BNUMBER:  B-270518  et al. , Mar. 15, 1996, 96-1 CPD ¶ 156 at 4.   Even where there is credible evidence of bias, the protester must demonstrate that the bias  translated into action which unfairly affected the protester's competitive position; that is,  the protester must demonstrate that the allegedly biased official exerted improper  influence in the procurement on behalf of the awardee or against the protester.    Id.   
DATE:  May 28, 1998
TITLE: William L. Menefee, B-270518 et al., Mar. 15, 1996, 96-1 CPD
¶ 156 at 4. Even where there is credible evidence of bias, the
protester must demonstrate that the bias translated into action
which unfairly affected the protester's competitive position; that
is, the protester must demonstrate that the allegedly biased
official exerted improper influence in the procurement on behalf of
the awardee or against the protester. Id., May 28, 1998
**********************************************************************

Matter of:William L. Menefee

File:B-279272            
        
Date:May 28, 1998

William L. Menefee III, for the protester.
Lynn W. Flanagan, Esq., Department of Agriculture, for the agency.
Paula A. Williams, Esq., and Michael R. Golden, Esq., Office of the 
General Counsel,
GAO, participated in the preparation of the decision.

DIGEST

Selection of offer with higher combined technical and price scores 
than that
proposed by the protester is unobjectionable where the evaluation was 
conducted
in accordance with solicitation, and the record supports the agency's 
view
that the protester's proposed building site was less desirable than 
the
awardee's.

DECISION

William L. Menefee protests the award of a lease to Cook Carson, Inc. 
(Carson)
under solicitation for offers (SFO) No 57-7335-79, issued by the 
Department of
Agriculture for office space in Pauls Valley, Oklahoma.  Menefee 
argues that the
award to Carson at a rent higher than that proposed by Menefee is 
based on
USDA's continued bias against Menefee, which translated to an 
unreasonable
evaluation of its offer. 

We deny the protest.

As amended, the SFO calls for 7,550 square feet (sq. ft.) of 
occupiable space in a new or existing building of sound and 
substantial construction, along with 50 on-site, paved parking spaces 
to house the offices of the Farm Service Agency (FSA), Rural Economic 
Community Development Service (RD), and the National Resources and 
Conservation Service (NRCS).[1]  The SFO contemplated award of a 
5-year lease with one 5-year option to the responsible offeror whose 
offer, conforming to the solicitation, was most advantageous to the 
government, price and other factors considered. 

Offers were to be evaluated on the basis of the following eight 
technical factors,
worth a maximum of 50 points,[2] and listed in descending order of 
importance:     
(1) quality/physical characteristics (including the age and physical 
condition of the
building, interior and exterior appearance of the space, 
attractiveness of grounds,
landscaping and approaches); (2) accessibility and location 
(accessibility to primary hard-surfaced roads, compatibility with 
surrounding area, and proximity of eating facilities); (3) layout 
capability (layout efficiency of space); (4) safety (including fire 
and structural safety, and surrounding area); (5) parking; (6) first 
floor space; 
(7) fixed rate, fully serviced lease; and (8) energy conservation.  
With regard to
price, also worth a maximum of 50 points, the offeror proposing the 
lowest annual rental would receive the maximum number of points for 
price.  Other offerors would receive a percentage of these points 
based on a ratio of the low offeror's annual rental to the other 
offerors' annual rental.   

Menefee's and Carson's offers were among those submitted in response 
to the SFO
by the September 22, 1997 extended due date.  Menefee submitted offers 
for two
locations--for the existing space currently occupied by the three USDA 
agencies,
and space in a building to be constructed on its offered site; Carson 
proposed to
construct a new building on its offered site.  Menefee's and Carson's 
initial
proposals were evaluated as follows:

                               Menefee
                          Existing Space   Menefee
                                          New Space  Carson
                                                   New Space

Quality/Physical Characteristics
(12 Maximum Points)               9          11        11

