BNUMBER:  B-276923 
DATE:  July 16, 1997
TITLE: MCC Construction Corporation, B-276923, July 16, 1997
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Matter of:MCC Construction Corporation

File:     B-276923

Date:July 16, 1997

James J. Gonzales, Esq., Holland & Hart, L.L.P., for the protester.
Laurence Schor, Esq., and Susan L. Schor, Esq., McManus, Schor, Asmar 
& Darden, L.L.P., for Satellite Services, Inc., an intervenor.
Maj. Michael O'Farrell and Col. Nicholas P. Retson, Department of the 
Army, 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

Under invitation for bids where award was to be made to the bidder 
submitting the lowest coefficient percentage factor, protest that 
contracting agency improperly failed to evaluate bids in accordance 
with the solicitation by using the wrong multipliers is denied where 
the evaluation was conducting using the multipliers set forth in the 
solicitation; any alleged contradiction between solicitation 
provisions was apparent on the face of the solicitation and thus had 
to be protested prior to bid opening. 

DECISION

MCC Construction Corporation protests the award of a contract to 
Satellite Services, Inc. under invitation for bids (IFB) No. 
DAHA-44-97-B-0001, issued by the Virginia Army National Guard/U.S. 
Property and Fiscal Office for Virginia for maintenance, repair, or 
minor alterations at specified military bases.  MCC argues that the 
Army improperly failed to evaluate the bids in accordance with the 
solicitation's stated methodology.

We deny the protest.

The solicitation, conducted using two-step sealed bidding, anticipated 
the award of a multi-year, indefinite delivery/indefinite quantity 
fixed-price contract to provide these services to Virginia Air 
National Guard bases located at the 192d Wing, Sandston, Virginia; the 
Alert Facility located on Langley Air Force Base, Virginia; and the 
203d Redhorse Squadron at the State Military Reservation, Virginia 
Beach, Virginia.  Six firms, including MCC and Satellite, were deemed 
qualified to participate in the second stage of the procurement, at 
issue here.
 
Under the anticipated contract, the agency will issue delivery orders 
for projects to be performed at the three locations.  Prices for 
individual delivery orders will be established by multiplying the 
awardee's proposed coefficient percentage factors by the prices of the 
specified tasks as listed in the current edition of a standard unit 
pricing guide.[1]  Hence, rather than bids for fixed-dollar amounts, 
bidders were to provide separate coefficient percentage factors for 
each location's set of four line items, for a total of 12 factors.[2]  
The four line items listed under each location were for construction, 
repair, and maintenance projects during normal working hours; 
construction, repair, and maintenance projects during overtime hours; 
highway, water, and sewer line projects during normal working hours; 
and highway, water, and sewer line projects during overtime hours.[3] 

The solicitation's section C, paragraph 00100-3, "Statement of Work," 
stated:

     "Projects will vary in size and dollar amount. . . .  It is 
     anticipated that 90% of all work called for will be construction; 
     the remaining 10% will be highway/sewer projects.  Projects are 
     expected to be distributed as follows:

        85% Sandston     10% Virginia Beach  5% Langley"

Paragraph 00100-8 of that same section, "Percentage of Work," stated 
that the percentage of work at each base was "an estimate used for 
evaluation factors for purpose of award."

While the IFB stated that bids would be evaluated and award made in 
accordance with the sealed bidding provisions of the Federal 
Acquisition Regulation, it was not until a pre-bid opening conference 
that the agency clarified that the basis for award would be the lowest 
coefficient.  At that conference, the agency also stated that 
clarification was required as to how the agency would determine the 
lowest proposed coefficient, and that this issue would be addressed by 
amendment.

Amendment No. 0001, issued February 3, 1997, contained the following 
instructions (underscoring in the original):

     "2.The following clarification is made for the basis of award: 

        The basis for award will be lowest weighted coefficient as 
        described below . . . 

