BNUMBER:  B-262243; B-262243.2
DATE:  December 12, 1995
TITLE:  Pacific Architects & Engineers, Inc.

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Matter of:Pacific Architects & Engineers, Inc.

File:     B-262243; B-262243.2

Date:     December 12, 1995

D. Whitney Thornton II, Esq., and Mitchell H. Segal, Esq., Seyfarth, 
Shaw, Fairweather & Geraldson, for the protester.
Kathleen C. Little, Esq., and Eric M. Drattell, Esq., McDermott,Will & 
Emery, for Johnson Controls World Services, Inc., an interested party.
Capt. Bryant S. Banes, Department of the Army, for the agency.
Linda S. Lebowitz, Esq., and Michael R. Golden, Esq., Office of the 
General Counsel, GAO, participated in the preparation of the decision.

DIGEST

Where the agency reasonably downgraded the protester's proposal for 
inadequate staffing and experience in mission essential functional 
areas, the agency reasonably determined to award a contract to a 
higher technically rated, higher evaluated cost offeror consistent 
with the solicitation's evaluation scheme which provided that 
technical evaluation factors were more important than cost in 
selecting the proposal representing the best overall value to the 
government.

DECISION

Pacific Architects & Engineers, Inc. (PAE) protests the award of a 
contract to Johnson Controls World Services, Inc. (JCWS) under request 
for proposals (RFP) No. DAKF04-95-R-0001, issued by the Department of 
the Army for installation support services at the National Training 
Center, Fort Irwin, California.  PAE protests the evaluation of its 
proposal, the agency's alleged failure to conduct meaningful 
discussions, and the agency's cost/technical tradeoff decision.

We deny the protests.

BACKGROUND

The National Training Center at Fort Irwin provides an environment 
where Army forces can engage in intensive force-on-force and 
computerized live-fire training, basically replicating modern 
battlefield conditions.  The mission of the training center, as 
described in the RFP, is "to improve unit readiness through training 
by providing a unique training atmosphere and environment."  Data 
collected based on near-battlefield conditions allows for the 
evaluation of the "performance and effectiveness of the Army's 
organizations, equipment, doctrine, and training."

The RFP, issued on November 4, 1994, contemplated the award of a 
cost-plus-award-fee contract for a base period with 4 option years for 
installation support services in the following functional areas:  (1) 
public works; (2) range control and airfield operations; (3) training 
support center; (4) morale, welfare, and recreation; and (5) 
administrative support.[1]  The RFP was divided into 72 tasks 
corresponding to requirements in the RFP's performance work statement.

The RFP stated that the contract would be awarded to the firm whose 
proposal was deemed to represent the best overall value to the 
government.  The RFP included two evaluation factors--quality and 
cost.  The RFP stated that "quality is somewhat more important than 
cost," and while weights were not disclosed in the RFP, the quality 
evaluation factor was weighted at 60 percent and cost was weighted at 
40 percent.

The quality evaluation factor was comprised of three 
subfactors--technical, management, and quality control.  Again, 
although not disclosed in the RFP, technical was weighted at 50 
percent, management at 30 percent, and quality control at 20 percent.  
Each quality subfactor included several sub-subfactors.  As relevant 
to these protests, the technical subfactor included the sub-subfactors 
of technical approach, technical management, and technical experience.  
Technical approach, which included the sub-elements of resources and 
methodology, was "somewhat more important" than the other two 
sub-subfactors, which were of equal importance.  Cost, which was 
weighted, but not scored, was comprised of the following four 
subfactors:  (1) most probable cost/cost realism; (2) total estimated 
cost; (3) fee structure; and (4) cost control experience.  In 
assessing cost realism, the RFP stated that the agency would develop 
an independent government estimate based on the offeror's total 
overall approach.  The RFP also provided that the agency would 
evaluate variance, that is, the difference between an offeror's 
proposed and evaluated (most probable) costs.  The RFP stated that in 
selecting the best overall proposal, the agency would consider the 
value of each proposal in terms of the quality of services offered for 
the proposed cost, and the advantages or disadvantages of the proposal 
to the government.  The RFP provided that the importance of total cost 
in the selection would increase as relative differences between the 
overall quality of proposals decreased.