Accessibility and Location (11 Max. Pts.)9   10        10

Layout Capability (7 Max. Pts.)   6           7         7

Safety (5 Max. Pts.)              3           5         5

Parking  (5 Max. Pts.)            3           4         5

First Floor Space (4 Max. Pts.)   4           4         4

Fixed Rate, Fully Serviced Lease (4 Max. Pts.)44        4

Energy Conservation (2 Max. Pts.) 2           2         2

TOTAL TECH. PTS. (50 Max.)       40          47        48

PRICE POINTS[3] (50 Max.)        50         39.3      46.3

TOTAL POINTS (100 Max.)          91         86.3      94.3
On November 12, based on the initial evaluation results and site 
visits, the real
property leasing officer (RPLO) recommended award to Carson on the 
basis of
initial proposals.  The SAC and the county administrative committee 
(CAC)
reviewed the offers received and the technical evaluations and 
concurred with the
RPLO's recommendation that award should be made to Carson.  Later that 
same
day, the RPLO notified Carson by telephone that it had been selected 
for the
proposed contract award.  

On November 13, the RPLO received a telephone call from Menefee 
questioning the
agency's decision to make award to Carson without requesting best and 
final offers
(BAFO).  Upon review of the SFO, the RPLO concluded that offerors 
should have
been given an opportunity to submit BAFOs; discussions were then 
conducted with offerors on November 13 and 14.  During discussions 
with Menefee concerning its offer for the existing space, the RPLO 
addressed the SFO's parking requirements and was assured by the 
protester that 50 parking spaces would be available for the agency's 
use at this location.  Regarding its proposed newly constructed space, 
the RPLO discussed the lot size and whether the lot could accommodate 
a suitable building and 50 on-site parking spaces.  In response, 
Menefee at first reported the lot size as 200 x 200 ft., which Menefee 
stated could amply accommodate the agency's needs as specified in the 
SFO.  The next day, November 14, Menefee informed the RPLO that the 
lot size was 160 x 200 ft., not 200 x 200 ft. as Menefee had 
previously indicated; nonetheless, the protester stated that the 160 x 
200 ft. lot could satisfy the agency's needs.

Thereafter, the RPLO, with the assistance of an agency resource 
engineer, searched
the courthouse records to verify the lot size; the courthouse records 
indicated that
the lot actually measured 140 x 200 ft.  The RPLO consulted with a 
leasing
officer at the General Services Administration (GSA) to determine 
whether
Menefee's 140 x 200 ft. lot was big enough to construct a building 
with 7,550 sq. ft. of occupiable space along with 50 parking spaces.  
GSA raised concern about how the proposed lot size of 140 x 200 ft. 
(the equivalent of 28,000 gross sq. ft.) could be adequate for a 
building of approximately 7,600 sq. ft. (approximately 8,000 gross sq. 
ft.) plus 50 parking spaces.  According to GSA, surface parking for 50 
vehicles would normally require 15,000 sq. ft. and, depending on the 
width of setbacks around the perimeter of the site for sidewalks and a 
buffer zone, Menefee's proposed site might accommodate only a building 
of approximately 8,040 gross sq. ft. and parking spaces for 42 
vehicles.  In GSA's opinion, the ideal lot size for a building that 
would meet USDA's needs and provide 50 parking spaces would be 42,600 
sq. ft., and not 28,000 sq. ft., which was the size of Menefee's lot.  

BAFOs were received on November 19.  In its BAFO, Menefee 
significantly reduced the proposed annual rent for its newly 
constructed space, while Carson reduced its annual rental to $94,375.  
Following the evaluation of BAFOs, Carson's technical score, 48 out of 
a possible 50 points, remained unchanged.  Its high technical score 
was primarily based on its score under the quality/physical 
characteristics factor and the accessibility and location factor, 
which reflected its offer of newly constructed space in a good 
location, with unlimited room for expansion, that will closely follow 
the layout sought by the agency.

