BNUMBER:  B-274944.2
DATE:  February 25, 1997
TITLE:  Dynalantic Corporation

**********************************************************************

DOCUMENT FOR PUBLIC RELEASE
A protected decision was issued on the date below and was subject to a 
GAO Protective Order.  This version has been redacted or approved by 
the parties involved for public release.
Matter of:Dynalantic Corporation

File:     B-274944.2

Date:February 25, 1997

John S. Pachter, Esq., Jonathan D. Shaffer, Esq., and Christina M. 
Pirrello, Esq., Smith, Pachter, McWhorter & D'Ambrosio, P.L.C., for 
the protester.
Thomas A. Eff, Esq., for Marine Safety International, the intervenor.
Brian F. Zeck, Esq., Kathy B. Cowley, Esq., and Eric A. Lile, Esq., 
Department of the Navy, for the agency.
Behn Miller, Esq., and Christine S. Melody, Esq., Office of the 
General Counsel, GAO, participated in the preparation of the decision.

DIGEST

Exclusion of proposal from the competitive range without discussions, 
thereby leaving a competitive range of one, is not reasonable where:  
(1) the deficiencies cited are minor in relation to the scope of work 
and the revisions necessary to correct them; and (2) excluded 
offeror's price is [deleted] million lower than sole remaining 
offeror's.

DECISION

Dynalantic Corporation protests the award of a contract to Marine 
Safety International (MSI) under request for proposals (RFP) No. 
N00600-96-R-0749, issued by the Department of the Navy for ship 
handling simulation services.  Dynalantic contends that it was 
improperly excluded from the competitive range without discussions 
based on an unreasonable technical evaluation.

We sustain the protest.

BACKGROUND

The RFP was issued on February 7, 1996 and contemplated the award of 
an indefinite-quantity fixed-price contract for a base year and 9 
option years to the offeror whose proposal provided the best value to 
the government.  The solicitation required offerors to submit 
technical proposals organized according to the following technical 
evaluation factors, which were listed in the RFP in descending order 
of importance:  Technical Approach; Personnel; and Management Plan.[1]  
According to the RFP's statement of work (SOW), offerors were to 
construct a facility to house the ship handling simulator complex; 
install and configure the simulator equipment and training stations; 
provide all personnel and technical services necessary to run the ship 
handling simulator complex for a period of up to 10 years; and remove 
the complex at the conclusion of contract performance.

For their price proposals, offerors were directed to complete and 
submit the fixed-price schedule set forth at section B, which required 
unit prices for estimated quantities of 3,360, 4,300, and 5,000 hours 
per contract year.  In this regard, the pricing schedule required 
offerors to propose one comprehensive hourly rate for performing any 
hour of required service.  Cost or price was approximately equal in  
importance to the combination of all other evaluation factors.

Several amendments were issued, and a pre-proposal conference and site 
visit were conducted on February 23, 1996.  By the May 23 closing 
date, two offers were received--from Dynalantic and MSI.  On June 11, 
a  three-member technical evaluation panel (TEP) completed its 
evaluation of the offerors' technical proposals and forwarded a 
consensus evaluation to the contract specialist--who was the cognizant 
contracting official for this procurement--which rated Dynalantic's 
and MSI's proposals as follows:

        Factor           Dynalantic           MSI

     Technical Approach  Unacceptable   Outstanding
     
     Personnel           Better         Outstanding

     Management Plan     Unacceptable   Outstanding

     Overall Rating      Unacceptable   Outstanding

The contract specialist briefly reviewed Dynalantic's submitted 
pricing schedule and determined that Dynalantic's proposed pricing 
exceeded the Navy's available funding; Dynalantic had proposed a total 
price of approximately [deleted] million.  Based on the TEP's 
"unacceptable" rating, the contract specialist excluded Dynalantic's 
proposal from the competitive range, leaving MSI as the sole 
competitor.

