BNUMBER:  B-277326; B-277326.2; B-277326.3; B-277326.4; B-277326.5 
DATE:  September 30, 1997
TITLE: Microcosm, Inc., B-277326; B-277326.2; B-277326.3; B-
277326.4; B-277326.5, September 30, 1997
**********************************************************************

DOCUMENT FOR PUBLIC RELEASE
The decision issued on the date below was subject to a GAO Protective 
Order.  This redacted version has been approved for public release.
Matter of:Microcosm, Inc.

File:     B-277326; B-277326.2; B-277326.3; B-277326.4; B-277326.5

Date:September 30, 1997

Alfred J. Verdi, Esq., for the protester.
Timothy A. Harness, for Summa Technology, Inc., and John R. Grady, for 
Universal Space Lines, the intervenors.
Vincent A. Salgado, Esq., and Louis R. Durnya, Esq., National 
Aeronautics & Space Administration, for the agency.
Christina Sklarew, Esq., and Paul Lieberman, Esq., Office of the 
General Counsel, GAO, participated in the preparation of the decision.

DIGEST

Where protester's proposal under broad agency announcement failed to 
include sufficient technical information to establish viability of 
proposed research, agency reasonably determined that technical success 
was improbable and properly determined not to fund proposal.

DECISION

Microcosm, Inc. protests the National Aeronautics & Space 
Administration's (NASA) evaluation and rejection of its proposal under 
NASA research announcement (NRA) 8-19, issued for low-cost 
earth-to-orbit transportation systems research proposals.  Microcosm 
alleges that NASA failed to evaluate the protester's proposal fairly, 
failed to communicate with the protester regarding certain aspects of 
its proposal, relaxed certain of the NRA requirements for the 
awardees, and used competitive procurement evaluation procedures which 
were not appropriate for NRAs.  

We deny the protest.

This procurement was conducted under NASA's Broad Agency Announcement 
(BAA) authority contained in NASA Federal Acquisition Regulation 
Supplement (NFARS)  sec.  1835.016-70.  A BAA is a contracting method by 
which government agencies can acquire basic and applied research.  
BAAs may be used by agencies to fulfill requirements for scientific 
study and experimentation directed toward advancing the state of the 
art or increasing knowledge or understanding rather than focusing on a 
specific system or hardware solution.  A BAA is considered a 
competitive procedure and meets the requirements for full and open 
competition if it is general in nature, identifying areas of research 
interest including criteria for selecting proposals; solicits the 
participation of offerors capable of satisfying the government's 
needs; and provides for peer or scientific review.  Federal 
Acquisition Regulation (FAR)  sec.  6.102(d)(2).  Unlike sealed bidding and 
other negotiated procurement methods, a BAA does not contain a 
specific statement of work and no formal solicitation is issued.  In 
addition, the issuing agency is under no obligation to award any 
contracts and there is no common due date for proposals.  Instead, the 
agency identifies a broad area of interest within which research may 
benefit the government and publishes its desire to contract for such 
research.  Private organizations are then invited to submit their 
ideas within a certain period of time.  The offerors who submit 
proposals are not competing against each other but rather are 
attempting to demonstrate that their proposed research meets the 
agency's requirements.  The agency may decide to fund those efforts 
and award contracts to those offerors who submit ideas which the 
agency finds suitable.  See FAR  sec.  35.016.

The BAA at issue is under NASA's Bantam System Technology Project, the 
first phase of which was conducted under NRA 8-15, which focused on 
other aspects of the project such as developing and demonstrating, in 
ground tests, low cost components for propulsion systems, adapting 
commercial manufacturing practices, utilizing commercial off-the-shelf 
hardware, and other similar requirements.  This NRA, for Phase II, is 
intended to continue the technology maturation process by 
demonstrating low recurring-cost technologies with a focus on flight 
demonstrations.[1]  NRA 8-19, in relevant part, solicited proposals 
for innovative technology development and flight demonstration to 
enable significant cost reduction in transporting small payloads to 
low earth orbit.  The NRA expressed NASA's goal for a new Bantam 
transportation system of delivering small payloads (150 kilograms) to 
low earth orbit (200 nautical miles sun synchronous) for a recurring 
price of $1.5 million beginning in 2001.  The Bantam System Technology 
Project was divided into two proposal cycles.  Cycle One proposals 
were for a 6-month effort for initial design and business plan 
development, with Cycle Two proposals to be for flight 
demonstrations.[2]  This protest concerns the first of the two cycles.   

