BNUMBER:  B-270894.2; B-270894.3
DATE:  August 15, 1996
TITLE:  First Street Investments Limited Partnership

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Matter of:First Street Investments Limited Partnership

File:     B-270894.2; B-270894.3

Date:August 15, 1996

Alex D. Tomaszczuk, Esq., and Devon E. Hewitt, Esq., Shaw Pittman 
Potts & Trowbridge, for the protester.
Barry D. Segal, Esq., and Allan I. Aasmaa, Esq., General Services 
Administration, for the agency.
Christina Sklarew, Esq., John Van Schaik, Esq., and Michael R. Golden, 
Esq., Office of the General Counsel, GAO, participated in the 
preparation of the decision.

DIGEST

Protest against award to higher-priced, higher technically rated 
offeror is denied where the solicitation evaluation scheme gave 
greater weight to technical merit than price, and the agency 
reasonably concluded that protester's lower price did not outweigh the 
technical advantages demonstrated in the awardee's higher-priced 
proposal.

DECISION

First Street Investments Limited Partnership protests the award of a 
contract to Arizona Public Service (Arizona) by the General Services 
Administration (GSA) under solicitation for offers (SFO) No. 
GS-09B-96089 for a lease of office and related space for the Bureau of 
Indian Affairs and the Bureau of Reclamation in the Phoenix, Arizona 
area.  First Street alleges improprieties in the evaluation of 
competing offers and the award decision.

We deny the protest.

The SFO sought offers for a 10-year term, with 5 years firm, for 
approximately 60,546 rentable square feet yielding between a minimum 
of 54,492 to a maximum of 57,216 occupiable square feet.[1]  The SFO 
required the space to be located "in a first class quality building of 
sound and substantial construction" and to have a potential for 
efficient layout.  It further specified that the space offered "should 
be located in a new or modern office building with facade of stone, 
marble, brick, stainless steel, aluminum or other permanent materials 
in good condition acceptable to the contracting officer . . . .  
Overall, the building should project a professional and aesthetically 
pleasing appearance including an attractive front and entrance way."  
Further, the SFO required that if the offered space was not in a new 
or modern office building, it should be in a building that by 
occupancy had undergone first class restoration or adaptive reuse for 
office space with modern conveniences.  If the restoration work was 
underway or proposed, the offeror was required to submit with its 
offer architectural plans acceptable to the contracting officer.  The 
SFO listed a number of architectural requirements, such as a 
requirement for windows in each exterior bay, which could be waived by 
the contracting officer.

The SFO provided that the lease contract would be awarded to the 
offeror whose proposal was determined to be most advantageous to the 
government, based on price and other factors in the solicitation.  The 
SFO listed the following four evaluation factors and stated that these 
factors combined were significantly more important than price:  
building configuration, efficient layout, public parking; and building 
security.    

Three firms, including First Street and Arizona, submitted initial 
offers.  First Street offered space currently leased by GSA for the 
Bureau of Indian Affairs.  On December 11 and 12, the agency conducted 
negotiations.  On December 12, the contracting officer issued letters 
requesting the submission of best and final offers (BAFOs) by December 
22 and transmitted an amendment.  First Street states that  the 
December 12 mailing it received contained only the amendment and the 
second page of the letter, which did not include the BAFO request.  
First Street states that it informed the agency on December 13 that it 
had not received a complete package and on December 19 it sent the 
agency a fax providing pricing information that had been requested 
during negotiations.  Only Arizona submitted its BAFO by the December 
22 BAFO deadline.  On January 2, First Street contacted the 
contracting officer to ask when BAFOs would be requested and was told 
about the contents of the December 12 letter, which was then faxed to 
First Street.  On January 4, First Street again contacted the agency, 
and it was agreed that the protester would be permitted to submit its 
BAFO by January 5.  The protester submitted a BAFO in accordance with 
these instructions, without revising the technical portion of its 
offer.  First Street's price revision was considered in the final 
evaluation.  Arizona was selected for award based on its 
higher-priced, higher technically rated proposal.

