BNUMBER:  B-276877 
DATE:  July 30, 1997
TITLE: Leon D. DeMatteis Construction Corporation, B-276877, July
30, 1997
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Matter of:Leon D. DeMatteis Construction Corporation

File:     B-276877

Date:July 30, 1997

Joseph R. Harbeson, Esq., and Douglas A. Cooper, Esq., Cooper & 
Cooper, for the protester.
Scarlett D. Grose, Esq., and Emily C. Hewitt, Esq., General Services 
Administration, for the agency.
Tania L. Calhoun, Esq., and Christine S. Melody, Esq., Office of the 
General Counsel, GAO, participated in the preparation of the decision.

DIGEST

Protest that technical qualifications criteria in solicitation for 
construction of a new federal courthouse are unduly restrictive of 
competition is denied where the record shows that the criteria are 
reasonably related to the agency's need to ensure that the contractor 
will have sufficient experience in all aspects of the type of complex 
construction that will be necessary for the project; protester's 
arguments focusing on the individual elements of this experience, but 
ignoring the value of the totality of this experience, do not show 
that the criteria are unreasonably restrictive.

DECISION

Leon D. DeMatteis Construction Corporation protests the terms of 
request for proposals (RFP) No. GS-02P-97-DTC-0010(N), issued by the 
General Services Administration (GSA) for construction of Phase II of 
a new federal courthouse in Brooklyn, New York.  DeMatteis argues that 
the solicitation's technical qualifications criteria are unduly 
restrictive of competition.

We deny the protest.

The new courthouse, one of the largest in the country, will consist of 
an 18-story building housing the new courthouse proper as well as a 
6-story structure connecting the new courthouse to the existing 
courthouse on the same site.  The connecting structure will contain 
the main building entrance and an interior atrium, enabling the two 
buildings to function as one complex.[1]  The new courthouse will be 
approximately 742,734 gross square feet in size and its estimated 
construction cost is between $165 and $180 million.

The new courthouse will house 15 District and 10 Magistrate 
courtrooms, a jury assembly area, judges' chambers, office space for 
court and court-related agencies, a grille/cafe, a U.S. Court of 
Appeals library, and a secure prisoner circulation/
detention system.  The interiors of the courtrooms and judges' 
chambers will contain extensive architectural paneling and millwork, 
and the public spaces will contain a variety of finishes, including 
marble wall panels, travertine tile, and terrazzo flooring.

The building's mechanical systems will include a central chilled water 
refrigeration and boiler plant system containing central air handling 
units for floors 4-17 and local floor air handling units for the lower 
floors; a variable air volume distribution system with hot water 
reheat coils; three dual-fueled boilers and three direct-fired 
dual-fueled absorption chillers; a direct digital control building 
automation system; cast iron plumbing; a copper domestic water system; 
fuel oil and natural gas distribution systems; a fully-sprinkled fire 
protection system; electric service from new utility network vaults to 
four 460-volt service switch gear with ground fault protection; two 
diesel-driven 1,000-kilowatt paralleled emergency generators; and 
extensive conduit and electrical power to support a security system.  

Work under this contract will include site work, demolition, 
excavation, reinforced concrete foundations and structure, fireproof 
steel frame structure, metal decking, concrete floors, a curved entry 
structure clad in coated aluminum curtain wall, coated aluminum and 
glass curtain wall and limestone building facade, roofing, sealant and 
flashing, skylights, interior architectural woodwork and finishes, 
doors, frames and hardware, stairs, interior partitions, signage and 
graphics, elevators, mechanical, electrical, plumbing and fire 
suppression systems.  Related work will include site improvements, 
landscaping, distinctive pavement, and asphalt paving for roadways.

The solicitation was issued on April 4, 1997, as step one of a 
two-step procurement.  Under the first step, at issue here, offerors 
must submit technical proposals to be evaluated under two technical 
qualifications criteria--project experience and past performance, and 
qualifications of key personnel.  Proposals that fail to satisfy the 
minimum requirements of either criterion will be automatically 
eliminated from further consideration.  Proposals deemed technically 
acceptable under these criteria will enter the pricing phase of the 
procurement.  Award will be made to the offeror submitting the 
lowest-priced, technically acceptable proposal.

