BNUMBER:  B-266219
DATE:  February 7, 1996
TITLE:  A-1 Postage Meters and Shipping Systems

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Matter of:A-1 Postage Meters and Shipping Systems

File:     B-266219

Date:     February 7, 1996

J. Hatcher Graham, Esq., for the protester.
Grace Bateman, Esq., Seyfarth, Shaw, Fairweather & Geraldson, for 
Pitney Bowes, Inc., an interested party.
Bryant L. Durham, Esq., Department of the Air Force, for the agency.
John Van Schaik, Esq., and Michael R. Golden, Esq., Office of the 
General Counsel, GAO, participated in the preparation of the decision.

DIGEST

Protest challenging the terms of a purchase description for a mail 
processing machine is denied where, contrary to protester's 
allegations, specifications that protester challenges are not 
impossible to perform and do not otherwise preclude the protester from 
competing.

DECISION

A-1 Postage Meters and Shipping Systems protests the terms of request 
for quotations (RFQ) No. F09650-95-Q-4383, issued by the Air Force for 
an automated mail processing machine for the Base Information Transfer 
Center (BITC) at Warner Robins Air Logistics Center.  

We deny the protest.

The RFQ, which sought quotations for equipment listed on a General 
Services Administration federal supply schedule, included a purchase 
description with detailed specifications and delivery, installation, 
and quality assurance requirements for the mail processing machine.  
A-1 alleges that certain provisions of the purchase description are 
impossible to meet.  A-1 further argues that the purchase description 
includes requirements that are available only in mail processing 
machines manufactured by Pitney Bowes, Inc. and which exceed the 
agency's actual minimum needs.  Explaining that it is familiar with 
the operation of the BITC, A-1 maintains that the actual requirements 
of that facility are limited to the ability to timely meter and 
account for postage on letters and packages up to 70 pounds.  
According to 
A-1, the solicitation requires equipment that exceeds these minimum 
requirements.  

Agencies are responsible for specifying their needs in a manner 
designed to promote full and open competition.  D & R Tank Co., Inc., 
B-258529, Jan. 26, 1995, 95-1 CPD  para.  53.  Where a protester challenges 
a solicitation requirement, our Office will not substitute its 
judgment for the contracting agency's, which is most familiar with the 
conditions under which the supplies and services are to be used, 
unless the protester proves that the challenged specification is 
impossible to meet or otherwise unduly restricts competition.  
California Inflatables Co., Inc., B-249348, Nov. 9, 1992, 92-2 CPD  para.  
331.  Moreover, the fact that specifications are based upon a 
particular product is not improper in and of itself; nor will an 
assertion that a specification was "written around" design features of 
a particular product provide a valid basis for protest if the record 
establishes that the specification is reasonably related to the 
agency's minimum needs.  Hewlett-Packard Co., 69 Comp. Gen. 750 
(1990), 90-2 CPD  para.  258.   

We have considered the specifications that A-1 has challenged and we 
conclude that none of those requirements are impossible to perform or 
improperly restrictive of competition.

A-1 first challenges section 3.2.4.1 of the purchase description, 
which requires that the mail machine include the following features 
and performance characteristics:

     "Modular mailing system which automatically feeds without 
     operator intervention various sizes and weights of mail ranging 
     from post card size to flats measuring at least 11 inches by 13 
     inches by 1/2 inch thick.  The system will also be equipped with 
     a flat feeding kit to ensure efficient automated feeding.  The 
     machine shall be capable of determining nonstandard size mail, 
     and if required, automatically add the required surcharge to the 
     appropriate postage."

A-1 argues that the requirement for feeding "without operator 
intervention" is physically impossible since with any machine an 
operator will have to insert pieces of mail face up, with addresses 
parallel to the machine, the top edge against the feeder, and writing 
on the envelope facing the operator.  

In response to this contention, the agency argues that A-1's reading 
of the purchase description is unreasonable since section 3.2.4.1 
simply calls for a machine that "automatically feeds without operator 
intervention" (emphasis added), but does not call for loading and 
starting the machine without operator activity.  According to the 
agency, with any machine, an operator will have to turn the machine 
on, identify the class of mail to be processed, select the appropriate 
accounting code, and load the mail.  The agency explains that section 
3.2.4.1 calls for a machine that allows the operator to load mixed 
sizes and weights of mail, select the appropriate class and account 
number, and select a process button so that mail is weighed, postage 
applied, and the appropriate account charged "without operator 
intervention."

We agree with the agency that A-1's reading of the challenged 
specification as establishing an impossible requirement is 
unreasonable.  Section 3.2.4.1 does not call for a machine that 
arranges and loads the mail and turns itself on.  Rather, as the 
agency notes, any machine will require some operator activity to load 
and start the machine.  Read in context, the activity required to be 
performed without operator intervention is feeding the mail through 
the machine.[1]

A-1 also challenges as unduly restrictive the requirement of section 
3.2.4.1 that the machine be capable of determining nonstandard size 
mail and automatically adding any required surcharge to the 
appropriate postage.

