BNUMBER:  B-278126; B-278126.2 
DATE:  December 31, 1997
TITLE: Oceaneering International, Inc., B-278126; B-278126.2,
December 31, 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:Oceaneering International, Inc.

File:     B-278126; B-278126.2

Date:December 31, 1997

Daniel J. Riley, Esq., and Stan Hinton, Esq., Baker & Botts, for the 
protester.
Buel White, Esq., and Brian Cohen, Esq., Bell, Boyd & Lloyd, for 
Phoenix Marine, Inc., an intervenor.
Veronica Murtha, Esq., and James Menapace, Esq., Department of the 
Navy, for the agency.
Jacqueline Maeder, Esq., Glenn G. Wolcott, Esq., and Paul Lieberman, 
Esq., Office of the General Counsel, GAO, participated in the 
preparation of the decision.

DIGEST

1.  Protest that agency improperly evaluated technical proposals is 
denied where the record shows that the evaluation was reasonable and 
consistent with the stated evaluation factors; protester's mere 
disagreement with the agency's conclusion does not render the 
evaluation unreasonable.

2.  Allegation that awardee should have been disqualified as 
nonresponsible for failure to demonstrate possession of a specific 
line of credit is dismissed where the requirement for financial 
capability at issue is not set forth in the form of a definitive 
responsibility criterion.  

DECISION

Oceaneering International, Inc. protests the award of a contract to 
Phoenix Marine, Inc. under request for proposals (RFP) No. 
N00024-97-R-4025(Q) issued by the Department of the Navy's Naval Sea 
Systems Command (NAVSEA) for world-wide diving and diving-related 
services.  Oceaneering challenges the agency's evaluation of technical 
proposals and argues that Phoenix Marine did not comply with a 
definitive responsibility criterion.[1]

We deny the protest.  

The RFP, issued via the Internet on October 18, 1996, contemplated the 
award of a combination cost and fixed-price/indefinite quantity, 
indefinite delivery contract for various diving-related services, 
including underwater maintenance on ships' hulls and structures, dry- 
and wet-welding, and salvage assistance.  All services will be 
performed in response to task orders issued on a per-diem cost plus 
award fee basis (for operational services, including emergency or 
field operations) or a firm, fixed-price basis (for non-operational 
services not requiring field deployment).   

The RFP called for the submission of separate technical and cost 
proposals and advised that technical considerations were more 
important than cost.  The RFP provided that award would be made, 
without discussions, to the offeror whose proposal, conforming to the 
solicitation, was determined to be most advantageous to the 
government.  The evaluation factors and subfactors and the weight of 
each factor or subfactor are listed below:

     1.  Personnel                      33 percent

     2.  Quality Assurance Plan and Procedures27 percent

        a.  Quality Assurance Plan 8 percent
        b.  Welding and NDT Procedures[2]7 percent
        c.  Welding Certification Plan6 percent
        d.  NDT Personnel Certification6 percent

     3.  Corporate:  Past Performance, Organization,
          Management                    27 percent

        a.  Past Performance       17 percent
        b.  Organization             6 percent
        c.  Management               4 percent

     4.  Equipment and Facilities       13 percent

        a.  Equipment                9 percent
        b.  Shore-based Support Facilities  4 percent
          
Two proposals, Oceaneering's and Phoenix Marine's, were received by 
the January 24 closing date.[3]  The proposals were reviewed 
individually by each of the three members of the technical evaluation 
review panel (TERP).[4]  The evaluators rated each factor and 
subfactor using adjectival ratings and corresponding point values on a 
scale of 0 to 10 (9.5 to 10 for "outstanding"; 8.5 to 9.4 for 
"excellent"; 7.5 to 8.4 for "good"; 6.5 to 7.4 for "acceptable"; 3.5 
to 6.4 for "marginal"; and, 0 to 3.4 for "unsatisfactory").[5]  The 
individual scores assigned were averaged to arrive at a composite 
numerical score for each of the subfactors.  The numerical rating was 
multiplied by the weight for the subfactor and the scores for each 
subfactor were totaled.  A proposal that received all outstanding 
ratings would receive a maximum weighted point score of 10.  The TERP 
awarded the following scores for the proposals:

             Maximum     Oceaneering    Phoenix Marine
     
Personnel      3.3            2.89             3.09
Quality Assurance2.7          2.44             2.34
Corporate
  Experience 2.7              2.31             2.27
Equipment &                          
  Facilities   1.3            1.18             1.11       