MSI's proposed pricing strategy also exceeded the Navy's available 
funding; MSI had proposed a total price of approximately [deleted] 
million.  Consequently, the contract specialist conducted several 
rounds of discussions with MSI--which ultimately resulted in the 
agency's reducing the minimum hours required by the solicitation.  On 
September 19, the Navy awarded the contract to MSI for approximately 
[deleted] million.  On October 1, pursuant to Federal Acquisition 
Regulation (FAR)  sec.  15.1004, the Navy provided a debriefing to 
Dynalantic.  On October 7, Dynalantic filed this protest; contract 
performance has been continued by the Navy under a "best interest" 
justification.  31 U.S.C.  sec.  3553(d)(3)(C)(i)(I) (1994).

PARTIES' POSITIONS

The RFP set forth a five-tier adjectival scoring system which was to 
be used to evaluate offerors' technical proposals:  Outstanding, 
Better, Acceptable, Marginal, and Unacceptable.  Of significance to 
this protest, the RFP specified use of the  "unacceptable" rating 
where:

     "the offeror's technical proposal has many deficiencies and/or 
     gross omissions:  Failure to understand much of the scope of work 
     necessary to perform the required tasks; failure to provide a 
     reasonable, logical approach to fulfilling much of the 
     [g]overnment's requirements; failure to meet many personnel 
     requirements of the solicitation.  (When applying this adjective 
     to the technical proposal as a whole, the technical proposal must 
     be so unacceptable that it would have to be completely revised to 
     attempt to make it other than unacceptable.)"  (Emphasis added.)  

The Navy has identified several alleged deficiencies that it argues 
would require a major revision of Dynalantic's technical proposal in 
order to make the proposal marginally acceptable.  According to the 
Navy, "gross omission of information on building and grounds"; the 
protester's proposed use of an "excessive" quality control panel; and 
the failure to propose adequate staffing warranted rating Dynalantic's 
proposal technically unacceptable.

Dynalantic contends that the deficiencies cited by the Navy were 
either patently unreasonable or minor and correctable.  In light of 
the Navy's evaluated strengths in Dynalantic's proposal--including 
"state of the art technology," "more realism than required," "Better" 
personnel, and a "strong start-up team"--Dynalantic argues that its 
proposal was sufficiently meritorious to be included in the 
competitive range, and that the Navy could have realized potential 
savings of approximately [deleted] million by holding discussions with 
the protester.

ANALYSIS

The Competition in Contracting Act (CICA) of 1984 requires that if an 
agency conducts discussions, it do so with all responsible offerors 
whose offers are in the competitive range.  10 U.S.C.  sec.  
2305(b)(4)(A)(i) (1994).  The FAR provides that the competitive range 
must include all proposals that have a reasonable chance of being 
selected for award and that any doubt as to whether a proposal is in 
the competitive range should be resolved by inclusion.  FAR  sec.  
15.609(a) (FAC 90-31).

There is a tension between the necessarily broad discretion of an 
agency, acting through the contract specialist, to determine what 
proposals are realistically competitive, and the mandate of the FAR 
that, when there is doubt, the questionable proposal should be 
included.  The question posed by the FAR, consistent with the full and 
open competition requirement of CICA, is not whether a reasonable 
contract specialist might under the circumstances prefer a competitive 
range of one, but whether the excluded competitors have a reasonable 
chance of being selected after the opportunity for improvement.  Birch 
& Davis Int'l, Inc. v. Christopher, 4 F.3d 970, 973-974 (Fed. Cir. 
1993).

The determination of whether a proposal is in the competitive range is 
principally a matter within the reasonable exercise of discretion of 
the procuring agency and in considering an agency's evaluation of 
proposals and subsequent competitive range determination we will not 
evaluate the proposals anew in order to make our own determinations as 
to their acceptability or relative merits.  Beneco Enterprises, Inc., 
70 Comp. Gen. 574 (1991), 91-1 CPD  para.  595.  However, we will examine 
the record to determine whether the agency's evaluation was fair, 
reasonable and consistent with the evaluation criteria, and in 
particular, consider whether the documentation and analysis supporting 
the agency's technical conclusions are supported and rationally 
related to the stated evaluation factors, as required by FAR  sec.  
15.612(d)(2) (FAC 90-32).  Programmatics, Inc.; Telesynetics Corp., 
B-228916.2; B-228916.3, Jan. 14, 1988, 88-1 CPD  para.  35.