Eight firms, including PAE and JCWS, submitted initial quality and 
cost proposals which were evaluated by the four committees (technical, 
management, quality, and cost) comprising the agency's source 
selection evaluation board (SSEB).  The contracting officer included 
each proposal in the competitive range and subsequently issued to each 
competitive range offeror written discussion questions, identifying 
errors and/or omissions in an offeror's proposal and areas of an 
offeror's proposal which required clarification.  The contracting 
officer also conducted oral discussions with each competitive range 
offeror.  Following discussions, each competitive range offeror 
submitted a best and final offer (BAFO).  As relevant to these 
protests, the SSEB's final consensus scores for PAE and JCWS were as 
follows:

                    PAE       JCWS
Technical           70.5      75.6
Management          81.2      86.3
Quality Control     87.4      99.2
Total Weighted Score77.1      83.5

The consensus scores, which were supported by narratives of the 
strengths, weaknesses, and risks in each offeror's quality proposal, 
corresponded to the following adjectival ratings:  outstanding--90 to 
100 points; excellent--80 to 89 points; satisfactory--70 to 79 points; 
and poor--60 to 69 points.

For the range operations functional area, the evaluators concluded 
that PAE's proposal posed a high risk.  The evaluators determined that 
PAE failed to address several key requirements of the RFP and proposed 
"to continue to [do] business as it is done under the current 
contract, not the RFP."  The evaluators also determined that PAE had 
several critical shortfalls in staffing; did not separate range and 
airfield functions; did not provide radio clerks; did not understand 
the range facility management support system; and did not properly 
address contractor-furnished equipment requirements.

For airfield operations, the evaluators concluded that PAE's proposal, 
considered overall poor, posed a high risk.  The evaluators believed 
that PAE's proposed personnel cross-utilization plan could overtask 
individuals to the point of ineffectiveness.  The evaluators pointed 
out that PAE's operating plans were incomplete and lacked details.  In 
addition, the evaluators concluded that PAE had a poor technical 
background in airfield operations.  Specifically, for the airfield 
manager and airfield safety officer positions, PAE intended to rely on 
the experience of two individuals to be hired by PAE's range control 
and airfield operations subcontractor if the firm were awarded the 
contract.  The evaluators believed that, even though these individuals 
were qualified to perform the required tasks, if PAE's subcontractor 
did not ultimately hire these individuals, the technical experience of 
PAE and its subcontractor was questionable and very limited.

Concerning cost, PAE proposed the eighth lowest cost and it had the 
fourth lowest evaluated cost.  The variance between PAE's proposed and 
evaluated costs was 
2.8 percent, the lowest variance among the eight offerors.  JCWS 
proposed the sixth lowest cost and it had the fifth lowest evaluated 
cost.  The variance between JCWS' proposed and evaluated costs was 
13.9 percent.  While PAE's proposed cost was approximately 6.8 percent 
higher than JCWS proposed cost, PAE's evaluated cost was approximately 
3.2 percent lower than JCWS' evaluated cost.  The evaluation of cost 
proposals was supported by narratives of the advantages, 
disadvantages, and risks in each offeror's cost proposal.

The SSEB evaluations were reviewed by the agency's source selection 
advisory council (SSAC) and the source selection authority (SSA).  
With respect to PAE, the SSA considered its overall medium to high 
total weighted quality score, which corresponded to the adjectival 
rating of satisfactory, and recognized PAE's highest proposed cost, 
fourth highest evaluated cost, and lowest cost variance between its 
proposed and evaluated costs.  The SSA noted that PAE's overall 
quality approach was rated as minimally satisfactory.  More 
specifically, the SSA noted that PAE's proposal for the technical 
approach and technical management sub-subfactors was rated 
satisfactory and its proposal for the technical experience 
sub-subfactor was rated poor.  The SSA recognized that PAE proposed 
knowledgeable and competent range control operations management 
personnel, but that PAE failed to understand that range operations and 
airfield operations were required to be maintained as separate 
functions and that PAE failed to identify contractor-furnished 
equipment required to support range control operations.  The SSA 
listed a number of significant deficiencies in PAE's proposed approach 
for airfield operations, including PAE's failure to provide correct 
skill qualifications; a limited understanding of flight operations and 
air traffic control operations; and inadequate operating procedures.  
The SSA recognized that PAE's management proposal was rated in the low 
excellent range and its quality control proposal was rated in the 
overall medium to high excellent range with no noted deficiencies.