     "3.The lowest coefficient will be determined by weighing each 
        line item against the amount of work to be performed as 
        described in the Statement of Work.  The weighted average is 
        for evaluation purposes only and will not be incorporated into 
        any resulting contract.  For example:

     BIDDER #1

          DESCRIPTION         COEFFICIENT*   % OF WORK AVG

     0001 Construction at Sandston 1.06           85    .901
     0002 Overtime work at Sandston  .02          85    .017
     0005 Construction at Va Beach 1.10           10    .110
     0007 Highway Work at Va Beach 1.09           10    .109

        WEIGHTED COEFFICIENT BIDDER #1                 1.137

     BIDDER #2

     0001 Construction at Sandston 1.08           85     .918
     0002 Overtime at Sandston       .04          85     .034
     0005 Construction at Va Beach 1.15           10     .115
     0007 Highway Work at Va Beach 1.11           10     .111

        WEIGHTED COEFFICIENT BIDDER #2                 1.178

     "* Coefficient rates are for example purposes only and are not 
     intended to represent any anticipated figures.

     "Based on the above sample, Bidder #1 would be the apparent low 
     bid."

     "4.. . . Bids will be publicly opened and coefficients read 
        aloud; however, no apparent low bidder will be declared until 
        a complete evaluation is made using the above guidance."

On the February 11 bid opening date, the Army read aloud the 
coefficients proposed by each of the six bidders.  The record shows 
that the bids were evaluated in accordance with the example provided 
in the amendment.  That is, the coefficients were multiplied against 
the locational percentages listed in the statement of work.  Under 
this evaluation methodology, Satellite was determined to be the 
apparent low bidder, with a coefficient of 2.2616.  MCC was the 
apparent second low bidder, with a coefficient of 2.2910.

By letter dated February 24, MCC advised the agency that it had 
received telephone calls from Satellite indicating that that firm had 
won the contract.  MCC stated that it had been present at bid opening 
and had recorded the coefficients, and that its calculations showed it 
to be the apparent low bidder.  MCC continued:

     "On Amendment 0001, paragraph 3, . . . it states, 'The lowest 
     coefficient will be determined by weighing each line item against 
     the amount of work to be performed as described in the Statement 
     of Work.'  It then goes on to present an inaccurate example of 
     how to determine the lowest coefficient.

     "It is the contention of MCC Construction Corporation that the 
     example presented in Amendment 0001 is flawed and the 
     coefficients should be weighted 'against the amount of work to be 
     performed as described in the Statement of Work.'  Using this as 
     a guide, each coefficient would be weighted with three factors:  
     (1) Its location percentage . . . ; (2) Its classification 
     percentage (i.e. construction or heavy and highway) . . . ; and 
     (3) Its normal or other-than-normal working hours percentage . . 
     . ."

After MCC was advised that award had been made to Satellite, the firm 
filed this protest.  

MCC asserts that the coefficients were to be weighted against the 
"amount of work to be performed as described in the Statement of 
Work"; that the statement of work contained two sets of figures; and 
that, as a result, the multipliers should have been combinations of 
these two sets of figures, adjusted for overtime or normal working 
hours, as appropriate.[4]  The Army and Satellite argue that the 
amendment's example clearly indicated that the evaluation would be 
conducted using the multipliers which were actually used.  They 
further argue that MCC's protest is an untimely challenge to what it 
sees as a contradiction between the amendment's example and the 
statement of work.  

To be reasonable, an interpretation of a solicitation must be 
consistent with the solicitation when read as a whole and in a manner 
giving effect to all of its provisions.  Herman Miller, Inc., 70 Comp. 
Gen. 287, 290 (1991), 91-1 CPD  para.  184 at 4; Supplemental Staffing 
Servs., Inc., B-257385, Sept. 21, 1994, 94-2 CPD  para.  108 at 3.  MCC's 
interpretation of the solicitation's evaluation methodology is not 
reasonable because it fails to give effect to all of the language that 
is present.  Nabholz Bldg. and Management Corp., B-274930, Nov. 21, 
1996, 96-2 CPD  para.  196 at 3.