In this case, as explained below, we find that Dynalantic's proposal 
was unreasonably evaluated as unacceptable, and further conclude that 
Dynalantic's proposal was improperly excluded from the competitive 
range.

Facility Deficiencies

As noted above, the RFP required offerors to construct the facility 
which would house the ship handling simulator training stations.  The 
ship handling simulator complex was to be designed with a "Blue Side" 
and "Gold Side"; each side was required to house a ship handling 
simulator training station comprised of a full mission bridge 
simulator (360 degree visual display), radar room and bridge wing 
simulator (225 degree visual display), and two 12-person learning 
feedback centers.  Each learning feedback center was to be used on a 
stand-alone basis with its adjacent simulator or, by means of 
removable wall panels, configured with the other learning feedback 
centers into a large auditorium space.  The solicitation also required 
each simulator's computer operator station to be located in the 
associated learning feedback center.

Despite high evaluation ratings for most of Dynalantic's proposed 
equipment,[2] the TEP concluded that Dynalantic's proposal was 
unacceptable under the Technical Approach factor because of "gross 
omissions" regarding Dynalantic's proposed facility.  In this regard, 
for the facility portion of the proposal--which was to be included in 
the Technical Approach discussion--the solicitation directed offerors 
to include a "[b]uilding picture/drawing/rendering, description and 
plan, and work intended on surroundings, including walkways, planted 
areas (if any) and parking area."

According to the TEP, Dynalantic's proposal failed to provide 
"adequate information or description to evaluate" its proposed 
facility; the TEP reported that because of these deficiencies, the TEP 
was unable to evaluate the facility's "utility within the context of 
exterior appearance."  The TEP stated that the only illustration of 
Dynalantic's proposed building--a 1-inch by 3-inch rectangular 
picture--was blurry, and indicated the use of a red color on the 
building exterior that intensified the Navy's aesthetic concerns about 
the facility's appearance.

The TEP also reported that based on Dynalantic's use of the term 
"renovation" in one of its construction schedules, the TEP concluded 
that Dynalantic misunderstood the facility requirement--and that the 
construction schedule's references to "renovation" indicated the 
contractor's intent to renovate an existing government building, 
instead of constructing a new building as required by the RFP.  
Finally, because Dynalantic's facility diagram depicted [deleted] and 
did not otherwise show removable panels--or the location of the 
computer operator stations--the TEP determined that Dynalantic's 
facility description was grossly deficient.

The TEP's conclusions regarding Dynalantic's proposed facility are not 
supported by the record.  First, despite the TEP's claims of 
inadequate detail, our review of Dynalantic's proposal shows 
approximately 11 pages of facility information including:  a 
dimensional "plan view" and "elevation view" of both the full mission 
bridge simulator and bridge wing simulator; a diagram of the ship 
handling simulator complex layout; two detailed construction 
schedules; and a small computer-generated picture of the proposed 
entrance to its facility--indicating a red brick rectangular building 
with five window fronts, parking spaces, and basic landscaping.  
Dynalantic's proposal also includes several paragraphs of narrative 
description, indicating that Dynalantic will subcontract the actual 
construction portion to an experienced local government contractor, 
and that:

     "The building for [the Navy's Ship Handling Complex] will be 
     erected on the site provided by the government, located on the 
     Naval Station, Norfolk, Virginia, at the Surface Ship and 
     Submarine Pier area off Hampton Blvd.  Dynalantic will, at its 
     own expense, design, erect, provide, maintain and be responsible 
     for the building, utilities, ship handling simulator systems, 
     grounds immediately surrounding and made available for the 
     complex, and parking areas."

