254979.2, Sept. 26, 
1994, 94-2 CPD  para.  114; Ford Contracting Co.--Recon., B-248007.3; 
B-248007.4, Feb. 2, 1993, 93-1 CPD  para.  90.  A party's failure to make 
all arguments or submit all information available during the course of 
the initial protest undermines the goal of our bid protest forum--to 
produce fair and equitable decisions based on consideration of the 
parties' arguments on a fully developed record--and cannot justify 
reconsideration of our prior decision.  Id.  Here, Northrop's request 
for reconsideration is based on information and arguments that were 
available during the initial protest, but not presented at that time.  
That is, during the initial protest Northrop could have explained why 
it believed that appropriate discussions could have improved its 
technical merit rating from green to blue.  Under the circumstances, 
Northrop's request does not provide a basis for reconsideration.  
Department of the Army--Recon., supra.

The request for reconsideration is denied.

Comptroller General
of the United States

1. The color/adjectival ratings were blue/exceptional, 
green/acceptable, yellow/marginal, or red/unacceptable.  The proposal 
risk ratings were high, moderate, or low. 

2. High proposal risk is defined in the RFP as "[l]ikely to cause 
significant serious disruption of schedule, increase in price, or 
degradation of performance even with special contractor emphasis and 
close government monitoring."  Moderate performance risk is defined as 
"some doubt exists, based on the offeror's performance record, that 
the offeror can perform the proposed effort."

3. Northrop's assertion that the agency "admitted" a link between its 
staffing approach and the color rating by lowering its color rating 
under the maintenance subfactor from blue in the initial evaluation to 
green in the final evaluation, after the firm reduced its maintenance 
staffing, is not clearly supported by the record.  Notwithstanding the 
use of the word "blue" in some areas of the initial evaluation 
documentation, the full narrative evaluation report shows that 
Northrop's proposal was rated green here, just as it was throughout 
the evaluation process.  Moreover, the weaknesses noted in the final 
report were the same as those noted in the initial report, indicating 
that any revision in the color rating was not due to the decrease in 
maintenance staffing.