In contrast, Menefee's BAFO earned a technical score of 39 out of a 
possible 50 points; Menefee's BAFO earned lower technical scores for 
the quality/physical characteristics of its proposed site (9 out of a 
possible 12 points) due to traffic safety concerns because the site 
was located near a highway.  In addition, Menefee's score was lowered 
because the large trees presently on the site would have to be removed 
to accommodate the building and parking areas, thereby diminishing the 
overall attractiveness of the site.  As to the accessibility and 
location of the site, the protester's score was reduced (9 out of a 
possible 11 points) because the proposed site is surrounded by a car 
wash to the east, an old wood building that is a seasonal garden 
center to the west, and an older, lower income residential area to the 
north.  Under safety, Menefee's technical score was reduced (4 out of 
a possible 5 points) because of the surrounding area; under parking, 
its score was reduced to zero (out of a possible 5 points) because 
adequate space was not available to provide the number of parking 
spaces called for in the solicitation.

Because Menefee's BAFO price was low, its BAFO received the maximum 50 
price points, for a combined technical and price score of 89 points.  
Carson's BAFO received 45.9 points for price, for a combined technical 
and price score of 93.9 points.  Based on her evaluation of BAFOs, the 
RPLO recommended award to Carson as the offeror submitting the most 
advantageous proposal.  The SAC and the CAC both concurred with her 
recommendation and the lease was awarded to Carson on December 5.  
Following denial of its agency-level protest, Menefee filed this 
protest with our Office on February 17.

Menefee's primary criticism of this procurement is that USDA is biased 
against it
since "being falsely accused of bid fixing by their Pauls Valley 
employee in 1996."     Essentially, Menefee argues that USDA's 
evaluation of proposals was tainted by
ongoing bias, resulting in the selection of Carson's proposal as the 
most advantageous to the government even though its own proposal 
offered a lower rental rate.

To support its allegation of bias, Menefee refers to an October 10, 
1996 conversation between Mr. Menefee and Mr. Thomas Roberts, the 
Community Development Manager for RD.  Mr. Menefee had visited Mr. 
Roberts's Pauls Valley office after learning that he had been accused 
of "bid fixing."  According to the protester, during this 
conversation, Mr. Roberts purportedly disclosed that the "real reason" 
why the SAC canceled the 1996 SFO was that certain procurement 
officials were "mad" with the CED for FSA because the CED had not 
given them more input in the selection of the leased space to be 
acquired under the 1996 procurement.  In addition, Menefee further 
contends that the same bias arises from dissatisfaction on the part of 
certain procurement officials with the current leased space in his 
building.  

Where a protester alleges bias on the part of procurement officials, 
the record must
establish that the officials intended to harm the protester, since 
government
officials are presumed to act in good faith.  Executive Sec. & Eng'g 
Techs., Inc.,    
B-270518 et al., Mar. 15, 1996, 96-1 CPD  para.  156 at 4.  Even where there 
is credible
evidence of bias, the protester must demonstrate that the bias 
translated into action
which unfairly affected the protester's competitive position; that is, 
the protester
must demonstrate that the allegedly biased official exerted improper 
influence in
the procurement on behalf of the awardee or against the protester.  
Id. 

Menefee has failed to make that showing.  Although Menefee relies on 
the October 10, 1996 conversation regarding the SFO cancellation that 
occurred a year prior to the issuance of this SFO to show bias against 
the protester, even if the conversation as represented by Menefee is 
factually correct, Menefee has made no showing that the RPLO who 
performed the evaluation and made the
recommendation for award to Carson was biased, or improperly 
influenced in any way by other procurement officials.  We therefore 
have no basis to conclude that USDA has acted improperly or 
unreasonably in its evaluation of proposals under the instant 
solicitation.  The kinds of action to which Menefee points, such as 
the cancellation of the 1996 solicitation, the alleged tenant 
dissatisfaction with the currently leased space in his building, and 
the initial decision by the RPLO to award the lease to Carson on the 
basis of initial proposals, do not demonstrate bias against Menefee or 
that any possible bias on the part of the Pauls Valley employees 
translated into improper action.  Consequently, we see no evidence in 
the record supporting bias in this award decision.