Offerors were invited to propose any transportation system 
architecture or concept (e.g., reusable, partially reusable, 
expendable, liquid, hybrid, or solid propellants) that would best 
approach or accomplish NASA's goal.  Different architectures and 
innovative concepts were encouraged, and both existing and new 
technologies were acceptable.  The NRA stated that "[m]ultiple awards 
are planned for each cycle and it is undesirable for NASA to have more 
than one contractor working on identical architectures or concepts."

Offerors were required to submit a technical description of their 
planned system and a business plan for the operation of the system on 
a commercial basis.  The NRA listed representative parameters to be 
defined in the technical and business plan areas of the proposals.  
Offerors were also instructed to include an overview of how they 
intended to accomplish the second phase, and the NRA stated that 
offerors selected for the first cycle must have the capability to 
accomplish the second cycle.  The NRA included standard instructions 
for responding to NRAs and supplemental guidelines specific to this 
NRA.  Offerors were warned that NASA might accept proposals without 
discussions and that proposals should therefore initially be as 
complete as possible and be submitted on the proposers' most favorable 
terms.  The instructions stated that to be considered responsive, a 
submission must, at a minimum, present a specific project within the 
areas delineated by the NRA; contain sufficient technical and cost 
information to permit a meaningful evaluation; be signed by an 
official authorized to legally bind the submitting organization; not 
merely offer to perform standard services or to just provide computer 
facilities or services; and not significantly duplicate a more 
specific current or pending NASA solicitation.  Proposals were to be 
evaluated under three principal factors, of approximately equal 
importance, described in the instructions as follows:

     Relevance to NASA's objectives:  includes the consideration of 
     the potential contribution of the effort to NASA's mission.  

     Intrinsic merit:  includes the following factors:
     
     1.  Overall scientific or technical merit of the proposal or 
     unique and innovative methods, approaches, or concepts 
     demonstrated by the proposal;

     2.  Offeror's capabilities, related experience, facilities, 
     techniques, or unique combinations of these which are integral 
     factors for achieving the proposal objectives;

     3.  The qualifications, capabilities and experience of the 
     proposed principal investigator, team leader, or key personnel 
     critical in achieving the proposal objectives;

     4.  Overall standing among similar proposals and/or evaluation 
     against state-of-the-art.

     Evaluation of the cost of a proposed effort: includes the realism 
     and reasonableness of the proposed cost and available funds.

A synopsis of the NRA was published in the Commerce Business Daily in 
January 1997, and the NRA was released in March.  Twelve offerors, 
including Microcosm, submitted proposals for Bantam technology, Cycle 
One on April 30.  NASA established a source evaluation team (SET) 
consisting of a technical panel, a business panel, and a cost panel to 
evaluate these proposals with panel members from three different NASA 
installations.  Individual members of the panels conducted the initial 
evaluations; each panel then met, discussed the attributes of each 
proposal, and reached a consensus on their findings.  The voting 
members reviewed the panel findings and reached a consensus on the 
strengths and weaknesses of each proposal and reported their findings 
to the source selection official (SSO).  The SSO selected 4 of the 12 
proposals for negotiations leading to award.  Microcosm, whose 
proposal was not among those chosen, requested and received a 
debriefing, and this protest followed.

Microcosm protests that its proposal was misevaluated, in essence 
alleging that the proposal's strengths were not given sufficient 
credit in the evaluation and that the proposal should not have been 
downgraded for improperly identified weaknesses.  In addition, 
Microcosm asserts that the agency was required to communicate with the 
protester to clarify any technical points and alleges that NASA 
introduced evaluation factors that were not disclosed in the NRA.

Proposals were not numerically scored.  They were evaluated according 
to the factors listed in the NRA, and strengths and weaknesses were 
assessed.  The evaluation record shows that NASA evaluators considered 
Microcosm's approach to be among the most complex of all the concepts 
that were submitted, and found that Microcosm's proposal failed to 
justify the added complexity and cost that this approach presented.  