Although the Navy correctly points out that Dynalantic's proposal did 
not include certified architectural renditions of its proposed 
facility or a schematic layout of the facility's landscaping and 
parking area, the RFP did not require this level of detail.  In this 
regard, the Navy concedes that the technical focus of this requirement 
is for simulator equipment and support services.  Moreover, the Navy 
admits that the required facility construction does "not pose a 
significant challenge"; in fact, the RFP specifically described "a 
steel pre-fabricated building, on a concrete slab, sheathed with an 
aesthetic siding" as an example of a suitable facility for this 
effort.

A review of Dynalantic's construction schedule confirms that this is 
exactly what the protester proposed.  While the TEP contends that 
Dynalantic's use of the term "renovation" called into question the 
contractor's understanding of the requirement, we think the only 
reasonable interpretation of the "renovation" reference--taken in 
context with the proposal narrative--is that Dynalantic would 
configure the interior of the facility constructed by its 
subcontractor to accommodate its proposed simulator complex layout.  
Although Dynalantic's facility diagram does not depict removable 
panels or the computer operator station locations, as pointed out by 
Dynalantic, its proposal narrative specifically states that its 
learning centers "[c]an be opened such that all four combined serve as 
[an] auditorium" and that each computer operator station "is located 
in a learning feedback center."[3]  In this regard, although the TEP 
downgraded the protester's proposal for [deleted].

Given the amount of facility detail set forth in Dynalantic's 
proposal, we think the Navy's reliance on the protester's "blurry" 
picture as a basis for downgrading Dynalantic to an unacceptable 
rating is unreasonable.  To the extent the TEP downgraded Dynalantic's 
proposed facility based on the picture's depiction of a "red" 
exterior, we find this unreasonable because the RFP specifically 
required the simulator complex facility to convey a "primarily red 
brick appearance."  In sum, we find no basis in the record to support 
the TEP's conclusion that Dynalantic's proposal contained "gross 
omissions" regarding its proposed facility.

Based on the TEP's facility evaluation, the TEP determined that 
Dynalantic did not understand this requirement, and therefore 
evaluated the protester's proposal as unacceptable under the Technical 
Approach factor.[4]  We find this conclusion unreasonable.  First, as 
discussed above, it appears from the record that Dynalantic's drawings 
and descriptive narrative regarding its proposed facility were more 
than sufficient to convey Dynalantic's intent to construct a 
20,000-square foot red exterior prefabricated rectangular building as 
well as its proposed configuration of the simulator training complex.  
Clearly, as indicated above, Dynalantic understood that it was to 
build and configure the ship handling simulator complex facility; to 
the extent the TEP desired additional detail such [deleted] this could 
have been readily requested and provided in discussions.

The record also shows that the TEP awarded high technical ratings for 
most of Dynalantic's proposed simulator equipment, and that the TEP 
described Dynalantic's proposed image generator and related simulator 
equipment items as "exceeding" the RFP's technical requirements, and 
providing "more realism than required."  At the hearing on the 
protest, the TEP chairman testified that Dynalantic clearly understood 
the installation, technology, and operation of the simulator training 
equipment.  Under these circumstances, we agree with Dynalantic that 
for the Technical Approach factor its proposal should have been rated 
at least "marginally acceptable."

Management/Staffing Deficiencies

The RFP required offerors to propose enough personnel to provide at 
least four simultaneous 20-hour ship handling simulator training 
sessions per week and to provide an organization plan ensuring quality 
management and monitoring of the overall ship handling simulator 
training mission.  Based on two deficiencies in the "Management and 
Staffing Plan" section of Dynalantic's technical proposal, the TEP 
found Dynalantic's proposal unacceptable under the Management Plan 
evaluation factor.

