BNUMBER:  B-278103 
DATE:  December 29, 1997
TITLE: Caswell International Corporation, B-278103, December 29,
1997
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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:Caswell International Corporation

File:     B-278103

Date:December 29, 1997

Rodney A. Grandon, Esq., Patton Boggs, L.L.P., for the protester.
Capt. Patrick B. Kernan, Department of the Army, for the agency.
Paula A. Williams, Esq., and Michael R. Golden, Esq., Office of the 
General Counsel, GAO, participated in the preparation of the decision.

DIGEST

Protest that interoperability requirement in solicitation for targetry 
equipment used for military training exercises is unduly restrictive 
of competition is denied where the requirement is based on the 
agency's need to ensure operational safety and military readiness. 

DECISION

Caswell International Corporation protests the terms of request for 
quotations (RFQ) No. DABT60-97-Q-0479, issued by the Department of the 
Army, for a quantity of commercially available targetry equipment used 
by the 25th Infantry Division stationed in Hawaii.  Caswell contends 
that the solicitation requirement for interoperability with existing 
government-owned targetry manufactured by ATA Defense Industries, Inc. 
(ATA) is unduly restrictive of competition. 

We deny the protest.

The agency issued a combined Commerce Business Daily synopsis and 
solicitation for targetry equipment which was published on July 25, 
1997.  The equipment under this RFQ, a total small business set-aside, 
will be used to support training for the 25th Infantry Division at a 
number of locations in Hawaii and will also be used as targetry that 
can be deployed by the 25th Infantry Division in support of its 
mission   to South Korea--the primary deployment site for the 25th 
Infantry Division.[1] 

The challenged interoperability requirement, listed in the performance 
specifications, provides as follows:

     All items procured under this contract must be fully 
     interoperable with existing deployable range equipment procured 
     from ATA Defense Industries.

A site visit was scheduled for August 15 to allow interested vendors 
to view, operate, and take readings from government-furnished targetry 
equipment that was the same as the targetry equipment being used by 
the 25th Infantry Division.  ATA was the only vendor that submitted a 
quotation by the August 22 extended closing date.  That same day, 
Caswell filed an agency-level protest in which it argued that the 
solicitation improperly restricts competition because potential 
vendors, other than ATA, cannot meet the requirement for 
interoperability with ATA-proprietary targetry equipment.  The agency 
denied that protest on September 10, and the firm's subsequent protest 
to our Office repeated this claim.[2]

The agency explains that the interoperability requirement is necessary 
because the targetry equipment at issue here will be combined with 
existing government-owned ATA targetry to meet the multi-level 
training needs of the 25th Infantry Division.[3]  According to the 
agency, if the range targetry equipment available to the Range Control 
Officer (RCO) are not interoperable, the RCO cannot pre-program the 
training scenarios in the way the exercises are going to occur nor, 
depending on the nature of the training exercises, rapidly reconfigure 
the targetry as needed.  The result would be detrimental to military 
training and readiness, as the RCO may be unable to conduct division, 
brigade, and battalion-wide exercises.  

For example, when a division-wide exercise is conducted, all ranges 
and targets are utilized.  Conducting the training and moving through 
the ranges with the soldiers are observer/controllers who evaluate and 
operate the targetry by means of a hand held controller (HHC).  If the 
targetry being acquired were not interoperable with the existing 
targetry, the observer/controller would have to carry two different 
types of HHCs (the average weight for each is more than 10 pounds) to 
operate the targets and would need to keep track of which HHC operated 
the next target device.  The agency states that the probability for a 
training incident is very high because most of these live-fire 
training exercises occur at night.  VT at 13:27:01.  To require the 
observer/controller to carry two HHCs would create an unacceptable 
risk which, the agency states, would threaten the safety of the 
soldiers participating in these live-fire training exercises.  VT at 
13:31:00.