The evaluation of technical proposals is primarily the responsibility 
of the contracting agency; the agency is responsible for defining its 
needs and the best method of accommodating them and must bear the 
burden of any difficulties arising out of a defective evaluation.  
Avogadro Energy Sys., B-244106, Sept. 9, 1991, 91-2 CPD  para.  229 at 5.  
In reviewing an agency's technical evaluation, we will not reevaluate 
the proposals; we will only consider whether the agency's evaluation 
was reasonable and in accord with the evaluation criteria listed in 
the solicitation.  Herndon Science and Software, Inc., B-245505, Jan. 
9, 1992, 92-1 CPD  para.  46 at 3.  A protester's disagreement with the 
agency's judgment is not sufficient to establish that the agency acted 
unreasonably.  Id.  

Microcosm proposed to design, test, qualify, and operate a [deleted] 
system that it calls the "Sprite."  Microcosm has developed a family 
of expendable launch vehicles under a sounding rocket program called 
"Scorpius," based on research that was performed, in part, under 
government contracts.  The proposed Sprite launch vehicle, while not a 
part of the Scorpius group, is designed to build on the technology 
developed under the Scorpius program in order to reduce cost and risk 
factors.  [Deleted].

Based on our review of the record, we find the agency's evaluation and 
consequent rejection of Microcosm's proposal reasonable.  The 
evaluation record indicates that the evaluators generally had concerns 
both because there was insufficient information included in 
Microcosm's proposal to permit a clear understanding of the firm's 
approach, and because that approach was exceptionally complex.   

Under the "Relevance to NASA's Objectives" evaluation factor, the fact 
that Microcosm's [deleted] was already in testing was deemed a 
significant strength.  The status of the engine was considered 
particularly important, given the fact that [deleted].  The evaluators 
also identified the proposed leveraging of existing avionics as a 
strength; the proposal identified three key elements of the proposed  
[deleted] as being available from Microcosm's sounding rocket program.  
However, the evaluators had concerns regarding the remaining 
[deleted], as well as the placement of the [deleted], for which they 
did not find adequate description in the proposal.  

The SET found three significant weaknesses (the [deleted] in the 
system; the use of [deleted]; and research repetitive of NASA/Air 
Force contract programs) and six other weaknesses ([deleted] that were 
considered unrealistic, the retention of data rights, and four arising 
from technical areas with insufficient proposal detail) under this 
evaluation factor.  

The first of the significant weaknesses concerned the [deleted], which 
NASA considered to be insufficiently explained.  [deleted].  In 
addition to the fact that Microcosm's overall vehicle design was 
considered one of the most complex of the 12 vehicle designs proposed, 
the SET found that the first-stage pod design was much more complex 
than the level of engineering detail in the Microcosm proposal would 
explain.  During NASA's review of the proposal, specialists in system 
design, main propulsion system design, structural design, structural 
analysis, avionics design, performance modeling, and operations from 
three NASA installations reviewed the proposal.  The proposal did not 
convince these specialists that the proposed design adequately 
supported the proposed manufacturing approach or had lower 
recurring-cost potential.  Although the [deleted] was one of the most 
unique features of Microcosm's proposed vehicle, it was one of the 
least completely described features in the proposal.  In view of the 
complexity and importance of the [deleted], NASA concluded that 
Microcosm's failure to adequately address it in its proposal was a 
significant weakness.

Microcosm takes the position that [deleted] "is used in various 
configurations on nearly all launch vehicles worldwide including 
Shuttle, Titan [and others]" takes exception to the agency's 
characterization of this aspect of Microcosm's design as a "unique 
feature."  In response, NASA points out that it is not the use of 
[deleted] per se that is considered to add complexity.  Rather, NASA 
explains that under the protester's concept, [deleted] are dependent 
on other [deleted] for oxidizer; half of the [deleted] have engines 
(causing them to lift or push) while the remaining [deleted] drag or 
pull; in addition, the [deleted] are individually jettisoned, 
requiring piping to be disconnected and shut off in a very precise and 
complicated manner.  The agency has provided a chart comparing key 
characteristics in Microcosm's design to two other [deleted], to 
illustrate its basis for concluding that Microcosm's design was 
unusually complex.  The chart compares attributes such as number of 
stages, propulsion system type, complexity of engines (by number of 
parts), ignition systems, and thrust vector control.  In nearly every 
category, the Sprite vehicle is more complex.  While these comparisons 
are not dispositive of whether the Sprite design would achieve the 
agency's goal, they support the agency's position that in the absence 
of sufficient additional information explaining the complexity (or  
demonstrating that the design is not as complex as it appears), the 
SET reasonably concluded that these unexplained complexities 
represented a significant weakness.  