TOTAL          10             8.82             8.81
                              
The offerors proposed scheduled and non-scheduled cost factors from 
which the agency generated a total evaluated cost factor.  The agency 
reports that Phoenix Marine's normalized cost is [DELETED] percent 
lower than Oceaneering's normalized cost.  The protester states that 
the differential is only [DELETED] percent.  In any event, the record 
confirms that the awardee's cost is significantly lower than the 
protester's cost.  Because the total technical scores of the two 
offerors were virtually identical and Phoenix Marine offered the lower 
price, the Navy determined that Phoenix Marine offered the best value 
to the government and awarded the contract on September 9.  

Oceaneering challenges the evaluation of each offeror's past 
performance, the evaluation of Oceaneering's proposed project manager, 
and the evaluation of Phoenix Marine's facilities and equipment.  
Oceaneering also protests that one member of the TERP failed to follow 
the evaluation scheme outlined in the RFP and argues that Phoenix 
Marine did not comply with an alleged definitive responsibility 
criterion.[6]  

TECHNICAL EVALUATION

Past Performance

The RFP instructs offerors to identify all public and private 
contracts that they have performed within the past 3 years that are 
similar in nature to this solicitation.  The criteria for evaluating 
past performance set forth in the RFP include the offeror's record of 
conforming to contract requirements and to standards of good 
workmanship; the offeror's record of forecasting and controlling 
costs; the offeror's adherence to contract schedules; the offeror's 
history of reasonable and cooperative behavior and commitment to 
customer satisfaction; and, generally, the offeror's concern for the 
interest of the customer.  

In evaluating Oceaneering's past performance, the Navy reviewed 
Oceaneering's proposal and examined Oceaneering's award fee scores as 
the incumbent,[7] after determining that the award fee criteria used 
by the Navy under the past contract were essentially equivalent to 
this solicitation's criteria for assessing past performance.  The TERP 
concluded that Oceaneering's performance under the prior contract was 
neither exceptional nor deficient, and that its performance 
demonstrated neither strengths nor weaknesses.  As noted above, the 
rating scheme employed by the agency prescribed a rating of "good" to 
reflect a proposal that was "adequately sufficient" with "no 
indications of exceptional features . . . or contrarily, weaknesses."  
Thus, under the Navy's rating plan, Oceaneering's past performance
was given a score of 8.4, which was the highest possible score under a 
"good"  rating.[8]

On the other hand, Phoenix Marine, a new corporation, had no corporate 
experience.  The Federal Acquisition Streamlining Act of 1994, 41 
U.S.C.  sec.  405(j)(2) (1994), states:  "In the case of an offeror with 
respect to which there is no information on past contract performance 
. . . the offeror may not be evaluated favorably or unfavorably on the 
factor of past contract performance."  Similarly, the Federal 
Acquisition Regulations (FAR)  sec.  15.608(a)(2)(iii) (June 1997) provides 
that firms "lacking relevant past performance history shall receive a 
neutral evaluation for past performance."  Based on the narrative 
descriptions defining the adjectival ratings, the Navy assigned 
Phoenix Marine a score of 8, which was the midpoint score for an 
adjectival rating of "good."  The Navy explains that the description 
supporting a "good" rating--that is one that was "adequately 
sufficient" with neither strengths or weaknesses--most closely 
conformed to a neutral rating.

Oceaneering argues that both of these past performance evaluations are 
improper.  First, as to its own proposal evaluation, Oceaneering 
argues that its past performance merited a higher adjectival rating 
than that of a company with no past performance.  Oceaneering also 
argues that the award fee criteria under the prior contract differ 
from the past performance evaluation criteria described in the 
solicitation, and that the formula for calculating the award fee makes 
the translation of the award fee factor to the RFP evaluation's scheme 
impossible.  

As for Phoenix Marine's past performance evaluation, Oceaneering 
asserts that the Navy's evaluation lacks a rational basis.  
Oceaneering acknowledges that, because Phoenix Marine has no corporate 
history, it was entitled to a "neutral" score; however, Oceaneering 
questions the Navy's determination that a neutral score equates to a 
"good" rating, arguing that such an evaluation "flies in the face of 
the ordinary meanings of the terms 'good' and 'neutral.'" 

