BNUMBER:  B-270585
DATE:  March 22, 1996
TITLE:  Shelby's Gourmet Foods

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Matter of:Shelby's Gourmet Foods

File:     B-270585

Date:March 22, 1996

Albert S. C. Millar, Jr., Esq., for the protester.
Michael Trovarelli, Esq., Susan L. Extein, Esq., Defense Logistics 
Agency, for the       agency.
Christine Davis, Esq., Office of the General Counsel, GAO, 
participated in the preparation of the decision.

DIGEST

Agency reasonably eliminated the protester's seriously deficient 
proposal from the competitive range in a prime vendor procurement to 
obtain full line food supplies for five military bases, where the 
proposal did not adequately describe how the protester would satisfy a 
contract of this scope and complexity.

DECISION

Shelby's Gourmet Foods protests the rejection of its proposal from the 
competitive range and the terms of request for proposals (RFP) No. 
SPO300-95-R-4000, issued by the Department of Defense (DOD), Defense 
Logistics Agency (DLA), to obtain a "prime vendor" to supply a full 
line of food products to various military installations in North 
Carolina.

We deny the protest.

In 1993, DOD introduced the Prime Vendor acquisition method of 
procuring food products, which is designed to use commercial practices 
and commercial items to the greatest extent possible.  Traditionally, 
DOD purchased a single food item or a limited number of items per 
solicitation; used military specifications to define the item(s); and 
provided for delivery to DOD depots where the government would store 
and redistribute the food in response to customer requests.  In 
contrast, under the Prime Vendor acquisition method, a single 
contractor supplies a full line of commercially available food 
products; uses electronic catalogues and an electronic ordering 
system; and employs a commercial distribution system.  Under such a 
distribution system, each military installation orders its immediate 
food requirements from the contractor, who supplies the food directly 
to the installation in routine, bulk shipments.
  
The instant prime vendor RFP, issued on an unrestricted basis, 
contemplated an indefinite quantity, indefinite delivery contract to 
supply food to five military bases in North Carolina.[1]  There were 
64 delivery points at the five military installations, and each 
delivery point required three weekly deliveries composed of any of the 
3,000 items on the RFP schedule.  These 3,000 food items encompassed 
the entire range of food products, e.g., fish, meat, poultry, fresh 
fruits and vegetables, dairy products, chilled foods, frozen foods, 
semi-perishable and canned foods, baked goods, and confections.  The 
estimated cost of supplying the food to the five specified bases was 
$25.1 million per year for a base and 3 option years.

The RFP advised that, of the 3,000 solicited food items, 120 items 
would probably account for 80 percent of the total amount spent under 
the contract.  The RFP provided quantity estimates for these 120 
items, for which it requested unit and extended prices, which were 
used to determine each offeror's total price.[2]

The RFP stated a "best value" evaluation scheme, in which technical 
quality was more important than price.  The technical evaluation was 
based upon 6 factors and 14 subfactors as follows: 

    A.  Distribution, Delivery System, and Location

        1.  Product Availability
        2.  Ordering System
        3.  Location
        4.  Surge/Mobilization Capability
        5.  Product Sourcing

    B.  Corporate Experience

        1.  Past Performance and Experience
        2.  Organizational Support

    C.  Quality Program

        1.  Quality Control Procedures
        2.  Inspection Procedures
        3.  Storage Procedures
        4.  Supplier Selection
        5.  Product Descriptions

    D.  Socioeconomic Considerations

    E.  Procurement Pricing Plan

        1.  Purchasing Procedures
        2.  Unit Pricing

    F.  Small Entrepreneurial Enhancement Development (SEED) Program

The technical factors were listed in descending order of importance.  
The RFP thoroughly described what the government expected the offeror 
to demonstrate under each technical factor and subfactor.  
Furthermore, the RFP authorized the government to conduct site visits 
to verify information in the offerors' proposals.  Under the 
evaluation plan for this procurement, an offeror could earn a rating 
of "highly acceptable," "acceptable," "marginally acceptable," or 
"unacceptable," under the various factors and subfactors.