Microcosm argues that comparing systems by their parts count is not 
the only way to determine whether a design is complex or simple; 
rather, low-cost elements, such as the engine, and design features, 
such as a low number of moving parts, should also be considered.  
Microcosm argues, for example, that although its design includes 
[deleted], rather than the [deleted] that NASA has cited in its 
comparisons, it is more relevant to the issue of simplicity that 
[deleted].  However, the information that Microcosm now provides was 
not provided in its proposal.[3]  In addition, NASA points out that at 
least one of the systems used in its comparison has engines with only 
six parts; moreover, both engines in this design have been tested, 
whereas only one of Microcosm's engine designs has been tested.     

Throughout the evaluation and agency report, it is clear that NASA 
considered a number of features of the Sprite design to be engineering 
challenges that could not be understood without substantially more 
data disclosure; in short, the proposal did not adequately explain the 
approach.  Although Microcosm has attempted in its protest submissions 
to provide additional information to explain certain aspects of its 
proposal, this information does not change the validity of the 
proposal's evaluation, since the agency could only evaluate proposals 
on the basis of the information they contained when they were 
submitted.  It is an offeror's responsibility to submit an adequately 
written proposal in order to establish that what it proposes will meet 
the government's needs; an offeror runs the risk of having its 
proposal rejected if the proposal submitted is inadequately written.  
See Herndon Science and Software, Inc., supra, at 4.

Identified as Microcosm's second significant weakness was the 
[deleted], which NASA believed would lower reliability and increase 
the cost of the system.  Although the NRA clearly welcomed innovative 
design approaches and permitted any type of vehicle configuration, the 
solicitation also made it clear that whatever configuration was 
proposed would be evaluated in terms of its ability to advance the 
NRA's stated mission--to enable significant cost reduction in 
transporting small payloads to low earth orbit.  NASA believed this 
design, which was the only one it received that proposed the use of 
[deleted], would generally increase vehicle processing time, reduce 
reliability, and increase recurring cost due to duplication of 
systems, increase in overall vehicle complexity, and high parts count.  
As an example of one of its concerns with the multi-stage Sprite 
design, NASA notes in its report that in order to [deleted].  Thus, 
the agency concluded that the [deleted], the higher the cost and 
reliability risk.  The Sprite's [deleted] design requires [deleted] 
systems, in addition to individual separation systems for each of the 
[deleted].  

In response to the agency's analysis, Microcosm asserts that NASA has 
raised a  "broad philosophical argument with no basis in engineering 
fact or support in traditional launch vehicle design."  The thrust of 
Microcosm's response is that NASA has ruled out any multi-stage 
design, and that this is an arbitrary restriction, inconsistent with 
the terms of the NRA.  On the contrary, these concerns are reasonably 
related to the NRA requirements.  NASA's concerns, discussed above, 
are similar to the concerns expressed regarding the [deleted]:  that 
the design is particularly complex; that the complexities are not 
justified by any explanations in the proposal; and that the 
complexities are inconsistent with achieving the stated goal of 
lowering costs.  We conclude that NASA's evaluation in this area was 
reasonable and consistent with the NRA.

The third significant weakness identified under this factor was NASA's 
concern that funding the proposed effort would be repetitive of 
contracts that Microcosm had with the Air Force and with NASA.  
Microcosm's proposal states that the Scorpius program is currently 
funded under multiple contracts, including ones with NASA, which call 
for initial launch of two suborbital vehicles within the next year; 
these launches would provide the system level test-bed for the Sprite.  
While NASA appreciated that the use of existing and already funded 
technologies proposed by Microcosm would reduce the element of risk to 
a certain extent, and assigned the proposal a significant strength on 
this basis, the evaluators did not want to fund a second demonstration 
of these technologies on what they considered to be only a slightly 
different scale.  NASA viewed this duplication of effort as analogous 
to the duplication that would occur if two contractors were working 
separately on identical technologies or concepts, which the NRA 
expressly discouraged.