The evaluation of technical proposals is a matter within the 
discretion of the contracting agency since that agency is responsible 
for defining its needs and the best method of accommodating them.  
Mesa, Inc., B-254730, Jan. 10, 1994, 94-1 CPD  para.  62 at 5.  In reviewing 
an agency's technical evaluation, we will not reevaluate the 
proposals; rather, we will examine the record to ensure that the 
evaluation was reasonable and consistent with the RFP evaluation 
criteria.  Id.  A protester's disagreement with the agency's judgment, 
standing alone, is not sufficient to establish that the agency acted 
unreasonably.  Ionsep Corp., Inc., B-255122, Feb. 10, 1994, 94-1 CPD  para.  
97 at 3.  

Here, we find no merit in Oceaneering's contention that the evaluation 
of its past performance was improper.  Oceaneering has not shown that 
the agency unreasonably determined that its past performance 
demonstrated neither strengths nor weaknesses.  Regarding the criteria 
on which the Navy relied, our review of the record shows that the 
RFP's past performance criteria and the award fee criteria under the 
prior contract are basically identical.  As the Navy points out, 
quality of performance under the award fee criteria encompasses the 
offeror's record of conforming to contract requirements and the 
standards of good workmanship; cost performance under the award fee 
equates to the offeror's record of controlling costs; and, timeliness 
equates to adherence to contract schedules.  The past performance 
criterion of reasonable and cooperative behavior and customer 
satisfaction and concern for the customer are not, as the protester 
suggests, isolated criteria, but can be reasonably viewed as being 
part of all the other criteria concerning performance and quality.

As to the use of the award fee scores, we note that award fee 
determinations are one indicator of successful performance and, thus, 
it was reasonable for the agency to consider award fee determinations 
in its evaluation of past performance.[9]  In any event, as noted 
above, the agency evaluators reviewed the protester's past performance 
information and independently determined that Oceaneering's past 
performance reflected neither strengths nor weaknesses.  Under these 
circumstances, we see nothing unreasonable in the agency's evaluation 
of Oceaneering's past performance.  
 
We also see no basis to question the agency's evaluation of Phoenix 
Marine's proposal with regard to past performance.  As discussed 
above, the agency concluded that the narrative description of a "good" 
rating--that is, "adequately sufficient" with no strengths or 
weaknesses--most accurately reflected the regulatory requirement for a 
"neutral" rating.  We find that the agency reasonably equated a lack 
of past performance history with a past performance history that was 
neutral, in the sense that it was neither positive nor negative.  It 
is reasonable for an agency, as the Navy did here, to treat an offeror 
without past performance information as equivalent to one with past 
performance that was marked neither by strengths nor by 
weaknesses.[10]  In concluding that this is what the Navy did here, we 
rely on the underlying substantive definition of the ratings, rather 
than the connotation of the label attached to the definition (since 
the underlying definition is, we agree, at odds with the "good" 
label).  In sum, we find that the Navy reasonably evaluated Phoenix 
Marine's past performance.

Project Manager

Oceaneering next complains that the agency improperly evaluated the 
skills and experience of its proposed project manager and alleges that 
the evaluation was biased.  We have reviewed the evaluation record and 
Oceaneering's proposal, including the resume submitted by 
Oceaneering's proposed project manager, and we conclude that the 
evaluation was reasonable and consistent with the RFP.

The solicitation listed two desired qualifications for the project 
manager:  (1) undergraduate degree in science, engineering, or 
business and (2) 8 years of experience with responsibility for the 
management of marine-related operations.  

Oceaneering alleges that the agency improperly treated desired 
qualifications in education and experiences as if they were mandatory 
and therefore downgraded its proposed project manager for failing to 
meet them.  Oceaneering also notes that the experience at issue was to 
be in "the management of marine-related operations," complaining that 
the agency interpreted this management more narrowly to mean only 
"project manager" experience.  The protester claims that its proposed 
project manager served as the project manager for Oceaneering's 
current contract since July 1995 and as project manager for a 
Department of Transportation and Coast Guard contract in 1994 and 
1995.  Additionally, Oceaneering asserts that its proposed project 
manager managed two 12-person inspection teams from 1991 through 1993 
and directed diving crews for another firm from 1988 to 1991.  The 
protester contends that this experience totals more than the desired 8 
years of "management of marine-related operations."