First Street primarily challenges the evaluation of the technical 
proposals and the decision to select Arizona for award.  Generally, 
the evaluation of technical proposals is a matter within the 
contracting agency's discretion since the agency is responsible for 
defining its needs and the best method of accommodating them.  Science 
Sys. and Applications, Inc., B-240311; B-240311.2, Nov. 9, 1990, 90-2 
CPD  para.  381.  In reviewing an agency's technical evaluation, we will not 
reevaluate the proposals, but will examine the record of the 
evaluation to ensure that it was reasonable and in accord with stated 
evaluation criteria, and not in violation of procurement laws and 
regulations.  Information Sys. & Networks Corp., 69 Comp. Gen. 284 
(1990), 90-1 CPD  para.  203.

First Street alleges that the evaluation was improper because every 
member of the source selection panel did not evaluate every part of 
each proposal, and because the source selection authority did not 
score proposals.  The protester points out that the source selection 
plan (SSP) identifies the source selection authority as a member of 
the evaluation team, and concludes that the source selection authority 
therefore was required to evaluate and score each proposal for 
technical merit.  Similarly, the protester concludes that because the 
SSP does not specifically provide that the evaluators are not 
responsible for scoring each evaluation factor, the SSP must require 
the source selection authority and other members to score each 
evaluation factor.  

We disagree.  We find no such requirements in the SSP and know of no 
basis to object to the agency's approach here, pursuant to which 
evaluation team members with differing skills or training scored those 
areas of the proposals related to their areas of expertise.  In 
addition, even if the SSP did require the approach that First Street 
suggests, SSPs are merely internal agency instructions which do not 
vest outside parties with rights; agencies are only required to adhere 
to the evaluation scheme outlined in the solicitation.  Antenna Prods. 
Corp., 69 Comp. Gen. 182 (1990), 90-1 CPD  para.  82.

Moreover, the record supports the conclusion that Arizona's proposal, 
and the space it offered, were superior to First Street's proposal and 
the space it offered.  First Street's proposal earned its lowest 
scores under the first two evaluation factors listed in the SFO.  
Under the first factor, building configuration, the SFO stated that 
the highest scores would be awarded for the following:

     "(a) Square or rectangular buildings with a center core 
     configuration to allow for large open space layout of systems 
     furniture and minimize required exiting.
     "(b) Buildings with required fire exiting that allows the maximum 
     open areas with minimum structural intrusions into the space.
     "(c) Buildings with 18,000 available occupiable square feet or 
     greater per floor.
     "(d) Contiguous space."

In the evaluation, proposals could be given a maximum of 60 points for 
this factor; First Street's proposal received 42 points, and Arizona's 
received 55 points.

Under the second factor, efficient layout, the SFO provided that the 
highest scores would be awarded as follows:
     
     "(a) Buildings with wide and regular column space (29' on center 
     or greater) to allow for a systems furniture layout with minimum 
     in wasted floor space.
     "(b) Buildings with center core to window wall dimensions of 50' 
     or greater.
     "(c) Buildings without narrow or irregular space configurations, 
     intrusions into the open space or other unusual building 
     features.
     "(d) Optimum layout based on the test fit provided by offeror."

Proposals could receive a maximum of 40 points for this factor; First 
Street's proposal received 27, and Arizona's received 34.

First Street offered space on four separate floors with approximately 
15,000 square feet available on each floor.  Each of the floors 
includes an area under all of the windows on the exterior walls that 
is unusable floor space but is considered "occupiable square footage" 
as measured by GSA's standards and therefore is included in the 
calculation of the lease price.  One side of the building has no 
windows, and another side provides no access to windows because the 
elevators and restrooms are all located along that wall.  The 
evaluation record describes the building configuration offered by 
First Street as "limiting, given the exiting, but not entirely 
unworkable."  It identifies as a problem irregular columns with narrow 
spaces left for workstations, noting that in some areas the columns 
would be in the middle of workstations.  The test fit revealed 
inefficiencies and inflexible areas.  For example, the protester's 
building did not offer the type of center core configuration 
appropriate to a large open space layout; did not offer minimal 
structural intrusions into the space; and did not offer at least 
18,000 square feet per floor.  Also, the protester did not offer space 
with the potential for an efficient layout with widely spaced columns 
or otherwise unobstructed areas.

On the other hand, the evaluators found that the building in which 
Arizona   proposed space has windows on all sides, nine foot ceilings 
throughout, and no columns and few other obstructions hindering the 
layout of the space.  The space offered is on two and one-half floors 
and the agency explains that it is most efficient to locate an agency 
on as few floors as possible.  The evaluators found no meaningful 
deficiencies in the space offered by Arizona and  First Street has not 
challenged the evaluation of Arizona's proposal.  Thus, on this record 
we have no basis to disagree with the conclusion that Arizona's 
proposal was technically superior to the protester's.