The agency received three proposals by July 27, 1995.  Shelby's, a 
small business, submitted the low-priced proposal.  Shelby's 
represented, pursuant to Federal Acquisition Regulation (FAR)  sec.  
52.215-6, that it was submitting its offer as a corporation, as 
opposed to a joint venture or a partnership, and Shelby's proposal 
contained no information suggesting a joint venture or partnership 
arrangement.  In its 2-1/2-page technical proposal, Shelby's listed 
its prior DOD food service contracts, which ranged in value from 
$17,271.60 to $143,747.78.  Under the Distribution, Delivery System 
and Location factor, the protester stated that it owned a computer to 
receive product orders; that it owned a delivery truck and could rent 
other trucks; and that its warehouse was inspected by a military 
veterinarian and the Georgia Department of Agriculture.  The protester 
addressed the Quality Program factor by stating that it "always 
look[ed] for quality products backed by a replacement guarantee."

From August 15 to August 17, the technical evaluation panel (TEP) 
visited the site or sites designated by each offeror as its place of 
performance.  The protester's proposal listed a single site as its 
place of performance--Shelby's warehouse in St. Mary's, Georgia near 
Jacksonville, Florida.  The TEP judged from the site visit that the 
protester's warehouse, inventory, computer resources, quality 
assurance program, distribution system and organizational structure 
were inadequate to support a contract of this size and complexity.  
For example, the TEP stated that the protester had "no 
[organizational] structure outside of owner.  Owner is buyer, loader, 
driver, [quality assurance] and whatever else is needed."  Although 
the protester stated at the site visit that it could obtain adequate 
supplies and additional warehouse space from two Jacksonville-based 
suppliers (Jacksonville Hotel Supply Co. (JHS) and Winn-Dixie Grocery 
Co.), the protester did not describe the alternate warehouse 
facilities and could not give a "viable answer" as to how it would 
"receive orders, purchase varying quantities of up to 500 items, 
receive them, breakdown [and] load orders, and deliver to 50 - 60 
points across [North Carolina] in less than 48 [hours or] as little as 
4 - 6 [hours]."

On August 29, the contracting officer requested additional information 
from each offeror to complete the proposal evaluation.  The 
contracting officer advised Shelby's that it had not adequately 
addressed any of the evaluation factors, and asked Shelby's to review 
the solicitation requirements and to provide the required information.  
In its response, Shelby's provided more proposal information and also 
asserted that Winn-Dixie and JHS were Shelby's joint venturers in the 
competition.  Shelby's submission prompted the contracting officer to 
request "a written joint venture agreement, or any other legal 
documentation to support your claim of a joint venture."  In response, 
Shelby's produced letters from JHS' Vice President, who affirmed the 
claimed joint venture arrangement,[3] and a letter from Winn-Dixie's 
Jacksonville location director, who did not.

On November 1, 1995, the contracting officer completed his review of 
the offerors' proposals and all evaluation documentation generated by 
the business evaluation panel and the TEP.  Based upon this review, 
the contracting officer concluded that the protester's technical 
proposal was unacceptable overall and eliminated it from the 
competitive range.  The agency found Shelby's proposal unacceptable in 
9 of the 10 subfactors comprising the most important Distribution, 
Delivery System and Location factor and the third-most important 
Quality Program factor.  With respect to the second-most important 
Corporate Experience factor, Shelby's proposal received an 
unacceptable rating under the Organizational Support subfactor and a 
neutral rating under the Past Performance and Experience subfactor 
(which was accorded because the protester was found to possess no 
relevant experience, see FAR  sec.  15.608(a)(2)(iii)).[4]