With respect to JCWS, the SSA concluded that its proposal demonstrated 
an overall excellent quality approach at a reasonable cost and 
presented an excellent probability of limited risk to the government.  
The SSA concluded that JCWS' proposed cost was reasonable and 
considered any risk to be acceptable regarding the variance between 
its proposed and evaluated costs.  The SSA concluded that JCWS 
demonstrated knowledgeable and competent comprehension of the range 
control requirements; JCWS proposed a unique staffing plan; JCWS' 
computer system would enhance the management of range control 
operations; and while JCWS' operating procedures were not complete, 
this shortcoming, considered to be of limited risk, could be corrected 
during contract phase-in.  The SSA noted that JCWS' airfield 
operations manual was very comprehensive.  The SSA recognized that 
JCWS' staffing approach had problems in the area of skill requirements 
and that JCWS lacked air traffic control experience.  The SSA 
recognized that JCWS' management proposal was excellent and its 
quality control proposal was outstanding, far exceeding the proposals 
of the other offerors.  The SSA selected JCWS for award.

TECHNICAL EVALUATION

PAE, which submitted a strong proposal for the public works functional 
area, questions the agency's decision to equally weigh (at 
approximately 23 percent each) the functional areas of public works, 
range control operations, and airfield operations in evaluating the 
technical approach sub-subfactor.  PAE argues that public works is 
"unquestionably the dominant function to be performed under the RFP" 
as evidenced by the projections in the government estimate showing 
approximately 65 percent of total staffing and estimated costs being 
allocated to the public works functional area.  PAE maintains that if 
public works had been assigned a substantially higher weight than 
range control operations and airfield operations, that is, if it were 
weighted at 65 percent as opposed to being equally weighted with the 
other two functional areas, its score for the technical approach 
sub-subfactor would have been higher.

We see no impropriety in the agency's decision to weigh the functional 
areas equally.  Even though the government estimate allocated 
approximately 65 percent of total staffing and estimated costs to 
public works, the record shows that the staffing and cost estimates 
did not correspond to or reflect any prioritization of minimum needs, 
but simply reflected that performance of public works requirements 
would be significantly more labor and cost intensive than performance 
of range control operations and airfield operations requirements.  In 
fact, the agency's source selection plan reflects that these three 
functional areas all were "mission essential" and of equal importance 
in accomplishing the primary training goals of the National Training 
Center, as described in the RFP's performance work statement.  Thus, 
we have no basis to question the agency's determination to equally 
weigh public works, range control operations, and airfield operations 
in evaluating the technical approach sub-subfactor.[2]

PAE next challenges the evaluation of its quality proposal for 
technical experience in the range control and airfield operations 
functional area.[3]  In reviewing an agency's evaluation, we will not 
reevaluate proposals, but instead, will examine the agency's 
evaluation to ensure that it was reasonable and consistent with the 
stated evaluation criteria.  Pacific Architects & Eng'rs, Inc., 
B-257431.7, Dec. 8, 1994, 95-1 CPD  202.

The RFP defined the technical experience sub-subfactor as "the 
specific experience related to the functional areas and includes 
direct experience of the personnel, the corporation, and the proposed 
subcontractors."  The RFP stated that the technical experience portion 
of an offeror's proposal "shall include the offeror's and any proposed 
subcontractor's technical experience during the last five years in 
performing services similar in size, type, and complexity required by 
the [performance work statement]."

As reflected in its proposal, PAE decided to subcontract range control 
and airfield operations requirements to a "relatively new . . . 
company."  PAE listed as its subcontractor's only experience an 
ongoing contract (since 1993) for maintenance, service, and repair of 
foreign and domestic vehicles at Fort Irwin.  Further, PAE stated in 
its proposal that "[o]ur experience is reflected in the level of 
people who comprise [the subcontractor organization]."

