BNUMBER:  B-272529
DATE:  October 21, 1996
TITLE:  JWK International Corporation

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Matter of:JWK International Corporation

File:     B-272529

Date:October 21, 1996

Keith L. Baker, Esq., and Timi E. Nickerson, Esq., Eckert, Seamans, 
Cherin & Mellott, for the protester.
Christopher M. Bellomy, Esq., Department of the Navy, for the agency.
C. Douglas McArthur, Esq., and Christine S. Melody, Esq., Office of 
the General Counsel, GAO, participated in the preparation of the 
decision.

DIGEST

Protest by sixth low bidder that five lower bids are nonresponsive on 
ground that supplemental pricing information required to be submitted 
with bids indicates that bidders do not intend to furnish minimum 
staffing set out in invitation for bids (IFB) is denied where a 
reasonable reading of the IFB shows that at least one of the 
lower-priced bidder's proposed staffing is consistent with the 
staffing set out in IFB.

DECISION

JWK International Corporation protests the award of a contract under 
invitation for bids (IFB) No. N62467-95-B-1126, issued by the 
Department of the Navy, Naval Facilities Engineering Command, for base 
operations services at the agency's facility in McGregor, Texas.  The 
protester asserts that the five lower bids submitted in response to 
the IFB are nonresponsive because each bid contains evidence, on its 
face, that the bidder does not intend to comply with the IFB's 
statement of work.

We deny the protest.

The IFB, issued as a small business set-aside, called for award of a 
combination firm, fixed-price and indefinite quantity contract for 
operations and maintenance at the facility, for a 6-month base period 
with four 1-year options and a fifth, 6-month, option period.  
Contract line item numbers (CLIN) 0001, 0011, 0021, 0031, 0041, and 
0051 represented the fixed-price portion of the work for the base and 
option periods, which is at issue here.[1]  The solicitation provided 
for award to the low responsive, responsible bidder on CLINs 
0001-0060.

The last page of section B, the bid schedule, instructed bidders to 
provide certain supplemental pricing information "in order to 
facilitate the [g]overnment's evaluation of the Firm Fixed-Price 
portion."  Bidders had to break down their prices for CLIN 0011 (the 
fixed-price portion of the first full year of performance) into 14 
elements.  One of these elements was startup costs; the other elements 
corresponded to 13 "annexes" set out in section C of the IFB which 
describe the different kinds of work required under the IFB.  For each 
of the annexes, as well as startup costs, bidders were to provide 
estimates of labor years devoted to that portion of the work 
(expressed as "full-time equivalents" (FTE)), with the associated 
labor, material, and equipment costs.  The IFB advised bidders that 
the "grand total" for the 13 annexes and startup costs had to equal 
the amount bid for CLIN 0011.

Three of the annexes listed in section C of the IFB are relevant to 
the protest: annex 6 (fire protection services); annex 7 (water supply 
system operation and maintenance); and annex 11 (operation and 
maintenance of the electrical distribution system).

The agency received 11 bids; the protester's bid was sixth low.  JWK 
contends that the five lower-priced bids are nonresponsive, 
specifically asserting that the supplemental pricing information 
provided by the five bidders indicates that they do not intend to 
furnish the minimum staffing levels set out in annexes 6, 7, and 11 of 
the IFB.

A bid must be responsive to be considered for award, which means that 
the bid must be an offer to perform, without exception, the exact 
thing called for in the solicitation and, upon acceptance, will bind 
the contractor to perform in accordance with the material terms and 
conditions of the IFB.  Stay, Inc., B-237073, Dec. 22, 1989, 89-2 CPD  para.  
586.  Responsiveness is determined at the time of bid opening from the 
face of the bid documents.  B-G Mechanical Serv., Inc., B-265782, Dec. 
27, 1995, 96-1 CPD  para.  6.