Because its proposed manager was rated "marginal," Oceaneering also 
argues that the evaluation was biased.  Oceaneering maintains that one 
of the evaluators  retaliated against the firm in his evaluation of 
Oceaneering's proposed project manager because the evaluator was 
allegedly removed from working on Oceaneering's prior contract at the 
request of the proposed manager.
  
As noted above, the RFP listed desired qualifications without stating 
that these qualifications were mandatory; thus, the RFP clearly 
advised offerors of the specific skills and experience the Navy 
sought.  While a candidate who did not possess the desired 
qualifications was acceptable, offerors were clearly on notice that 
such a candidate could be scored lower than a candidate with the 
desired credentials. 

Here, the agency did not reject Oceaneering's proposed project manager 
as "unacceptable," but rather rated him "marginal," primarily because 
he did not demonstrate that he had 8 years experience in the 
management of marine-related operations.  Specifically, based on the 
resume submitted, the agency found that Oceaneering's proposed program 
manager had 2 years management experience on Oceaneering's current 
contract.  However, rather than the claimed 2 years of management 
experience for work with the Department of Transportation and the 
Coast Guard, the proposed project manager's resume, in fact, indicated 
that his work was sporadic and amounted to only 9 months of actual 
management experience.  Similarly, the proposed program manager's 
management of 12-person inspection teams reflected a 7-month effort, 
rather than the 2 years claimed by the protester.  As to Oceaneering's 
assertion that its proposed manager "directed diving crews" for 
another firm from 1988 to 1991, the proposed project manager's resume 
stated that he was an "Ocean Engineer/Diver" providing "engineering 
and program management support."  In sum, the Navy determined that 
Oceaneering's proposed project manager had a maximum of 6 years and 8 
months of management experience.  Based on our review of the record, 
we see no basis to question the Navy's determinations.

Regarding the allegation of bias, the protester must provide credible 
evidence showing bias and demonstrate that agency bias unfairly 
affected the protester's competitive position.  ASI Personnel Serv., 
Inc., B-258537.7, June 14, 1995, 95-2 CPD  para.  44 at 7.  Our Office will 
not attribute unfair or prejudicial motives to procurement officials 
on the basis of inference or supposition.  Id.  Here, as noted above, 
the agency reasonably downgraded the proposed project manager for lack 
of the desired experience.  Accordingly, Oceaneering's allegation of 
bias is without merit.  
 
Equipment and Facilities

Oceaneering next argues that the evaluation of Phoenix Marine's 
equipment and facilities was flawed.   Because Phoenix Marine does not 
own as much of its own equipment and facilities as does Oceaneering, 
the protester argues that Phoenix Marine should not have been as 
highly rated under this factor as Oceaneering.  

The RFP required that the contractor provide (1) the equipment and 
facilities to perform the qualification welding required under the 
solicitation; (2) 1,000 square feet of enclosed warehouse controlled 
access storage for government-furnished equipment; (3) an open tank 
for conducting wet welding trials in seawater; and, (4) a hyperbaric 
chamber suitable for conducting dry-chamber welds.  Additionally, 
Schedule D of the RFP listed minimum requirements for diving 
equipment.

In its proposal, Phoenix Marine stated that it would purchase or 
subcontract for the required equipment and provide facilities through 
leasing arrangements.  Specifically, Phoenix Marine proposed to meet 
the open tank requirement by either constructing a tank [DELETED] or 
subcontracting [DELETED].  Phoenix Marine also provided that it would 
subcontract for [DELETED], lease facilities [DELETED], and purchase 
much of the diving equipment listed on Schedule D.  With its proposal 
Phoenix Marine provided letters of commitment to subcontract for 
existing equipment.  Accordingly, the TERP determined that Phoenix 
Marine's proposal had no weaknesses and assigned the proposal an 
"excellent" rating.

The agency acknowledged in Oceaneering's debriefing that current 
ownership of the equipment and facilities by the prime contractor was 
beneficial to the agency and, noted that it had awarded Oceaneering 
higher numerical scores than Phoenix Marine because the protester owns 
the required equipment and facilities.  However, the RFP did not 
require ownership of the equipment and facilities, and Phoenix 
Marine's proposal to purchase, lease, or subcontract for the required 
equipment and facilities was permissible.  The protester points to 
nothing but general disagreement with the agency's assessment to 
support its position.   On this record, we have no basis to question 
the agency's determination.  