Specifically, PAE's subcontractor's vice president for operations was 
proposed as the subcontractor's range control and airfield support 
manager.  According to his resume, since 1991, this individual has 
been "[r]esponsible for Consolidated Services and Service Contract 
Management, acquisition of new contracts and Contract Administration"; 
from 1988 to 1991, was a "Department Manager, Training Support 
Department, F[or]t Irwin Community"; and from 1975 to 1976, was an 
"Airspace Management Officer" responsible for the management and 
control of a military airspace division.  Also included in this 
individual's resume were summary statements that "[a]s a Contract 
Administrator and as a Department Manager, the positions held in the 
area of Range Control and Airfield Operations are exactly related to 
this effort," and that this individual "[d]eveloped technical 
procedures for Range and Airfield Operations . . . [that] are 
currently in practice at F[or]t Irwin Range Control, Airfield 
Support."

In addition, PAE's subcontractor proposed to hire upon award, as 
evidenced by letters of commitment, two individuals for the airfield 
safety officer and airfield operations officer positions.  From 1987 
to 1990, the proposed airfield safety officer was an airfield 
manager/airfield aviation safety officer/range control radio 
supervisor under a predecessor contract at Fort Irwin.  From 1991 to 
the present, the proposed airfield operations officer was an airfield 
safety officer/supervisor under a predecessor contract at Fort Irwin 
responsible, among other things, for daily management of the aviation 
safety program.  This individual also served from 1987 to 1991 as an 
Army helicopter pilot and an assistant aviation safety officer.

The agency considered PAE, along with its proposed subcontractor, to 
have "a poor technical background," stating:

     "Apparently, [PAE] places all of [its] technical experience in 
     two individuals [its proposed subcontractor] plan[s] to hire for 
     the performance of this contract (Airfield Manager and Airfield 
     Safety Officer).  There is no doubt that the two individuals are 
     qualified to perform the mission, but there are no guarantees 
     that [PAE's subcontractor] will hire the individuals.  If [PAE's 
     subcontractor] does not hire the proposed individuals, then the 
     technical experience of [PAE and its subcontractor] becomes 
     questionable.  Therefore, the overall technical experience of 
     [PAE and its subcontractor] is very limited in a contract dealing 
     with airfield operations in a tactical environment."

From our review of the record, we think the agency reasonably 
concluded that PAE did not have previous direct corporate experience 
in performing requirements in the range control and airfield 
operations functional area.  Moreover, we think the agency reasonably 
concluded that PAE's proposed subcontractor, a "relatively new 
company" with only an ongoing contract for vehicle maintenance, 
service, and repair, also did not have previous direct corporate 
experience in performing range control and airfield operations 
requirements.  We further believe the agency had reasonable concerns 
with PAE's approach--the hiring of proposed personnel by the proposed 
subcontractor--for demonstrating experience.

In this regard, the record shows that the agency did not question the 
underlying qualifications of PAE's subcontractor's proposed personnel 
for the airfield safety officer and airfield operations officer 
positions; rather, the agency was hesitant to attribute to PAE and its 
subcontractor the experience of proposed new key personnel who had no 
previous institutional experience with either PAE's or its 
subcontractor's organization.  The agency also was concerned that even 
if PAE were awarded the contract, unforeseen circumstances could 
prevent PAE's subcontractor from hiring the proposed individuals for 
these key positions.  In response, PAE points to the experience of its 
subcontractor's vice president for operations who was proposed as the 
subcontractor's range control and airfield support manager.[4]  The 
record shows, however, that this individual's resume lacked any 
details and contained only summary statements regarding this 
individual's recent (within the last 5 years) range control and 
airfield operations experience.[5]  There also was no indication in 
this individual's resume that he had specific experience commensurate 
with the experience required for the airfield safety officer and 
airfield operations officer positions should the individuals proposed 
for these key positions not be hired by PAE's subcontractor.  On this 
record, we conclude that the agency reasonably downgraded PAE's 
proposal for a lack of corporate and personnel experience in the 
mission essential range control and airfield operations functional 
area.[6]

PAE also challenges the evaluation of its quality proposal concerning 
its personnel cross-utilization plan for the performance of the range 
control radio requirements.