First, the TEP questioned whether Dynalantic intended to provide four 
full-time facilitators--who were required by the RFP in order to offer 
four simultaneous 20-hour training sessions per week.  Although 
Dynalantic's proposal included resumes and full-time employment 
commitments for four facilitators, identified these personnel as 
"compris[ing] the full time instructional staff" at the complex, and 
stated that "facilitator/instructors will be scheduled as needed to 
satisfy the custom ship visit plan," Dynalantic's proposal also 
described its full-time staff as including "two facilitators."  The 
TEP also determined Dynalantic's proposal was unacceptably deficient 
under the Management Plan evaluation factor because the TEP concluded 
that Dynalantic had proposed "[e]xcessive procedures related to 
quality control" which imposed "unacceptable subjective evaluation by 
non-Navy personnel."

In its protest, Dynalantic does not dispute the TEP's concerns 
regarding its proposed management plan.  Dynalantic admits that it 
stated, inadvertently, that its staff included "two" full-time 
facilitators instead of the requisite "four," and  concedes that the 
TEP may have misunderstood the purpose of its proposed quality control 
team--which was offered as an additional set of personnel, to be used 
in addition to the key facilitators and personnel running the 
simulator complex.

Instead, the basis for Dynalantic's challenge to the TEP's Management 
Proposal evaluation lies in its disagreement with the weight the TEP 
gave the above-referenced deficiencies.  Dynalantic argues that the 
identified deficiencies are akin to informational deficiencies which 
could have been clarified easily without a major revision to its 
proposal, and, consequently, the Management Approach section of its 
proposal should have been rated "marginal" instead of unacceptable.  
We agree.

As argued by Dynalantic, simply changing one word in its 
proposal---e.g., replacing the word "two" with the word "four"--would 
have eliminated any ambiguity regarding Dynalantic's full-time 
facilitator staffing intentions.  As noted above, Dynalantic's 
proposal included resumes for four facilitators; under the Personnel 
factor, one facilitator received an "outstanding" rating, one 
facilitator was evaluated as "better," and the remaining two 
facilitators were rated "acceptable."  Even if we conclude (as urged 
by the TEP chairman) that Dynalantic either "misunderstood" the Navy's 
requirement for four full-time facilitators, or otherwise proposed an 
unacceptable technical solution of two full-time facilitators, given 
Dynalantic's inclusion of four facilitator resumes and corresponding 
employment commitments in its proposal, we think that any ambiguity in 
this area could have been remedied without a substantial proposal 
rewrite.

With respect to Dynalantic's proposed quality control team, we think 
the TEP's conclusion that this "deficiency" constituted a fatal flaw 
in Dynalantic's proposed Management Approach is similarly 
unreasonable.  First, contrary to the TEP's conclusion, Dynalantic did 
not propose a "non-Navy" panel; the protester's proposal specifically 
stated that its "Quality Action Team" (QAT) would include and be 
composed of "invited representatives" from "NAVSURFLANT [the requiring 
Navy activity for this procurement]."

In its proposal, Dynalantic described its QAT in part by stating that 
"Dynalantic ha[d] priced their [ship handling complex] services to the 
Navy based on some 5,000 man-hours devoted to monitoring, enforcing, 
and improving the quality of the shiphandling [sic] training."  The 
TEP chairman testified that in addition to concerns about a non-Navy 
panel overseeing the Navy's training performance, the agency did not 
want to bear the expense of Dynalantic's proposed QAT.  These concerns 
could have been readily addressed and corrected through discussions.

First, despite the TEP's interpretation to the contrary, our review of 
Dynalantic's proposal supports the protester's contention that its 
proposed QAT was not intended to "critique" the Navy's ship officers 
or impose a burden on Navy personnel, but rather was intended to 
provide a secondary support staff whose sole task would be to "provide 
follow-up and ensure the Navy's full satisfaction" with the simulator 
training complex and Dynalantic's key personnel (e.g., the 
facilitators) and technical support.  The record shows that the 
[deleted].