Failure to Follow Evaluation Scheme

Oceaneering also alleges that one of the three members of the TERP 
failed to follow the evaluation scheme outlined in the RFP.  The 
protester bases this allegation on a memo written by this evaluator, 
and the fact that this evaluator's scores were generally lower than 
the scores of the other evaluators.  The memo, which was part of the 
member's evaluation sheets, states, in relevant part, that the rating 
adjectives "are weighted far too heavily on the 'good' side" since a 
subfactor which merely meets the criterion but does not exceed the 
criteria must be rated as "good" and, even if weaknesses are apparent, 
must be rated as "acceptable."  
 
The protester argues that this evaluator "clearly scored according to 
his own evaluation scheme."  We disagree.  Individual evaluators may 
not agree on all aspects of an evaluation, and an expression of 
disagreement with some aspects of an evaluation does not mean that the 
evaluator failed to follow the evaluation scheme outlined in the 
solicitation.  Roy F. Weston, Inc., B-274945 et al., 
Jan. 15, 1997, 97-1 CPD  para.  92 at 4 n.7; Stat-a-Matrix, Inc. et al., 
B-234141 et al., 
May 17, 1989, 89-1 CPD  para.  472 at 6.

Here, while the memo on which the protester relies suggests that the 
evaluator believed the adjectival ratings were overly generous, the 
memo does not support the protester's contention that the evaluator 
refused to follow the RFP evaluation scheme.  Rather, the memo 
outlines how the evaluator evaluated the proposals within the 
parameters of the RFP's evaluation criteria.  Specifically, the first 
paragraph of the memo explains that the evaluator evaluated "the 
specific qualifications of the individual person or item being 
reviewed and compares the qualifications against the requirements put 
forth in the RFP."  We have reviewed the scores and do not find them 
unreasonable.  More importantly, it is clear that the evaluator 
applied the same standards to both Oceaneering's and Phoenix Marine's 
proposals.  On this record, we find no merit in this portion of the 
protest.   
 
Definitive Responsibility Criteria

Finally, Oceaneering protests that Phoenix Marine is ineligible for 
award because it failed to meet what Oceaneering asserts was a 
definitive responsibility criterion.  In this regard, section L of the 
solicitation provides as follows: 

     The offeror will need the financial capability to simultaneously 
     conduct two or more underwater operations.  It is estimated that 
     a single operation can cost as little as $20,000 or as much as 
     $2,000,000.  The offeror will need the financial resources or 
     credit line to absorb these costs for a reasonable period after 
     initiation of the operation.  Accordingly, upon written notice 
     from the Contracting Officer, the Offeror shall furnish all 
     information necessary for the Contracting Officer to determine 
     the financial responsibility of the Offeror. 

Oceaneering alleges that this RFP provision required offerors to 
demonstrate current funds or a credit line totaling $2,000,000, and 
that Phoenix Marine provided documentation showing only an approved 
line of credit of [DELETED] and commitments for funds by two Phoenix 
Marine officers totaling [DELETED].  Oceaneering argues that, because 
Phoenix Marine did not demonstrates an ability to produce $2,000,000, 
it should have been eliminated from award consideration.

A definitive responsibility criterion is a specific and objective 
standard established by an agency for use in a particular procurement 
to measure a offeror's ability to perform the contract.  See M&M 
Welding & Fabricators, Inc.--Recon., B-271750.2, Mar. 26, 1997, 97-1 
CPD  para.  124 at 2.  These special standards of responsibility limit the 
class of offerors to those meeting specified qualitative and 
quantitative qualifications necessary for adequate contract 
performance.  Id.  Here, the requirement that offerors have the 
financial capability to fund operations for a limited time period does 
not set out a specific, objective standard measuring the offeror's 
ability to perform; rather, the provision expresses in general terms a 
factor which is encompassed by the contracting officer's subjective 
responsibility determination.  Our Bid Protest Regulations preclude us 
from reviewing a contracting officer's affirmative responsibility 
determination absent a showing of
possible bad faith on the part of government officials or that a 
definitive responsibility criterion was not met.  4 C.F.R.  sec.  21.5(c) 
(1997).  Since these circumstances are not present here, we will not 
consider Oceaneering's allegations.[11]

The protest is denied.  