DeMatteis's protest focuses on the project experience and past 
performance criterion, which calls for experience demonstrating a 
firm's overall coordination and subcontracting responsibilities, 
including schedules and budgets.[2]  Specifically, the RFP requires 
that the offeror demonstrate that it has successfully completed a 
minimum of three projects in the role of a general or prime contractor 
within the past 10 years; each project must comply with the following 
subcriteria:

     a. Type of Facility:  Courthouse, Civic Building, Museum, 
        Library, Embassy, Hospital, Corporate Headquarters, or Office 
        Building (all complete with interiors).  All projects must be 
        new construction.  Modernization or alterations of existing 
        buildings are not acceptable.  
        Note:  At least one project must have been completed on a job 
        site with a limited working area.  The project/building 
        (excluding parking lots) must have occupied at least 75 
        percent of the total job site.

     b. Gross Square Footage:  Not less than 400,000 gross square 
        feet/each project

     c. Number of Stories:  Not less than 10 (above grade)/each 
        project

     d. Construction Contract Dollar Value:  Not less than 
        $100,000,000/each project.

On April 24, DeMatteis filed an agency-level protest in which it 
argued that these criteria, except for the square footage requirement, 
were unduly restrictive of competition; the firm's April 25 protest to 
this Office repeated this claim.  DeMatteis and several other firms 
submitted technical proposals by the May 6 closing date, but the 
procurement has been suspended pending resolution of this protest.

In preparing a solicitation for supplies or services, a contracting 
agency must specify its needs and solicit offers in a manner designed 
to obtain full and open competition and may include restrictive 
provisions or conditions only to the extent that they are necessary to 
satisfy the agency's needs.  41 U.S.C.  sec.  253a(a) (1994).  The 
determination of the agency's minimum needs and the best method of 
accommodating them is primarily within the agency's discretion.  
Premiere Vending, 73 Comp. Gen. 201, 206, 94-1 CPD  para.  380 at 7.  
Agencies enjoy broad discretion in the selection of evaluation 
criteria, and we will not object to the use of particular evaluation 
criteria or an evaluation scheme so long as the criteria used 
reasonably relate to the agency's minimum needs in choosing a 
contractor that will best serve the government's interests.  Id.; 
Renow, Inc., B-251055, Mar. 5, 1993, 93-1 CPD  para.  210 at 3. 

GSA explains that the project experience and past performance 
criterion is grounded in the agency's need to ensure that the general 
contractor chosen will have sufficient relevant experience in all 
aspects of the complex construction presented by this project.  For 
clarity of presentation and response by offerors, GSA divided the 
areas of experience required by this project into the RFP subcriteria 
set out above. 

GSA first considered the specific attributes of the courthouse and 
identified other types of buildings that contain similar attributes, 
such as extensive coordination of trades, various centralized systems, 
varying floor heights, mixed use, and a high level of finishes.  Since 
all of the building types listed in subcriterion (a) have these 
features in common, GSA considered that experience with any of these 
types would be representative of that required here.  In addition, 
since the task of coordinating construction increases in complexity as 
the number of stories increases, GSA decided to ensure that the 
contractor had experience with multi-story construction by imposing a 
10-story minimum requirement, reflected in subcriterion (c).  GSA also 
decided to ensure that the contractor had experience in constructing 
and allocating project funds for such a large project by imposing 
minimum size and dollar thresholds, set out in subcriteria (b) and 
(d).  GSA also limited acceptable projects to those completed within 
the past 10 years because building and construction methodology for 
large-scale multi-story projects has changed radically in the last 
decade.

Central to GSA's approach is that these subcriteria are not separate, 
free-standing requirements, but rather complementary parts of a 
single, unified criterion which represents all aspects of the relevant 
experience necessary for this project.  Since GSA will be asking the 
successful contractor to call upon all of this relevant experience on 
this one project, its underlying need is for a contractor who 
demonstrates relevant experience in all these aspects on each project.