Microcosm points out that the NRA advised offerors that both existing 
and new technologies would be acceptable, and reasons that the 
proposed technology from existing programs should be acceptable.  
Microcosm concedes that its current contracts use the [deleted] now 
being developed in single stage suborbital flights, but distinguishes 
the efforts by noting that these flights do not test the [deleted] or 
the [deleted], nor any other aspects crucial to the Sprite system.  

We find no basis to question NASA's assessment of a significant 
weakness due to other similar contracts Microcosm holds.  Since NASA's 
purpose in trying to avoid the award of two contracts to two different 
contractors for the same approach is to expend research funds only on 
truly innovative concepts, it is reasonable to conclude that the same 
purpose is served by preventing one contractor from performing the 
same (or substantially similar) work under more than one contract.  

The agency also identified various other weaknesses, including the 
absence of any [deleted]; [deleted] detail that was minimal; the 
failure to address [deleted]; [deleted]; and structural mass fractions 
proposed for the first and second stages, the achievability of which 
the evaluators doubted.[4]   The evaluators also expressed doubt 
regarding the achievability of the proposed [deleted], which was the 
final weakness identified in this area.  In sum, these weaknesses were 
all based on NASA's conclusion that additional basic engineering data 
was necessary to demonstrate the viability of the system and to 
validate Microcosm's claims of system simplicity.  

Based on our review of the record in each of these areas, we consider 
reasonable NASA's conclusions regarding the paucity of detail in the 
protester's proposal.  For example, the report explains the weakness 
rating for the failure to provide any [deleted] in the proposal as 
follows:

     A propulsion system consists of engines, tanks to hold 
     propellants, a pressurization system to move fluids around the 
     vehicle, and a plumbing and control system connecting the tanks 
     and the engines.  Typically this information is portrayed on a 
     fluid, or gas, system schematic.  The main propulsion system must 
     provide for loading and unloading of rocket propellant from each 
     stage, loading and unloading liquid oxygen from each stage, 
     loading and unloading pressurization gases from each stage, 
     pre-start chill functions, engine start and operation, engine 
     shutdown, and system preparations for staging.  The evaluation 
     team identified the lack of a [deleted] as a weakness in the 
     offeror's proposal.

Microcosm acknowledges that it included no [deleted] in its proposal, 
asserting that the NRA did not expressly require this information and 
that [deleted] is common to all launch vehicles, rather than being 
unique to the Microcosm design.  
Although this information was not specifically required, the NRA did 
require that proposals contain sufficient technical information to 
permit a meaningful evaluation.  We find reasonable the agency's 
explanation regarding the importance of this information for the 
purpose of validating the firm's claims of system viability and 
simplicity.  

Responding to the weakness ratings generally, Microcosm asserts that 
while "the central theme of the NASA evaluation is the complexity of 
the Microcosm design," Microcosm in fact "identified design simplicity 
as one of the major strengths."  However, the primary support in the 
proposal for simplicity of design consists of the protester's 
conclusory statements to that effect.  For example, Microcosm states 
in its proposal, "We anticipate more than a factor of [deleted] than a 
traditional vehicle with almost no [deleted].  If funding proceeds for 
the Scorpius program, we anticipate being able to reduce total launch 
costs by a factor of [deleted] with commercial operation beginning in 
[deleted]. . . ."  Microcosm lists the requirements established in the 
NRA for payload capacity, orbit, and price per mission and then lists 
"Microcosm Design Capability" next to that list, matching its 
projected capability to each of the stated requirements.  The proposal 
concludes that "Microcosm meets the above economic and performance 
goals with a [deleted] that will be made from major assemblies 
developed over the past 4 years for low cost rockets."  These 
unsupported assertions, however, do not demonstrate that the system it 
is proposing will perform as represented.  It is the offeror's 
responsibility to submit an adequately written proposal in order to 
establish that what it proposes will meet the government's needs; this 
principle is particularly important where research is to be undertaken 
into new concepts.  See Herndon Science and Software, Inc., supra, at 
4.