Comptroller General
of the United States
 
1. Oceaneering also alleges that Phoenix Marine is ineligible for 
award because it improperly obtained Oceaneering's proposal 
information before the award of the contract in violation of the 
Procurement Integrity Act, 41 U.S.C.  sec.  423 (1994).  Specifically, 
Oceaneering protests that several of its key employees who played 
significant roles in the development of Oceaneering's proposal were 
also involved, without Oceaneering's knowledge, in the preparation of 
Phoenix Marine's proposal.  Thus, Oceaneering maintains that Phoenix 
Marine improperly obtained proprietary information concerning 
Oceaneering's proposal and used that information to Oceaneering's 
detriment in the competition. 

In response to these allegations, the Navy conducted an investigation 
and concluded that the allegations were unsupported by Oceaneering.  
However, the Navy advises that, because of the severity of the charges 
and the conflicting testimony offered, the agency requested that the 
Navy's Inspector General investigate further.  We have contacted the 
Navy's Office of Inspector General and confirmed that it is actively 
investigating the allegations.  In view of the Inspector General's 
ongoing investigation, we are dismissing the protest issues under 
investigation, pending completion of the Inspector General's 
investigation.  See Hazeltine Corp., B-235239, June 22, 1989, 89-1 CPD  para.  
592 at 3; Usatrex Int'l, Inc., B-231815.4, Oct. 31, 1988, 88-2 CPD  para.  
413 at 2.  Upon completion of the investigation, the protester may 
reinstate its protest regarding these issues.   

2."NDT" refers to Nondestructive Testing.

3. Oceaneering, the incumbent, has been the prime contractor for these 
services for most of the past 20 years; Phoenix Marine is a newly 
incorporated company.

4. An initial TERP evaluation was completed in April.  However, this 
panel had difficulty confirming the scores assigned and, while it was 
in the process of reaching consensus and preparing a final report, two 
members became unavailable for continued service.  Thus, two new 
members were assigned to the TERP.  New members were not shown the 
draft report of the initial TERP.  The newly-constituted TERP 
completed a reevaluation of the proposals on July 1, which is the 
evaluation at issue in the protest. 

5. The adjectival ratings were defined in detail.  For example, an 
adjectival rating of "good" was described as follows:

            The offeror's proposal is adequately sufficient with no 
            major weaknesses . . . .  [A]ny weaknesses noted are of a 
            minor 
            nature . . . .  A rating within GOOD is used when there 
            are no indications of exceptional features that could 
            prove beneficial,
            or contrarily, weaknesses which may diminish the quality 
            of 
            the Offeror's performance . . . .

An "acceptable" rating was described as:

            The offeror's proposal is minimally sufficient . . . .  
            [T]here are many areas for improvement . . . .  
            [I]ndicated weaknesses would diminish the quality of the 
            Offeror's performance . . . . 

6. In its initial protest, Oceaneering also challenged the evaluation 
of other personnel and the agency's cost analysis.  The Navy fully 
responded to these issues in its report, but the protester failed to 
rebut the agency's response in its comments.  Therefore, we consider 
these issues to have been abandoned by the protester and we will not 
consider them.  Analex Space Sys., Inc., PAI Corp., B-259024, 
B-259024.2, Feb. 21, 1995, 95-1 CPD  para.  106 at 8-9.  

7. While Oceaneering submitted information on a number of past 
contracts, both the Navy and Oceaneering considered Oceaneering's 
performance as the incumbent to be its most relevant experience.

8. In assessing a score of 8.4, the Navy also considered Oceaneering's 
award fee scores for delivery orders completed by Oceaneering during 
the prior 3 years.  Oceaneering's average award fee score for the past 
3 years was 8.4.

9. Oceaneering, in its proposal, used its final award fee score to 
support its past performance.

10. It would seem preferable to advise offerors in the solicitation, 
in more detail than was done here, regarding the way in which the 
agency would implement the mandate for a neutral rating for offerors 
lacking past performance information.

11. In any event, the protester misreads the requirement.  The RFP 
does not require, as Oceaneering alleges, that an offeror must be able 
to obtain $2,000,000.  While the RFP does state that an operation may 
cost as much as $2,000,000, the solicitation specifically states that 
an offeror needs only the financial resources to absorb the cost of 
two or more operations for a reasonable period after initiation of the 
operation.  According to the agency, a reasonable period that an 
offeror would be required to finance would be approximately two 
months, not the entire period of the largest single operation.