The agency explains that the Domestic Mail Manual (DMM) requires that 
a surcharge be added to "nonstandard mail," that is, any mail piece 
weighing less than one ounce and exceeding size limits established by 
the DMM.  According to the agency, if the surcharge is not included in 
the postage, the mail will be returned by the Postal Service due to 
insufficient postage.

A-1 argues that no one would send a piece of mail weighing less than 
an ounce and exceeding the size limits in the DMM.  As a result, 
according to A-1, the circumstances requiring a surcharge would not 
occur so the requirement for a machine that can apply a surcharge to 
mail that requires it exceeds the agency's minimum needs.  However, 
A-1 also states that "[i]t should be noted that the Protestant's 
machine can identify and affix postage to nonstandard pieces, as 
necessary."  A-1 thus concedes that, as required by section 3.2.4.1, 
A-1's machine is "capable of determining nonstandard size mail, and if 
required, automatically add[ing] the required surcharge to the 
appropriate postage."

Prejudice is an essential element of every viable protest.  See  
Hines/Mortenson, 
B-256543.4, Aug. 10, 1994, 94-2 CPD  para.  67.  Since A-1's machine can 
perform the function in issue, and since the firm admits that it can 
meet the RFQ requirement,  section 3.2.4.1 does not affect A-1's 
ability to compete.  We therefore will not consider the issue further. 

A-1 similarly challenges a number of other provision of the purchase 
description but concedes that its machine can meet those 
requirements--demonstrating that it is not prejudiced by the 
challenged requirements.  For example, A-1 challenges section 3.2.4.2 
of the purchase description, which states,

     "The system shall be equipped with an 11 ounce capacity scale 
     which will allow the system to apply, without operator 
     intervention, appropriate postage and calculate discounts for 
     zip+4, presort, or bar coded mixed weight mail pieces, and 
     automatically reject mail exceeding the US Postal Service 11 
     ounce limit for first class letters/flats while processing at a 
     rate of at least 200 pieces per minute when processing uniform 
     mail."

A-1 again questions the term "without operator intervention," arguing 
that an operator would have to select an appropriate mail class and 
discounts and would have to load the mail on the machine.  In 
response, the agency again maintains that the protester's reading of 
the specifications is unreasonable.  According to the agency, although 
it is true that the operator would have to select the appropriate mail 
class and discounts and load the mail, the mail would then be weighed, 
postage applied, and the cost charged to the appropriate account 
without operator intervention.  The agency states that, contrary to 
A-1's contentions, section 3.2.4.2 does not call for a machine that 
would allow the operator to walk away from the machine while it is 
operating.

In its comments on the agency report, the protester states that its 
machine "would perform the required service as well as [a Pitney Bowes 
machine].  However, it would be performed in the Differential Weigh 
Mode and would not have to be presorted as would the Pitney Bowes 
machine."  Since A-1's machine would, according to A-1, perform the 
required service as well as the Pitney Bowes machine, it is unclear to 
us how section 3.2.4.2 would prevent A-1 from offering its machine.  
Again A-1 is not prejudiced by the requirement. 

A-1 also challenges the requirements of section 3.2.4.8 that the 
machine be equipped with user identification codes for up to 12 
operators and section 3.2.4.9 which requires "supplier provided bar 
codes."  Here again, since A-1 concedes that it can meet these 
requirements, it is not prejudiced by these provisions.[2]

The protest is denied.

Comptroller General
of the United States

1. In its comments on the agency report, A-1 for the first time 
challenges the requirement of section 3.2.4.1 for a "flat feeding 
kit."  This allegation is untimely.  Under our Bid Protest 
Regulations, a protest based upon alleged improprieties in a 
solicitation that are apparent prior to the time set for receipt of 
quotations must be filed before that time.  4 C.F.R.  sec.  21.2(a)(1) 
(1995).  Where a protester initially files a timely protest and later 
supplements it with new and independent grounds of protest, the later 
raised allegations must independently satisfy our timeliness 
requirements, since our Regulations do not contemplate the unwarranted 
piecemeal presentation or development of protest issues.  See Remtech, 
Inc., 70 Comp. 
Gen. 165 (1991), 91-1 CPD  para.  35.  Here, quotations were due on 
September 22, 1995.  Since A-1 first challenged the flat feeding kit 
requirement in its comments submitted on November 24, after the 
closing date, the allegation will not be considered.

2. Although A-1's protest also challenged sections 3.2.4.3, 3.2.4.4, 
3.2.4.7, and 5.1, the protesters' comments on the agency report did 
not address the agency's response. Where a protester comments on the 
agency report and fails to address issues to which the agency report 
responded, we consider such issues abandoned.  Datum Timing, Div. of 
Datum Inc., B-254493, Dec. 17, 1993, 93-2 CPD  para.  328.