Here, the agency disagrees with JWK's assertion that the staffing 
levels set out in the bidders' supplemental pricing information bear 
on the responsiveness of the bids.  Rather, the agency contends, it 
requested the supplemental pricing information solely for the purpose 
of evaluating price reasonableness and not for the purpose of judging 
conformance to the statement of work.  We need not resolve this issue 
since, even assuming that the IFB set out minimum staffing 
requirements as JWK contends, at least one of the low bidders proposed 
staffing sufficient to perform in accordance with those requirements.

With respect to annex 6, JWK argues that the required minimum staffing 
is 21 FTEs; the record shows that the fourth low bidder, LB&B 
Associates Inc., proposed 23 FTEs for annex 6.  Thus, even under JWK's 
interpretation of the annex 6 staffing levels, LB&B's bid is 
acceptable.

With respect to annex 11, paragraph C11.6e required the contractor to 
provide a duty electrician (to be available within 30 minutes of an 
emergency call) and paragraph C11.6f called for a chief of the watch 
(to be available on base 24 hours a day, 7 days a week).  JWK contends 
that this staffing translates into a minimum of 5.2 FTEs; LB&B's bid 
listed 1 FTE for annex 11.

We do not agree with the protester's calculations.  First, paragraph 
C6.4b(5) of the statement of work for annex 6 (fire protection 
services) specifically states that the dispatcher assigned to annex 6 
will serve as chief of the watch "for other annexes such as security, 
water, sewer, or electrical services."  Thus, the chief of the watch 
position in annex 11 is the same as the dispatcher position in annex 
6; there is no separate FTE required for this position under annex 11.  
Nor is there an FTE requirement for a duty electrician in annex 11, 
since the duty electrician is required to be "on call" rather than 
physically present for any specified period.[2]  

With regard to annex 7 (water supply system operation and 
maintenance), paragraph C7.6e set out the following staffing:  a 
maintenance supervisor (to be available for the "first shift," Monday 
to Friday); and a laboratory technician (to be available "as 
required").   An attachment to annex 7 (Technical Exhibit 7-2) refers 
to another position, an operator, with no required availability 
specified.  JWK interprets the IFB to require 12.6 FTEs for annex 7 
(three positions at 4.2 FTEs each); LB&B's bid indicated that 1 FTE 
would be furnished. 

While JWK argues that, based on Technical Exhibit 7-2, annex 7 should 
be interpreted as establishing minimum staffing of three positions (a 
maintenance supervisor; an operator; and a laboratory technician), the 
protester ignores the specific minimum staffing requirements set forth 
in paragraph C7.6e of the annex.  That paragraph, entitled Staffing, 
expressly states that the minimum staffing is a maintenance supervisor 
for the first shift, Monday through Friday, with a laboratory 
technician as needed; there is no mention, and no specified 
availability, for the third position ("operator") listed in the 
technical exhibit.  Thus, we think the statement of work, at most, 
establishes the minimum staffing as one FTE, the number listed in 
LB&B's bid. 

In sum, since LB&B's lower-priced bid offered the minimum staffing JWK 
asserts was required for annex 6, as well as adequate staffing under a 
reasonable interpretation of the requirements for annexes 7 and 11, we 
see no basis to conclude that the bid is nonresponsive even assuming, 
as JWK argues, that the IFB specified minimum required staffing 
levels.  In view of this conclusion, we will not consider JWK's 
challenge to the responsiveness of the other bids since JWK would not 
be in line for award even if its challenge to those bids were 
sustained.  See Bid Protest Regulations, 4 C.F.R.  sec.  21.0(a) (1996); 
ECS Composites, Inc., B-235849.2, Jan. 3, 1990, 90-1 CPD  para.  7.

The protest is denied.

Comptroller General
of the United States

1. CLINs 0002-0008, 0022-0028, 0032-0028, 0042-0048, and 0052-0058 
contained the agency's estimates for the indefinite quantity work.  
CLINs 0009, 0019, 0029, 0039, 0049, and 0059 and CLINs 0010, 0020, 
0030, 0040, 0050, and 0060 were for material and equipment to support 
the fixed-price work in the base and option periods.

2. In any event, the staffing listed by the low bidder---1 FTE---is 
consistent with JWK's staffing estimate for the duty electrician.