It is undisputed that the multipliers would be based on "the amount of 
work to be performed as described in the Statement of Work," and that 
the statement of work shows two sets of figures, one for the type of 
work to be done and one for the percentage of projects expected to be 
performed at each location.  If the amendment had not included an 
example showing how the evaluation would be conducted, it might be 
necessary to parse the statement of work to determine what the 
multipliers would be.  But the amendment's inclusion of the example 
disposes of this question by clearly indicating that the "amount of 
work" would be represented by the locational percentages.  That these 
percentages standing alone, and not in any combination with other 
percentages, would be used to evaluate the bids is underscored by the 
language in section C, paragraph 00100-8, which states that the 
"percentage of work at each base . . . is an estimate used for 
evaluation factors for purpose of award."  In our view, any question 
that existed regarding the amount of work as described in the 
statement of work was answered by the amendment's example. 

MCC's interpretation of the solicitation wholly ignores the language 
of the amendment's example; indeed, it must in order to make any 
sense.[5]  The firm's contention that the example could not have been 
meant to be taken literally because it did not account for all line 
items is untenable; the example was just that, an example.  The fact 
that it was not all-inclusive does not entitle the protester to ignore 
it altogether, see Nabholz Bldg. and Management Corp., supra, and its 
insistence on doing so was at its peril.  The record shows that the 
evaluation methodology used by the agency was proper and consistent 
with the solicitation, and we have no basis to object to the agency's 
actions.  General Elec. Co., 71 Comp. Gen. 519, 521 (1992), 92-2 CPD  para.  
159 at 3; Supplemental Staffing Servs., Inc., supra, at 4.

In any event, the protest itself reveals that MCC is actually 
challenging what it perceives to be a contradiction between the 
amendment's example and the language in the statement of work.  Even 
if we did not consider the IFB clear as to the evaluation methodology 
that would be used, the contradiction that MCC perceives was apparent 
on the face of the solicitation.  Under our Bid Protest Regulations, 
such a deficiency must be protested prior to the time set for bid 
opening.  4 C.F.R.  sec.  21.2(a)(1) (1997); General Elec. Co., supra.  The 
allegation made in MCC's February 24 letter to the agency, by its own 
admission, before the agency notified it of the evaluation process 
used, only serves to reinforce our conclusion that the firm was on 
notice that this alleged contradiction existed on the face of the 
solicitation.  Where a protester believes that such a contradiction 
exists, it does not have the option of simply making unilateral 
assumptions regarding the meaning of the provisions and then expecting 
relief when the agency does not act in the manner the protester 
assumed; rather, the patent impropriety it believes exists must be 
challenged prior to closing.  Christie Constructors, Inc., B-271759; 
B-271759.2, July 23, 1996, 96-2 CPD  para.  87 at 6. 

The protest is denied.

Comptroller General
of the United States         

1. A coefficient percentage factor is a numerical factor representing 
the contractor's indirect costs and profit or any other costs not 
included in the unit pricing guide's prices.  A coefficient percentage 
factor of 1.25, for example, would indicate that indirect costs and 
profit are 25 percent of direct costs.

2. Bidders were to submit two additional coefficient percentage 
factors for line items whose evaluation is not at issue here.

3. The solicitation estimated that 2 percent of the maximum dollar 
amount of the contract would be for work accomplished on an overtime 
basis. 

4. For example, MCC believes that the multiplier for the line item 
covering construction during normal working hours at the Sandston 
location should have been 74.97 percent:

            a) 85 percent [percentage of work at Sandston] x 90 
               percent [percentage of work that will be construction] 
               = 76.5 percent;
            b) 76.5 percent x 98 percent [percentage of work conducted 
               during normal working hours] = 74.97 percent.

5. MCC's argument that the agency's interpretation of the solicitation 
ignores the language in the statement of work suffers from the same 
defect.  Only if the agency ignored the language of the amendment's 
example could its interpretation even arguably be unreasonable.