In any event, the solicitation did not specifically require 
contractors to propose a quality control team; instead, the RFP simply 
required offerors to include "the proposed lines of responsibility, 
authority, and communication through which the task will be managed, 
and the procedure to be taken to insure quality control and cost 
control."  Since Dynalantic's proposal otherwise explained its project 
organization and staffing approach,[5] since its proposed support team 
was rated "Better" by the TEP, and since a specific quality control 
team was not required, we think Dynalantic reasonably could have 
alleviated the TEP's concerns without a substantial proposal 
rewrite--for example, [deleted].  In sum, we agree with the protester 
that the facilitator and QAT deficiencies did not reasonably warrant 
the "unacceptable" rating awarded by the TEP for the Management Plan 
factor.

Totality of Marginal Deficiencies

In addition to the "unacceptable" deficiencies discussed above, the 
Navy identified several other areas of Dynalantic's proposal which it 
evaluated as "marginal."  The Navy argues that even if we determine 
that the above-referenced Technical Approach and Management Plan 
deficiencies should have resulted in a rating of "marginal" instead of 
"unacceptable" under those factors, the totality of the "marginal" 
deficiencies in Dynalantic's proposal--combined with the deficiencies 
discussed above--renders the protester's proposal technically 
unacceptable and warrants its exclusion from the competitive range.  
Relying on our decision in Rice Servs., Ltd., 68 Comp. Gen. 112 
(1988), 88-2 CPD  para.  514, the Navy argues that collectively considered 
the "marginal" deficiencies in Dynalantic's proposal require a 
complete rewrite of its proposal and render the protester's proposal 
essentially noncompetitive with MSI's--which was properly rated 
outstanding.

We do not find Rice Servs., Ltd., to be controlling. Rice, in which we  
held that an offer's exclusion was proper, involved major as well as 
marginal deficiencies; here we are concerned with only marginal 
deficiencies which can be easily remedied.  

For example, as discussed above, in light of the submitted facilitator 
resumes and narrative content indicating four full-time facilitators 
were available to perform, Dynalantic should be able to readily remedy 
the Navy's concerns about its proposal's statement indicating that 
only "two" full-time facilitators were proposed.  In this regard, at 
the hearing, the TEP chairman's testimony showed that most of the 
TEP's evaluated "marginal" deficiencies in Dynalantic's proposal 
resulted from descriptive errors--e.g., omitting the term 
"photographic" in promising a compliant bow-image visual subsystem; 
omitting the term "21 ships" in identifying the proposed ship data 
base; providing the exact name of the identified host computer--which, 
when considered in the context of the TEP's simulator equipment 
evaluation determining that Dynalantic had offered "state of the art 
technology" and equipment which significantly "exceeds" almost all of 
the RFP's technical specifications, should be correctable with minimum 
government discussions and revisions by the contractor.  

Regarding the remaining two deficiencies which arguably require 
substantive changes in the contractor's technical 
approach--Dynalantic's proposed full bridge simulator vertical field 
of view (VFOV) and tide database program--the record provides no basis 
for concluding that a substantial proposal rewrite is required for 
either deficiency.  At the hearing, the TEP chairman testified that 
although Dynalantic's VFOV capability for its proposed full mission 
bridge simulator was evaluated as "marginal" based on the protester's 
offering of a 33-degree VFOV rather than the required 36-degree VFOV, 
this marginal deficiency "wouldn't be a big deal to fix."  With regard 
to the full bridge simulator tide database deficiency, we simply note 
that this specification affects only 1 of 12 required databases for 
the full bridge simulator--and compared with the totality of the other 
"marginal" deficiencies, does not by itself constitute a basis for 
concluding that a substantial proposal rewrite would be required.