PAE proposed to use airfield operations specialists, instead of range 
radio/data clerks, for performance of the range control radio 
requirements.  The agency downgraded PAE's quality proposal because it 
believed that PAE's proposed cross-utilization of airfield operations 
personnel for performance of these requirements was not feasible in 
light of the RFP's requirements.  The agency explains that while under 
the predecessor contract one individual could monitor a single radio 
for both range control and airfield communications, under the current 
RFP, range control and airfield communications require the use of two 
different radios because there are two different sites involved.  
Although PAE's proposed approach would have been acceptable under the 
predecessor contract, the agency concluded that this approach was not 
responsive to the requirements of the RFP.  In light of this 
explanation, we see nothing unreasonable with this aspect of the 
evaluation.[7]

MEANINGFUL DISCUSSIONS

PAE contends that the agency failed to conduct meaningful discussions, 
as required by Federal Acquisition Regulation  15.610; see Stone & 
Webster Eng'g Corp., B-255286.2, Apr. 12, 1994, 94-1 CPD  306, 
concerning a significant staffing shortfall in range control and 
airfield operations, specifically for the range radio/data clerk 
position.  PAE's contention is not supported by the record.

Task 33 of the RFP's performance work statement required the 
contractor to establish and operate the Range Control Center, 
including the firing desk (which involves range control and range 
status requirements) and the communications desk (which requires the 
operation, monitoring, and maintenance of constant two-way radio 
communications with all units utilizing any and all ranges/training 
areas).  As reflected in the government estimate, the agency estimated 
that to successfully perform task 33, the contractor would need 10 
range radio/data clerks and 1 range scheduler.

In its proposal, PAE discussed the firing desk and communications desk 
requirements under task 33.  PAE proposed 1 range scheduler, but no 
range radio/data clerks.  In response, the agency submitted the 
following two written discussion questions to PAE:

     "Clarify how the offeror proposes to staff the Firing Desk.  What 
     positions? Hours of operations? Radio Operations? Supervisory 
     responsibility? Weekend Operations?

     "Clarify how the offeror proposes to staff the Communication[s] 
     Desk with what positions, what hours of operations will be each 
     day? What position will be responsible to talk on the radios, who 
     will inspect the radios and what are the qualifications of that 
     position, what position is designated to repair [or] fix the 
     radios, who is qualified to work on SINGCARS, who will operate 
     the [range facility management support system], who will be in 
     charge?"[8]

During oral discussions, PAE also was advised that it was understaffed 
for 14 tasks, including task 33.  In its BAFO, PAE stated that the 
firing desk and the communications desk each would be staffed by an 
airfield operations specialist, 7 days per week, 24 hours per day, and 
that the airfield operations specialist would operate the radios.

Based on this record of discussions, we conclude that there can be no 
question that the agency conducted meaningful discussions concerning 
PAE's staffing shortfall of range radio/data clerks for task 33.[9]

PAE also contends that during discussions, the agency failed to advise 
the firm that the lack of experience of its proposed subcontractor for 
range control and airfield operations posed an increased risk of 
nonperformance of a critical mission requirement; that PAE's lack of 
understanding of significant changes in the RFP from the current 
contract created a substantial performance risk; and that PAE's 
proposal suffered from a critical shortfall, namely, a failure to 
maintain range control and airfield operations as separate functions.  
These arguments, which PAE first raised in its comments on the 
agency's initial administrative report, are untimely.

Under our Bid Protest Regulations, a protest not based on an apparent 
solicitation impropriety must be filed within 10 working days after 
the basis of protest is known, or should have been known, whichever is 
earlier.  4 C.F.R.  21.2(a)(2).  Where a protester files supplemental 
protest grounds, each new ground must independently satisfy the 
timeliness requirements of our Bid Protest Regulations, which do not 
contemplate the piecemeal presentation or development of protest 
issues.  QualMed, Inc., B-257184.2, Jan. 27, 1995, 95-1 CPD  94.  
This is true even if the supplemental protest grounds may be merely 
"examples" of flaws in the agency's evaluation generally alleged in 
the initial protest since such staggered presentation of "examples," 
each of which involves different factual circumstances and requires a 
separate explanation from the agency, constitutes precisely the 
piecemeal presentation of issues that our timeliness rules do not 
permit.  Id.