First Street also argues that the technical evaluation was flawed 
because the agency considered the "class" or aesthetic appeal of the 
buildings being offered, which the protester characterizes as the 
improper application of an unstated evaluation criterion.  As evidence 
of the improper consideration of the "class" of the buildings, First 
Street notes that the SSP used by the evaluators provided for the 
assignment of additional "price" points to proposals based on whether 
the offered buildings were class "A," "B," or "C."  In addition, the 
protester states that during a negotiation session an agency official 
noted that the firm's offered building was a class "C" building and 
after award the contracting officer commented on the "class" of 
Arizona's building.

We find no merit to this allegation.  As discussed above, the record 
shows that First Street's technical score was justified by 
considerations related to the building configuration and layout 
potential--in other words, considerations consistent with the 
evaluation scheme established in the SFO.  In addition, the agency 
reports that the provisions of the SSP concerning building class were 
not implemented in the evaluation.  Also, there is no evidence that 
building class was considered in the scoring of the proposals.[2]  In 
any event, we point out that the SFO included certain minimum 
requirements in the statement of work--concerning overall appearance 
and quality of the building exterior--that GSA was required to take 
into consideration in order to determine whether offered space met its 
minimum needs.  The record shows that in order to meet the 
requirements of the SFO, the building First Street offered would need 
extensive renovations or repairs, including the installation of new 
windows, replacing the heating, ventilation and air conditioning 
system, and overhauling the plumbing system.  The protester's proposal 
included no plans for such work, as required by the SFO.  Although 
First Street's proposal was kept in the competitive range, it appears 
from the record that First Street's building did not meet certain 
requirements.[3]  

First Street also argues that the award decision was flawed because 
price was not given sufficient weight.  In selecting an awardee, 
price/technical tradeoffs may be made subject only to the test of 
rationality and consistency with the established evaluation factors.  
Maytag Aircraft Corp., B-237068.3, Apr. 26, 1990, 90-1 CPD  para.  430.  An 
award to an offeror with a higher technically scored proposal and a 
higher price is unobjectionable, so long as the result is consistent 
with the evaluation criteria and the agency has determined that the 
technical difference is sufficiently significant to outweigh the price 
difference.  Calspan Corp., B-258441, Jan. 19, 1995, 95-1 CPD  para.  28.   
Even where a source selection official did not specifically discuss 
the price/technical tradeoff, we will not object to the tradeoff if it 
is clearly supported by the record.  Maytag Aircraft Corp., supra.

The record here reasonably supports the agency's price/technical 
tradeoff.  First Street's proposal received a technical score of 99 
points and offered a price of $12.95 per square foot.  Arizona's 
technical score was 119 points, and its price was $18.40.  Moreover, 
beyond the scores assigned to the proposals and the prices offered, 
the agency reports that leasing First Street's building would 
potentially have an impact on the operations efficiency of the tenant 
agencies and could be expected to result in difficult-to-estimate 
future costs resulting from the inflexible layout of the space.  The 
agency concluded, for example, that the irregular and narrow column 
spacing would require system furniture to be reconfigured and 
workstations to be specially designed or customized to accommodate the 
structural intrusions in the space.  Because the protester's building 
presents difficulties for space planning for system furniture, the 
agency calculates that its minimal square footage requirement would be 
higher for this type of inflexible layout than it would be in a 
building with large open spaces, such as the one offered by Arizona. 

In addition, because First Street's building has a smaller area 
available on each floor, the agency would not be able to locate its 
tenants' larger divisions on single floors; space requirements for 
certain equipment, such as copy machines, storage and file rooms, 
would have to be provided on each floor, increasing the total space 
required.  Thus, in making its price/technical tradeoff, the agency 
explains that it did not simply compare prices and technical scores, 
but took potential hidden costs into account.  Having considered the 
technical scores assigned to the two proposals and the advantages and 
disadvantages of the space offered by the two firms, the agency 
explains that it considered the superiority of Arizona's proposal to 
be worth the additional cost of awarding to that firm.  We have no 
basis to question that determination.[4]
First Street also alleges that GSA prevented First Street from 
competing under this procurement on a full and fair basis.  The 
protester bases this allegation on a number of events which it 
believes show a pattern of behavior intended to exclude First Street 
from the competition.  In this respect, First Street alleges that it 
was misled about the time frame concerning the request for (and 
submission deadline for) BAFOs, and that the agency unfairly required 
the firm to submit its BAFO in 24 hours after First Street sought 
information concerning the deadline.  The agency's account of the 
events alleged by First Street differs; the agency alleges, for 
example, that the protester offered to submit its BAFO within 24 
hours.  We need not resolve this conflict.  The simple fact remains 
that First Street was not prevented from competing for the award; its 
BAFO was fully considered.[5]