Among the major deficiencies attributed to Shelby's proposal was its 
failure to include a plan for ensuring that orders could be filled and 
delivered according to the contract requirements, particularly given 
that Shelby's own inventory and warehouse were inadequate to meet the 
demands imposed by the RFP.  Although Shelby's stated that it could 
obtain sufficient stock and adequate warehouse space from Winn-Dixie 
and JHS, the agency found that Shelby's had not substantiated its 
claim of a joint venture with these firms, and that neither firm 
promised to reserve any inventory or warehouse space for Shelby's or 
to play a specific role in meeting the contract requirements.  Even 
though Shelby's was evidently a high-volume customer of these firms, 
Shelby's did not state which firm would be responsible for 
coordinating individual orders and consolidating shipments, where 
shipments would originate, which firm would make shipment 
arrangements, or how long it would take to make deliveries.  
Compounding this problem was the fact that Shelby's owned only one 
small, non-refrigerated delivery truck and proposed to use rented 
trucks from a Wilmington, North Carolina, firm to meet the contract 
requirements.  In the absence of any explanation from Shelby's, the 
contracting officer presumed that the trucks would travel from North 
Carolina to Jacksonville to retrieve the food, then from Jacksonville 
to North Carolina to deliver it, which the contracting officer viewed 
as highly inefficient.[5]

The contracting officer further found that Shelby's never addressed 
the Organizational Support subfactor, which required offerors to 
describe key personnel and their functions and to provide an 
organizational chart showing the individuals involved in contract 
performance.  Similarly, the contracting officer found that Shelby's 
submitted "so little information under all the [Quality Program] 
subfactors . . . that the response must be considered nonexistent."  
Specifically, the contracting officer found that Shelby's relied upon 
general statements, such as "we select the best," or "I always look 
for quality products," instead of describing the procedures and 
furnishing the documentation required by the Quality Program 
subfactors.

The contracting officer advised the protester of its proposal's 
elimination from the competitive range on November 8.  Shelby's 
protests that DLA lacked a reasonable basis for excluding its proposal 
from the competitive range.

The evaluation of proposals and the resulting determination of whether 
a proposal is within the competitive range is a matter within the 
discretion of the contracting agency, since the agency is responsible 
for defining its needs and the best method of accommodating them.  
OPSYS, Inc., B-248260, Aug. 6, 1992, 92-2 CPD  para.  83.  Our Office will 
only question the agency's evaluation where it lacks a reasonable 
basis or conflicts with the stated evaluation criteria for award.  See 
General Servs. Eng'g, Inc., B-245458, Jan. 9, 1992, 92-1 CPD  para.  44.  A 
protester's mere disagreement with the agency's technical evaluation 
does not establish that the evaluation was unreasonable.  DAE Corp., 
Ltd., B-257185, Sept. 6, 1994, 94-2 CPD  para.  95.

The record reasonably supports DLA's conclusion that Shelby's 
submitted a seriously deficient technical proposal that did not 
demonstrate the firm's ability to perform a contract of this scope and 
complexity, and Shelby's proposal was therefore properly rejected.  
From our review, the reasons given by DLA for finding Shelby's 
proposal unacceptable, as set forth above, were reasonably based.  It 
is apparent from the record that Shelby's, whose experience was 
limited to much smaller food service contracts, did not appreciate the 
significantly enhanced requirements imposed by this RFP and did not 
structure its proposal to meet such requirements.  In our view, DLA's 
rejection of Shelby's proposal was reasonable.

The protester's specific objections to the technical evaluation in no 
way cause us to question the reasonableness of the evaluation.  For 
example, the protester claims that DLA should have accepted its 
representation that it could make timely deliveries, instead of 
questioning Shelby's ostensible use of North Carolina rental trucks to 
retrieve food from Florida and return to North Carolina.  Shelby's 
simply asserts that "rhetorical questions as to how the product would 
get to the trucks would seem a little unnecessary."  Similarly, the 
protester argues that its proposal to obtain adequate supplies "from 
the Winn-Dixie warehouse on 24 hour notice, day or night," was 
"self-explanatory on its face," and that DLA had no basis to criticize 
the adequacy of Shelby's ordering and distribution system.  Contrary 
to the protester's bald objections, we think that DLA reasonably 
questioned these areas of Shelby's proposal and was entitled to probe 
beyond Shelby's blanket assurances that it could perform the contract.