On August 2, 1995, PAE filed its initial protest and simply alleged a 
lack of meaningful discussions regarding staffing shortfalls in the 
range control and airfield operations and the training support center 
functional areas.  On September 11, the agency filed its initial 
administrative report and responded to PAE's argument regarding the 
referenced staffing shortfalls.  PAE received its copy of the report 
on September 13.  In its report, the agency included documentation 
addressing the evaluation of PAE's initial proposal and BAFO, copies 
of written discussion questions and a memorandum for the record of 
oral discussions, and the SSA's best value statement.  On September 
25, we verbally extended the due date for the filing of comments on 
the agency report so that a document dispute could be resolved.  On 
September 27, PAE filed a supplemental protest, raising several new 
grounds of protest "based upon information that was first disclosed to 
[PAE] in the 'modified' agency report, received by [PAE] on September 
13, 1995."  In its supplemental protest, PAE did not, however, raise 
any additional issues concerning the agency's alleged failure to 
conduct meaningful discussions.

By notice dated September 28, we resolved the document dispute.  
Because of a document transmittal problem, by notice dated October 3, 
we extended the due date for comments on the agency report and 
supplemental documents to October 11.  On this date, PAE filed its 
comments and raised three specific, new issues, as outlined above, 
concerning additional areas where it believed the agency failed to 
conduct meaningful discussions.

We conclude that the three specific, new issues involving the agency's 
alleged failure to conduct meaningful discussions, first raised by PAE 
in its comments filed on October 11, 1 month after receipt of the 
agency report on September 13, constitute supplemental protest grounds 
which fail to independently satisfy our timeliness requirements.  
Although PAE received an extension of time for filing its comments on 
the agency report, such an extension did not have the effect of 
waiving the timeliness requirements for filing bid protests; 
notwithstanding the comment due date, any protest allegations based on 
information in the agency report had to be filed no later than 
September 27, 10 working days after PAE received the agency report.  
Accordingly, PAE's three specific, new issues which concern the 
agency's alleged failure to conduct meaningful discussions are 
untimely.  Management Technology, Inc., B-257269.2, Nov. 8, 1994, 95-1 
CPD  248.[10]

COST/TECHNICAL TRADEOFF

PAE challenges the SSA's cost/technical tradeoff decision which 
resulted in the award to JCWS, whose higher technically rated, higher 
evaluated cost proposal was determined to represent the best overall 
value to the government.  Specifically, PAE points out that in its 
administrative report, the agency states that the firm submitted the 
"best overall" cost proposal.  PAE argues that it was prejudiced 
because this characterization was not reflected in the SSA's best 
value determination.  We disagree since it is clear from the record 
that PAE offered the "best overall" cost proposal only insofar as the 
variance between its proposed and evaluated costs was the lowest among 
the eight offerors.

Although JCWS submitted a higher evaluated cost proposal than PAE (by 
approximately 3.2 percent), the SSA determined that JCWS' overall 
excellent quality approach, compared to PAE's overall minimally 
satisfactory quality approach, justified the payment of a cost premium 
to JCWS.[11]  Thus, having considered the entire record, we conclude 
that the SSA's determination to award the contract to JCWS, whose 
higher technically rated, higher evaluated cost proposal was deemed to 
represent the best overall value to the government, was reasonable and 
consistent with the RFP's evaluation scheme.  See Pacific Architects & 
Eng'rs, Inc., supra.

The protests are denied.

Comptroller General
of the United States

1. At issue in these protests is the functional area involving range 
control and airfield operations.

2. PAE also argues that the agency reversed the importance of the 
resources and methodology sub-elements of the technical approach 
sub-subfactor.  The RFP provided that the resources sub-element was 
"substantially more important" than the methodology sub-element.  PAE 
points to an uncompleted composite scoring worksheet in the agency's 
source selection plan which shows a sub-element weight of 30 percent 
for resources and 70 percent for methodology, and argues that the 
methodology sub-element was "substantially more important" than the 
resources sub-element, contrary to the terms of the RFP.