Further, since the 25th Infantry Division is routinely deployed to 
South Korea, the Army must have the ability to combine the targetry 
used by the 25th Infantry Division in Hawaii with the targetry on hand 
in South Korea.  The agency maintains that, as in Hawaii, the military 
readiness of the troops in South Korea would be severely compromised 
if the targetry equipment deployed with the 25th Infantry Division 
were not interoperable with the government-owned ATA targetry used by 
the soldiers in South Korea.  VT at 13:39:40.  

The Competition in Contracting Act of 1984 requires that agencies 
specify their  needs and solicit offers in a manner designed to 
achieve full and open competition, so that all responsible sources are 
permitted to compete. 10 U.S.C.  sec.  2305 (a)(1)(A)(i) (1994).  The 
determination of a contracting agency's minimum needs and the best 
method for accommodating them are matters primarily within the 
agency's discretion.  Tucson Mobilephone, Inc., B-250389, Jan. 29, 
1993, 93-1 CPD  para.  79 at 2, recon. denied, B-250389.2, June 21, 1993, 
93-1 CPD  para.  472.  Where a requirement relates to national defense or 
human safety, as here, an agency has the discretion to define 
solicitation requirements to achieve not just reasonable results, but 
the highest level of reliability and effectiveness.  Industrial 
Maintenance Servs., Inc., B-261671 et al., Oct. 3, 1995, 95-2 CPD  para.  
157 at 2; Harry Feuerberg & Steven Steinbaum, B-261333, Sept. 12, 
1995, 95-2 CPD  para.  109 at 3. 

The record provides no basis to question the legitimate concerns of 
the agency  regarding the impact on the safety of the soldiers 
participating in the training exercises and the overall military 
readiness of the 25th Infantry Division if the targetry being acquired 
were not interoperable with existing government-owned targetry 
equipment.  Based on this record, including the testimony from agency 
officials, and the fact that Caswell does not refute the agency's 
explanation supporting its requirement, we do not find the 
interoperability requirement unduly restrictive.

The protester continues to argue that potential vendors such as itself 
could not achieve interoperability with the ATA equipment because the 
cost to reverse engineer an interface would be prohibitive and would 
require access to ATA proprietary information, such as ATA's 
proprietary control systems.  The agency responds that the level of 
effort and technical approach needed to manufacture an interface box 
to achieve interoperability do not require access to ATA's proprietary 
data.  In this regard, the agency asserts that, in order to make 
different target systems interoperable, a potential vendor need only 
determine the radio signals generated by the government-owned HHC.  
Once the radio signals are obtained, the vendor could build an 
interface box that would be placed on the targets to convert the radio 
signals from the differing HHC to a language that the vendor's target 
interface box could understand.  While Caswell disagrees with this 
technical approach and argues in favor of an extensive engineering and 
design effort that allegedly would require access to ATA proprietary 
software, Caswell has not shown that the agency's position regarding 
the feasibility of developing an interface is wrong.  Further, given 
our conclusion that the interoperability requirement at issue here is 
reasonably related to the Army's needs, the fact that Caswell or other 
vendors cannot meet the requirement does not demonstrate that it is 
improper.[4]

The protest is denied.

Comptroller General
of the United States      

1. A hearing was conducted in connection with this protest pursuant to 
4 C.F.R.  sec.  21.7(g) (1997). 

2. A purchase order was subsequently awarded to ATA, but performance 
has been suspended pending resolution of this protest.  

3. Two members of the technical team testified that the Army owns more 
than $1 million in ATA targetry equipment in the 25th Infantry 
Division's primary areas of operation--Hawaii and South Korea.  Video 
Transcript (VT) 13:48:10.  

4. Caswell has made a number of other related contentions during the 
course of this protest pertaining to the adequacy of the agency's 
market survey and the time allowed for vendors to attend the site 
visit and engineer a solution to the interoperability requirement.  
Although these contentions are not specifically addressed in this 
decision, each was carefully considered by our Office and found to be 
either immaterial in view of our conclusion above that the requirement 
was justified by the Army, or untimely (either because the protest 
issues were not raised prior to the date set for the submission of 
quotations or because they were first raised in the comments to the 
agency report).  Bid Protest Regulations, 4 C.F.R.  sec.  21.2.