In sum, although the TEP rated many aspects of Dynalantic's technical 
proposal as "marginal," as discussed above, the record provides no 
basis for concluding that the totality of these "marginal" 
deficiencies renders Dynalantic's proposal noncompetitive.  In this 
regard, at the hearing, the contract specialist testified that if 
Dynalantic's proposal had received a "marginal" rating for each 
evaluation factor, he would have included the proposal in the 
competitive range and conducted discussions.[6]  Since we think it is 
clear from the record that Dynalantic's proposal could be made 
"acceptable" without a substantial rewrite, and since Dynalantic's 
offered price was [deleted] million lower than the [deleted] million 
price offered by MSI, in light of the relative importance of price, we 
think Dynalantic's proposal as a whole could not properly be viewed as 
having no reasonable chance for award.[7]  Under these circumstances, 
we conclude that the exclusion of Dynalantic's proposal from the 
competitive range was improper.  See 47 Comp. Gen. 29 (1967) (even 
though sole remaining offeror was technically superior, exclusion of 
protester from competitive range without discussions was improper 
since protester's offered price was $60 million lower than its 
competitor's); Falcon Sys., Inc., B-213661, June 22, 1984, 84-1 CPD  para.  
658 (elimination of proposal from the competitive range, thereby 
leaving a competitive range of one, is improper where informational 
deficiencies were not so material that major revisions would have been 
required to make proposal acceptable).

In reaching this conclusion, we note that this case is distinguishable 
from those situations where the record makes it clear that, despite 
being technically acceptable,  the excluded proposal had no reasonable 
chance for award when compared to another technically superior offer.  
See, e.g., Agriculture Technology Partners, B-272978; B-272978.2, Dec. 
5, 1996, 96-2 CPD  para.  226.  Unlike those cases, here the Navy does not 
argue that Dynalantic lacked any reasonable chance for award.  In 
fact, as confirmed by the contracting officer's hearing testimony, the 
Navy recognizes that the potential for the protester's proposal to 
become technically acceptable after minimal discussions warrants 
retaining Dynalantic's proposal in the competitive range.

Navy's Destruction of Individual Evaluators' Notes and Worksheets

The record shows that in accordance with its source selection plan, 
the Navy destroyed the TEP members' individual evaluation notes and 
worksheets.  In its protest, Dynalantic urges our Office to sustain 
its challenge to the Navy's destruction of documents; Dynalantic 
contends that the Navy's practice violates FAR  sec.  15.608(a)(3) (FAC 
90-31), which requires the contracting agency to document its 
technical evaluation, and  sec.  15.612(d)(1) (FAC 90-32), which requires 
the source selection official to consider "any rankings and ratings."

Our Office has criticized the Navy for its document destruction 
practices.  See Dimensions Int'l/QSOFT, Inc., B-270966; B-270966.2, 
May 28, 1996, 96-1 CPD  para.  257; Southwest Marine, Inc.; American Sys. 
Eng'g Corp., B-265865.3; B-265865.4, Jan. 23, 1996, 96-1 CPD  para.  56.  
However, we recognize that evaluators' individual notes and worksheets 
may or may not be necessary to determine the reasonableness of the 
agency's evaluation.  Dimensions Int'l/QSOFT, Inc., supra; Southwest 
Marine, Inc; American Sys. Eng'g. Corp., supra.

In this case, the TEP's consensus evaluation--and the subsequent 
hearing--provided an adequate record for our review.  Consequently, 
since our Office was fully able to review and examine the TEP's 
evaluation, we have no basis for sustaining Dynalantic's protest based 
on the agency's destruction of the individual evaluators' notes and 
worksheets.  However, we think it is appropriate to emphasize that had 
the Navy not destroyed these documents, the requirement for oral 
testimony--and the resulting costs to be paid as part of our 
recommended corrective action--may well have been avoided.[8]

RECOMMENDATION

As discussed above, we think the TEP's evaluation was unreasonable, 
and improperly deprived Dynalantic of a meaningful opportunity to 
compete by resulting in the exclusion of Dynalantic's proposal from 
the competitive range.  Consequently, we sustain the protest.