PAE's argument is not supported by the record.  The record shows that 
in evaluating PAE's proposal, consistent with the terms of the RFP, 
the agency considered the resources sub-element to be "substantially 
more important" than the methodology sub-element and that the scoring 
worksheet completed for PAE's BAFO weighed the resources sub-element 
at 70 percent and the methodology sub-element at 30 percent.  The 
record further shows that the uncompleted composite scoring worksheet 
in the source selection plan simply contained a typographical error.

3. PAE was advised at its debriefing that it was ranked fourth 
overall.  PAE did not protest the evaluation of the proposals of the 
higher overall ranked intervening offerors.  Therefore, PAE only had 
standing to protest the evaluation of its proposal, arguing that had 
its proposal been properly evaluated, it would have been ranked first 
overall and its proposal would have been deemed to represent the best 
overall value to the government.

4. In its second set of supplemental comments, PAE also states that it 
demonstrated experience in range control and airfield operations as 
reflected by the experience of its proposed project manager and its 
proposed installation support department manager, individuals who did 
not currently work for PAE, but who would be hired upon award as 
evidenced by letters of commitment.  The resumes for these individuals 
appear to show that they had relevant range control and airfield 
operations experience.  However, just like PAE's subcontractor's 
proposed new key personnel, these individuals also had no previous 
institutional experience with PAE's organization and present the same 
concerns to the agency.

5. The record shows that the agency submitted the following written 
discussion question to PAE concerning the resume of its 
subcontractor's vice president for operations:  "[r]esume does not 
show any experience in Range and Airfield Operations.  Please 
clarify."  PAE responded that this individual's resume had been 
changed to reflect his range and airfield experience at Fort Irwin.  
However, as discussed, the resume lacked details of this individual's 
recent and relevant experience.  PAE further stated, in summary 
fashion, that "[a]lthough [this individual] has extensive experience 
in Range and Airfield Operations, [its subcontractor] will also 
provide years of additional experience through the personnel who had 
accepted job offers and will work for [this individual] in key 
positions."

6. PAE received a consensus score of zero for range control and 
airfield operations experience.  However, its overall consensus score 
for technical experience, covering all functional areas, was 62 
points.  We do not believe that PAE was prejudiced by the zero score 
for range control and airfield operations experience since, as 
discussed, PAE failed to demonstrate recent, relevant corporate and 
personnel experience for the requirements of this functional area.  

7. We note that the agency advised PAE during discussions to refer to 
an attachment to the RFP's performance work statement which discussed 
detailed procedures for the performance of range control and airfield 
operations requirements.  To improve its proposal, the agency also 
suggested that PAE "consider incorporating [into its proposal] current 
installation information and current military procedures from the 
[National Training Center--Airfield Procedures Guide]."  (Emphasis in 
original.)  The record shows that PAE did not request a copy of this 
publication until October 1995, during the pendency of these protests.

8. Given the specificity of these questions, we find baseless PAE's 
contention that these were not discussion questions simply because 
they were presented under the caption "clarification." 

9. The agency prepared a memorandum for the record of its oral 
discussions with PAE.  The narrative section of the memorandum shows 
that PAE was advised, and PAE has not shown otherwise, that it was 
understaffed for task 33, the task, as previously stated, under which 
PAE addressed the firing desk and communications desk requirements.  
Attached to this memorandum was a most probable cost staffing matrix 
for PAE's proposal.  The matrix was broken down by task number and 
showed the government estimate for staffing, the number of persons 
proposed by PAE, the government's most probable cost staffing estimate 
for PAE's proposal, and a delta column.  The matrix, however, 
contained a typographical error involving the reversal of the 
government's most probable cost staffing estimates for task 31 and 
task 33.  Because the matrix showed that PAE was understaffed for task 
31, not task 33, and task 31 was not listed in the memorandum of oral 
discussions as a task area for which PAE was told it had a staffing 
shortfall, PAE, disregarding the record of written discussions, argues 
that the agency failed to conduct meaningful discussions regarding the 
absence of any range radio/data clerk positions in its proposal for 
task 33.