Finally, First Street alleges that the agency improperly engaged in 
post-BAFO discussions with Arizona.  First Street alleges that since 
the requirement for rentable square feet listed in the lease contract 
(60,246 square feet) was lower than the amount listed in Arizona's 
BAFO (63,126), the agency must have held discussions with Arizona to 
effect this change.  The protester also speculates that the decrease 
in rentable square footage would result in a reduction in the 
occupiable square footage below the minimum required by the SFO and 
argues its own offer might have received a higher technical score if 
it had been evaluated under the "changed" requirement.  

In response, the agency states that it held no post-BAFO discussions.  
Subsequent to the submission of BAFOs, the Bureau of Indian Affairs 
reduced its request for space, based on a reduction in its needs.  
However, because the new space requirement did not differ 
significantly from the requirement specified in the SFO, the 
contracting officer did not amend the solicitation but simply 
presented Arizona with a lease contract for 60,246 square feet, which 
Arizona accepted.  

While generally the government must issue a written amendment to 
notify all offerors of changed requirements in order to afford them an 
opportunity to respond to the revised requirements, see Diversified 
Computer Consultants, B-230313; B-230313.2, July 5, 1988, 88-2 CPD  para.  
5, we will only sustain a protest of the agency's failure to issue a 
written amendment notifying offerors of a change in requirements where 
this change affected the selection decision or was otherwise 
prejudicial to the protester.  FKW Inc. Sys.; ColeJon Mechanical 
Corp., B-235989; B-235989.2,
Oct. 23, 1989, 89-2 CPD  para.  370.  Here, the SFO described the required 
space as approximately 60,546 rentable square feet, yielding between 
54,492 and 57,216 occupiable square feet.  The lease contract shows 
60,246 rentable square feet--which is consistent with the 
"approximately 60,546" square feet required by the SFO--and in fact 
provided 55,116 occupiable square feet.  This occupiable square 
footage is within the range specified in the SFO.  In these 
circumstances, we fail to see how the modification constituted a 
"change" that required amending the solicitation, and we find no 
support for the suggestion that the protester was prejudiced by this 
modification.  

The protest is denied.

Comptroller General 
of the United States 

1. The SFO explained that "rentable space" is the area for which a 
tenant is charged rent, and may include a share of the building's 
common areas, such as lobbies and corridors, etc., while "occupiable 
space" includes only the portion of rentable space that is available 
for the tenant's personnel, equipment, and furnishings.

2. The record shows that, notwithstanding the SSP, prices were not 
scored so there was no opportunity to add "price" points based on 
building class.

3. The record shows that during a recent inspection by GSA, First 
Street's building was found to be in "sub-standard condition," and 
generally was considered to present an "unacceptable working 
environment" requiring a renovation of the space.  Further detail also 
is provided showing reports of ceiling tiles that are broken, stained 
or missing; carpet that was badly worn, stained and visibly dirty; 
stained or dirty walls; tile floors that were dirty; restroom fixtures 
in poor and unsightly condition; unacceptable electrical and 
communication distribution systems, in addition to the building's 
failure to meet the SFO's requirement for windows in all of the office 
bays.

4. First Street argues that the selection decision was flawed because, 
consistent with the solicitation, the comparison of its price and 
Arizona's price should have been based on the entire 10-year potential 
term of the lease, rather than on the 5-year firm period.  While the 
protester is correct that the SFO called for the evaluation and 
selection to be based on consideration of the full 10-year potential 
lease term, First Street's argument ignores the fact that neither 
firm's unit price varied over the 10-year term and thus the price 
delta would be the same percentage no matter how long the term of the 
lease.

5. First Street does not argue that it would have offered a different 
space or would otherwise have revised the aspects of its offer that 
earned its low technical score if it had been given additional time to 
prepare its BAFO.