Moreover, our review of the record confirms the reasonableness of the 
agency's determination concerning which proposal was the most 
advantageous to the government, thus further underscoring the absence 
of bias.  The SFO clearly states that price was of equal importance as 
the combination of the other eight technical factors.  Although 
Menefee's BAFO was lower priced than Carson's, the record shows that 
Menefee's proposed site was considered less desirable and was rated 
lower in the technical areas involving quality/physical 
characteristics, accessibility and location, safety, and parking.  
While the protester argues, for example, that its proposal was 
"rejected" because its proposed lot size was less than "42,000 square 
feet" and could not therefore accommodate the proposed building and 
parking spaces, the evaluation record contradicts this claim.[4] 

The record shows that Menefee's proposal was not rejected because of 
insufficient parking; rather, its proposal was merely downgraded under 
the parking factor.  More specifically, under the evaluation scheme 
set forth in the amended SFO, the maximum possible points an offeror 
could earn under the parking factor was           5 points.  The 
record shows that Menefee's BAFO received 0 points under the parking 
factor because the RPLO determined, in consultation with the agency's 
own engineer and a leasing official at GSA, that Menefee's proposed 
site was not large enough to accommodate both a suitable-sized 
building and 50 on-site parking spaces.  In its comments submitted in 
response to the agency report, Menefee does not rebut the RPLO's 
finding, but merely states that its proposal was not fairly evaluated.  
The record does not support Menefee's allegation of misevaluation.  
Moreover, since Menefee does not contest the agency's evaluation under 
the technical areas of quality/physical characteristics,[5] 
accessibility and location, and safety, we find no basis to conclude 
that the technical evaluation of proposals were unreasonable.  The 
evaluations were properly based on the review of the offerors' 
proposals and site visits which resulted in a higher overall score for 
Carson's proposal.  Menefee's general disagreement with the agency's 
evaluation does not establish that the evaluation was unreasonable.  
Peterson Constr. Co., B-256841, Aug. 3, 1994, 94-2 CPD  para.  55 at 3.

The protest is denied.

Comptroller General 
of the United States  

1. Previously, in connection with a different SFO issued in early 
1996, Menefee was the lowest-priced offeror with the highest technical 
evaluation score for existing space to house the USDA Service Center 
in Pauls Valley.  The offers were rejected and the SFO canceled 
because the State Administrative Committee (SAC), which is made up of 
employees from each of the three agencies--FSA, RD, and NRCS, 
questioned how the older renovated building offered by Menefee could 
receive a higher technical evaluation score than the newly constructed 
space offered by the other two offerors.  Further, the SAC was 
concerned that there was an appearance of a conflict of interest 
because the county executive director (CED) for FSA (who subsequently 
evaluated the offers received under the canceled SFO) was observed 
leaving the county office with Mr. Menefee on the same day proposals 
were due.  A second SFO, issued later that year, was also canceled 
when a lease moratorium was imposed on the FSA.  

2. The points assigned to each award factor were not listed in the 
SFO, but were listed in USDA's evaluation plan. 

3. In order to protect potentially proprietary information, we are not 
disclosing the offerors' proposed prices.

4. In this regard, the protester alleges that during a site visit he 
had advised the RPLO that he and his wife own the adjoining property; 
consequently, additional space was available if more than 50 parking 
spaces were needed.  However, the agency was not interested in 
additional parking spaces; rather, the agency was evaluating  whether 
Menefee's proposed site would provide 50 on-site parking spaces.    

5. The agency reports that during one of the RPLO's trips to Pauls 
Valley the RPLO  visited the local police department and discussed 
Menefee's proposed location with a police officer who told her that 
there had been a few car accidents where the cars did not complete the 
curve off the interstate highway and ended up in an area where the 
proposed building or parking lot would be constructed.  In its 
comments on the agency report, the protester provides a statement from 
the chief of police for the Pauls Valley police department in which 
the chief of police states that he had not spoken with the RPLO 
regarding traffic or criminal problems at Menefee's proposed location.  
The chief of police's statement did not dispute the veracity of the 
RPLO's conversation with an (unnamed) police officer who had informed 
her of the few accidents that had occurred in that area.  Under these 
circumstances, we have no basis to question the accuracy of the 
agency's account.