There is no merit to this argument.  Even if PAE's staffing shortfall 
for range radio/data clerks for task 33 was not orally discussed, and 
PAE has not established that this is the case, PAE's understaffing 
problem clearly was the subject of two written discussion questions, 
as previously addressed.  We think there can be no dispute that 
discussions in this regard were meaningful.

Finally, we note that the agency made upward adjustments to both PAE's 
and JCWS' most probable cost staffing estimates to account for 
staffing shortfalls.  With respect to JCWS, it was understaffed by 1 
person in the mission essential range control operations functional 
area and by 12 persons in the non-mission essential training support 
center functional area.  The agency considered JCWS' understaffing in 
the range control operations functional area to be limited, noting 
that it had a "unique" staffing plan, and its understaffing in the 
training support center functional area, for which JCWS presented "a 
sound technical and management approach," to be of some, but 
acceptable, risk.

10. We point out that there was sufficient information included in the 
so-called "modified" agency report received by PAE on September 13 to 
have triggered the filing by September 27 of a supplemental protest 
issue challenging the agency's alleged failure to conduct meaningful 
discussions regarding the experience of PAE's proposed subcontractor.  
Specifically, the report contained copies of the individual technical 
evaluators' assessments of PAE's BAFO for range control operations 
("[t]he proposed subcontractor of the offeror appears somewhat 
knowledgeable about [range control operations], but not very competent 
in overall operation") and airfield operations ("[PAE] has a poor 
technical background [and] [a]pparently, [PAE] places all of [its] 
technical experience in two individuals [its proposed subcontractor] 
plan[s] to hire for the performance of this contract . . . .  If the 
[subcontractor] does not hire the proposed individuals . . . then the 
technical experience of [PAE and its subcontractor] becomes 
questionable . . . and is very limited in a contract dealing with 
airfield operations in a tactical environment").  Finally, the SSA's 
best value statement furnished to PAE clearly stated that "[PAE's] 
technical experience is considered poor."

We also point out that PAE is untimely from its debriefing in alleging 
that the agency failed to conduct meaningful discussions regarding its 
lack of understanding of significant changes in the RFP from the 
current contract and its failure to maintain range control and 
airfield operations as separate functions since, as the memorandum of 
the August 1, 1995 debriefing shows, PAE was advised, among other 
things, that (1) "[y]our personnel staffing was not adequate in range 
and airfield operations"; (2) "[t]he new contract is not the same a[s] 
the current [contract]"; and (3) PAE "[d]id not separate the Range 
functions from the Airfield [functions] [and] proposed to use Airfield 
radios and personnel to monitor Range." 

11. The record shows that in response to discussions, PAE capped its 
G&A rate in its BAFO, and that this was listed by the cost evaluators 
as a strength of the firm's cost proposal.  The evaluators concluded 
that PAE's cost proposal did not reveal any significant proposal 
risks.  The record also shows that JCWS did not cap its G&A rate in 
its BAFO.  The agency referenced a report of the Defense Contract 
Audit Agency (DCAA) in which DCAA explained that it verified PAE's 
proposed G&A rates as reflected in a forward pricing rate agreement 
and the mathematical accuracy of JCWS' G&A rate calculation.  DCAA 
took no exception to JCWS' proposed G&A rate, and only recommended 
that the agency "consider" the inclusion of a G&A rate ceiling in any 
resulting contract.  The evaluators listed JCWS' lack of a cap on its 
G&A rates as a weakness in its cost proposal.  Like PAE, however, the 
evaluators concluded that JCWS' cost proposal did not reveal any 
significant proposal risks.  The record shows that the SSAC, in making 
its briefing and recommendation to the SSA, noted PAE's constant G&A 
rate for each period of performance and JCWS' decision not to cap its 
G&A rate, which decreased for the option years.  The SSAC's report 
furnished to the SSA concluded that JCWS' G&A rate was very favorable, 
and in light of the firm's previous cost experience, concluded that 
JCWS' decision not to cap its G&A rate presented only a slight risk in 
an otherwise favorable cost proposal.