Microcosm also protests that NASA improperly assigned a significant 
weakness to its business plan, which the agency considered to be 
incomplete.  The record shows that, although the NRA required offerors 
to identify certain parameters for the system in its first 10 years of 
operation, such as expected annual revenues and expenses, Microcosm 
only showed 4 years of the life cycle in its plan, from which the 
values for the missing years could not be determined.  NASA also was 
concerned that the lack of information about initial nonrecurring 
expenses would preclude determining the rate of return.  Revenue and 
expenses, shown as total amounts, provided no way to determine what 
was included, and "other revenue" entries included no explanation of 
their source or content.  As a related weakness, the evaluation noted 
that little basis was provided for the projection of [deleted] flights 
per year; this rate, which is higher than the current rate, was not 
supported by trend data or market research information.  

NASA also identified Microcosm's failure to grant NASA [deleted] as a 
significant weakness.  The NRA warned offerors that "restrictions on 
resulting technology are highly discouraged and will be considered in 
the evaluation."  Microcosm stated in its proposal that NASA would 
acquire unlimited rights to all inventions developed under the 
contract; however, Microcosm also retained certain rights for itself 
in its proposal, stating, for example, that

     [Deleted].

The protester opines in its proposal, further, that "in order for 
commercial funding to occur, it is critical that [deleted] be retained 
by SSLC."[5] 

Based on our review of the record, we find no basis to question the 
reasonableness of the agency's evaluation with regard to Microcosm's 
incomplete business plan and its failure to grant unlimited data 
rights.

Microcosm also protests that NASA violated NFARS  sec.  1835.016-70(e)(4) 
by failing to communicate with Microcosm to clarify areas of its 
proposal that were unclear.  This regulation provides, in relevant 
part:

     After receipt of a proposal and before selection, scientific or 
     engineering personnel shall communicate with an offeror, 
     regarding the proposal, only for the purpose of clarification, as 
     defined in FAR 15.601, or in order to understand the meaning of 
     some aspect of the proposal that is not clear, or in order to 
     obtain confirmation or substantiation of a proposed approach, 
     solution, or cost estimate.

Microcosm argues that this provision required NASA to communicate with 
the protester, particularly in connection with those areas of the 
proposal that were considered lacking in technical information or 
detail.  We disagree.  

The operative language, quoted above, describes the only purposes for 
which communication with an offeror is permitted; it does not, as the 
protester urges, require that communications occur.  Here, the NRA 
explicitly warned offerors that the agency might accept proposals 
without discussion and that proposals should initially be as complete 
as possible and be submitted on the proposer's most favorable terms.  
NASA did not communicate with any offerors before it made its 
selections.
 
Microcosm also protests that NASA introduced "other competitive 
procurement evaluation procedures," alleging that the agency 
improperly created three categories of proposals (high potential, 
potentially viable, and not viable) and followed procedures similar to 
ones used by the Air Force.  We find this allegation without merit.  
First, there is no prohibition in the NFARS, the NRA, or applicable 
portions of the FAR, against sorting proposals into categories during 
the process of evaluation and source selection.  We do not agree with 
Microcosm's premise that this act constituted a competitive range 
determination.  Second, there is no evidence of any impropriety in the 
selection process.

Taken together, the strengths and weaknesses identified in Microcosm's 
proposal reasonably support the SET's decision to reject Microcosm's 
proposal.  Accordingly, the issues raised in Microcosm's initial 
protest are denied.

Microcosm raised a number of additional issues in comments and 
supplemental protests, which we dismiss for the reasons explained 
below.

Several of Microcosm's supplemental protest grounds concern the 
evaluation of other offerors' proposals.  However, unlike the 
situation that exists under a negotiated procurement, offerors who 
submit proposals under a BAA are not competing against each other, and 
thus the various issues Microcosm has raised regarding the evaluation 
of other offerors' proposals are not for consideration.[6]  See FAR  sec.  
35.016.