Shelby's argues that DLA should have made site visits to Winn-Dixie's 
and JHS' facilities and credited Shelby's proposal with their 
resources and experience, since Shelby's in fact substantiated its 
joint venture with these firms.  This allegation has no merit.
  
Joint ventures are recognized legal entities for contracting with the 
government.  See FAR subpart 9.6.  A joint venture is an association 
of persons or firms with an intent, by way of contract, to engage in 
and carry out a single business venture for joint profit, for which 
purpose they combine their efforts, property, money, skill and 
knowledge.  See T.V. Travel, Inc.; World Travel Advisors, Inc.; 
General Servs. Admin.--Recon., 65 Comp. Gen. 109 (1985), 85-2 CPD  para.  
640.  In this case, Shelby's was requested to produce "a written joint 
venture agreement, or any other legal documentation to support [its] 
claim of a joint venture."  Shelby's did not produce such a joint 
venture agreement or documentation, nor has Shelby's ever claimed 
during the course of this protest that such documentation exists.  
Absent such an agreement designating the responsibilities, profits, 
liabilities and resources shared by the participating firms, the 
contracting officer was not required to accept Shelby's and JHS' 
blanket affirmation of a joint venture arrangement.[6]  Moreover, it 
is notable that Shelby's did not represent itself as a joint venture 
pursuant to FAR  sec.  52.215-6, did not designate any other firms' 
facilities as performance sites, and did not develop a technical 
approach integrating the responsibilities of its purported partners.

Finally, Shelby's protests that the Prime Vendor acquisition method 
and the RFP evaluation scheme are biased in favor of large businesses.  
Shelby's asserts that large businesses are more likely than small 
businesses to submit higher-priced, technically superior proposals in 
response to a Prime Vendor acquisition.  Shelby's argues that the 
agency should have neutralized this advantage by making price a more 
important evaluation factor, using all items on the RFP pricing 
schedule to calculate an offeror's total price, and making Corporate 
Experience a less important evaluation factor.

These allegations concern solicitation defects, which Shelby's should 
have protested before initial proposals were due in order to be 
considered timely under our Bid Protest Regulations, section 
21.2(a)(1), 60 Fed. Reg. 40,737, 40,740 (Aug. 10, 1995) (to be 
codified at 4 C.F.R.  sec.  21.2(a)(1)).  Shelby's concedes that the 
alleged defects were "apparent from the face" of the solicitation, but 
maintains that "it was not until the evaluation process was observed 
in action that it became crystal clear that the prime vendor concept 
was not designed to effect cost savings."  Our Bid Protest Regulations 
do not entitle protesters to wait until their proposals are rejected 
to protest such apparent solicitation defects.  Shelby's could have 
protested the acquisition strategy before initial proposals were due, 
but chose instead to compete under this strategy.  We will not now 
hear Shelby's untimely objections to the RFP.

The protest is denied.

Comptroller General
of the United States

1. The bases were Seymour and Pope Air Force Bases, Fort Bragg, Camp 
Lejeune, and Cherry Point Marine Corps Air Station.

2. As for the remaining items on the schedule, the RFP requested fixed 
prices reflecting each item's indirect and distribution costs, but not 
the item's invoice price.  The prices for the remaining items were not 
used to calculate each offeror's total price, although they were 
comparatively evaluated.

3. In an earlier letter, JHS's Vice President described Shelby's as a 
"customer." 

4. As for the remaining evaluation factors and subfactors, the 
protester's proposal received marginally acceptable ratings under both 
Procurement Pricing Plan subfactors, a highly acceptable rating under 
the Socioeconomic Considerations factor, and an acceptable rating 
under the SEED Program factor.  The favorable ratings were not deemed 
sufficient to overcome the deficiencies under the more significant 
evaluation factors. 

5. Shelby's also failed to address whether the rented trucks would 
meet the RFP's refrigeration and dry storage requirements.

6. As noted above, Winn-Dixie, although it did "not foresee any 
difficulties in providing . . . support" to Shelby's, never affirmed a 
joint venture arrangement as to this procurement, contrary to the 
protester's apparent belief.