DeMatteis does not address this critical underlying justification for 
the criterion.  Instead, the protester extracts specific aspects of 
the experience encompassed by these subcriteria and contends that it 
has demonstrated competence in each of these aspects under an array of 
projects that do not, individually, meet all of the subcriteria.  
Essentially, DeMatteis argues that an offeror's management competence 
demonstrated in this fashion would meet GSA's minimum needs.      

GSA asserts that an evaluation on this "mix and match" basis might 
demonstrate contractor experience in specific areas--such as 
specialized security systems or types of mechanical systems--but would 
yield little relevant information concerning a contractor's ability to 
manage and coordinate the entire project.  For example, the successful 
construction of a 10-story building which does not meet the other 
subcriteria requirements would show a contractor's knowledge of basic 
multi-story construction but would not demonstrate any knowledge of 
sophisticated, state-of-the-art building systems in the same building. 

This project requires the contractor to perform thousands of different 
tasks, all on this one project, and GSA seeks assurance that the 
contractor chosen has a track record of performing these thousands of 
different tasks all on one project.  GSA's disagreement with DeMatteis 
as to the validity of its claims of equivalent specific experience 
aside, the agency's larger concern is that the sum of this experience 
gained under a wide array of unrelated projects does not "add up" to 
the totality of this experience gained under one project--that the 
whole is, in fact, greater than the sum of its parts.  While DeMatteis 
rejects this underlying concern in favor of a limited focus on the 
individual elements of the required experience, it has not persuaded 
us that GSA's approach is unreasonably restrictive.

DeMatteis' specific challenges are unpersuasive for the same reason.  
DeMatteis takes particular issue with the exclusion of residential 
buildings from the "types of facility" subcriterion.  For example, the 
firm cites three multi-story residential buildings on which it claims 
experience--for one or more of the buildings--with such things as the 
coordination of numerous trades; centralized heating, ventilation, and 
air conditioning systems; a standard centralized security system; 
varying floor heights; and expensive finish work.  Setting aside the 
fact that all three of these buildings had construction costs well 
below $100 million,[3] there is no evidence that any one of these 
buildings has all of the specific attributes present in this project.  
This merely validates GSA's statement that it did not include 
residential buildings because they typically do not contain components 
and complexities similar to those which will be encountered here.[4]

As for DeMatteis' insistence that it and other competent contractors 
are being improperly excluded from competing here, the determinative 
consideration regarding the propriety of a challenged method of 
proposal evaluation is whether it reasonably relates to the 
government's minimum needs and not whether or not it works to the 
prejudice of one or another offeror.  120 Church St. Assocs., 
B-232139, Nov. 21, 1988, 88-2 CPD  para.  496 at 5.  Accordingly, given our 
conclusion that the experience criterion at issue here is reasonably 
related to GSA's minimum needs, the fact that DeMatteis or other 
contractors cannot meet the criterion does not demonstrate that it is 
improper. 

The protest is denied. 

Comptroller General
of the United States

1. The new courthouse will be built on the site presently occupied by 
the existing courthouse and a federal office building.  Under Phase I 
of the project, being performed under a separate contract, the federal 
office building and a structure connecting that building to the 
existing courthouse will be largely demolished.  The existing 
courthouse will remain in continuous operation throughout both phases 
of the project.

2. Since the protester's objections to the second criterion derive 
from its objections to the first, we need not address them separately.

3. While DeMatteis argues that the $100 million figure is arbitrary, 
we have no basis to conclude that GSA's desire to ensure that the 
contractor chosen is capable of allocating funds for such a large 
project is unreasonable, especially considering that the $100 million 
threshold is well below the estimated construction costs here.

4. DeMatteis does not dispute GSA's reasons for including the 
multi-story requirement or the 10-year limitation, but argues that its 
recent, similar experience in other types of buildings is sufficient.  
For the reasons stated above, we find this argument to be without 
merit.  DeMatteis raises no specific challenge to the minimum square 
footage subcriterion.