In comments filed under its initial protest, Microcosm raised two new 
issues, alleging a "prejudicial assignment of adjectival ratings" and 
"random gradings not related to the NRA requirements or the evaluation 
factors."  Because these were not raised within 10 days of when the 
protester first became aware of their basis (in the agency report), 
they are supplemental protest grounds which fail to independently 
satisfy our timeliness requirements.  Although Microcosm received an 
extension of time for filing its comments on the agency report, such 
an extension did not have the effect of waiving the timeliness 
requirements for filing bid protests; notwithstanding the extended 
comment due date, any protest allegations based on information in the 
agency report had to be filed no later than 10 days after Microcosm 
received the agency report.  Accordingly, these new issues are 
untimely.  Management Tech., Inc., B-257269.2, Nov. 8, 1994, 95-1 CPD  para.  
248 at 10. 

After receiving a supplemental agency report in response to 
Microcosm's second supplemental protest on August 12, Microcosm filed 
a third supplemental protest on August 22.  In this protest, Microcosm 
alleges that proposals were evaluated in an unequal manner (including 
objections to individual ratings); and that the evaluation was 
inadequately documented and the source selection decision inadequately 
justified; and that NASA conducted discussions with only the awardees, 
allegedly violating a duty to open discussions with all offerors.  On 
September 18, Microcosm filed its fourth supplemental protest, based 
on statements contained in a request filed by the agency seeking 
dismissal of certain supplemental issues.  This latest protest alleges 
a reversal in the agency's position regarding issues raised in the 
penultimate supplemental protest.

We dismiss these issues.  Several of the allegations involve the 
evaluation of the selectees' proposals and therefore, as explained 
above, do not form a valid basis of protest in a procurement under a 
BAA.  To the extent the newly-raised issues are based on information 
contained in the initial agency report, which Microcosm received on 
July 30, they are untimely filed.  Moreover, allegations that NASA 
failed to follow its source selection plan fail to state a valid basis 
for protest, since the source selection plan provides internal agency 
guidance and does not establish legal rights and responsibilities such 
as to make actions taken contrary to those statements subject to 
objection.  See Indian Resources Int'l, Inc., B-256671, July 18, 1994, 
94-2 CPD  para.  29 at 3; Motorola, Inc., B-247937.2, Sept. 9, 1992, 92-2 
CPD  para.  334 at 5.  New issues concerning the production of individual 
evaluators' worksheets to document the evaluation fail to state a 
valid basis of protest since, as explained above, the consensus 
reports and source selection decision were consistent with the NRA; 
since the evaluators' notes and scoring sheets are not necessary to 
judge the rationality of the evaluation that is otherwise adequately 
documented, an examination of individual scoresheets would be 
irrelevant here.  See Hydraudyne Sys. and Eng'g, B.V., B-241236, 
B-241236.2, Jan. 30, 1991, 91-1 CPD  para.  88 at 4-5. 

The protest is denied.

Comptroller General
of the United States

1. The NRA solicited proposals in three separate areas; only the first 
area, for Bantam Technologies, is relevant here.

2. Cycle Two, for flight demonstration, will be acquired competitively 
and Microcosm will be eligible to compete for that phase as well.

3. Microcosm repeatedly and inaccurately asserts that certain 
information was in fact included in the proposal.  For example, the 
protester alleges that "specific facts" concerning its engines--parts 
count, man-hour estimates, and comparison pricing with other 
engines--were included in its proposal; however, the support cited for 
this assertion is to a journal article listed only as a reference in 
one of the proposed employee's resumes included in the proposal.  We 
do not consider this information to have been included in the proposal 
in any useful way.

4. The evaluators were unable to arrive at a more certain conclusion 
because of the low level of detail in the proposal for the structure 
and main propulsion system.

5. In addition to restricting rights, this statement also draws into 
question the exact relationship between the Scorpius and Sprite 
projects and would appear to support NASA's concern that research 
under the two programs could be duplicative.  To the extent the line 
between the two is imprecise--as demonstrated by the discrepancy in 
opinion between NASA and Microcosm expressed in the course of this 
protest--the line between data rights arising under one project or the 
other would also be imprecise. 

6. We also find without merit the protester's allegations of unequal 
treatment among offerors; since we have concluded that NASA's 
treatment of Microcosm's proposal was reasonable, the evaluation of 
other offerors' proposals is irrelevant, and no credible claim of bias 
has been raised.