In view of our findings above, we recommend that discussions be held 
with Dynalantic.  Best and final offers should be solicited from both 
competitors and evaluated by a new TEP.[9]  In the event that 
Dynalantic is selected for contract award of the remainder of the 
requirement, MSI's contract should be terminated.[10]

Since we sustain the protest, we also recommend that Dynalantic 
recover its costs of filing and pursuing its protest, including 
reasonable attorneys' and consultant fees.  Bid Protest Regulations,  sec.  
21.8(d)(1), 61 Fed. Reg. 39039, 39046 (1996) (to be codified at 4 
C.F.R.  sec.  21.8(d)(1)).  The protester should submit its certified claim 
for such costs, detailing the time expended and costs incurred, 
directly to the agency within 60 days after receipt of this decision.  
Bid Protest Regulations,  sec.  21.8(f)(1), 61 Fed. Reg., supra (to be 
codified at 4 C.F.R.  sec.  21.8(f)(1)).

The protest is sustained.

Comptroller General
of the United States

1. A past performance proposal, not at issue in this protest, was also 
required.

2. Each simulator was to be equipped with the following principal 
subsystems:  a pilot house; ship controls, displays and 
communications; radar simulation; and a visual subsystem. 

3. Dynalantic's proposal included three separate references which 
stated that the computer operator stations were located in the 
learning feedback centers.

4. The SOW required the simulators to be equipped with pre-existing 
ship handling programs, but to be also capable of accommodating 
individual training programs written by ship commanders for unique 
training needs.  The TEP's evaluation shows that it concluded 
Dynalantic misunderstood the trainer mission because its proposal did 
not convey Dynalantic's understanding that the commanding officer may 
choose to write his own training program.  This conclusion is 
completely unsupported by the record; for example, Dynalantic's 
proposal specifically acknowledges that simulator "flexibility is most 
important for ship directed training under the specific direction of 
the ship [commanding officer]" and that "in cases where the 
[commanding officer] elects not to use the [c]ontractor's curriculum, 
the [commanding officer] will be furnished a guide to using the 
training resources of the [complex]."

5. The record shows that the TEP downgraded Dynalantic for omitting a 
"Figure 3-2" staffing diagram.  At the hearing, the TEP chairman 
testified that despite this deficiency, it was able to identify 
Dynalantic's staffing approach.  In this regard, Dynalantic proposed 
several points of contact between the Navy and its simulator training 
personnel; the primary point of contact--for overseeing the Navy's 
needs and ensuring quality control--was Dynalantic's proposed Director 
of Training.

6. In his competitive range determination document, the contract 
specialist wrote that Dynalantic's pricing schedule appeared 
[deleted].  At the hearing, the contract specialist explained that 
this description simply referred to an assessment of Dynalantic's 
pricing approach [deleted] and that the reference to Dynalantic's 
pricing in no way constituted a negative assessment.  The contract 
specialist confirmed the Navy's repeated representations that price 
did not factor into the agency's decision to exclude Dynalantic's 
proposal from the competitive range; specifically, the contract 
specialist testified that the sole basis for Dynalantic's exclusion 
was the TEP's determination that the protester's technical proposal 
was unacceptable.

7. The RFP provided that the "Government may elect to pay a price 
premium of up to approximately 35 percent to select an offeror whose 
non-cost price evaluation factors (e.g. technical and past 
performance, if included) are superior."  [Deleted].

8. The Navy has since reported that it will discontinue this practice.

9. Although we find no evidence of bad faith, we are nonetheless 
troubled by the quality of the TEP's evaluation; as discussed above, 
none of the TEP's cited deficiencies supports an "unacceptable" 
rating.  Under these circumstances, we agree with the protester that a 
new TEP should be convened.  See J. M. Cashman, Inc., B-233773, Apr. 
14, 1989, 89-1 CPD  para.  380.

10. We understand that the construction phase of the requirement is 
nearly complete.  However, the remaining simulator equipment 
installation and support services--the crux of this technical 
effort--have not been ordered.  At the hearing, the TEP chairman 
testified that Dynalantic's proposed simulator equipment could be 
installed in the facility constructed by MSI; the TEP chairman also 
testified that Dynalantic's personnel could easily operate and run 
MSI's proposed simulator equipment.