BNUMBER:  B-278260.2 
DATE:  February 25, 1998
TITLE: Davies Rail and Mechanical Works, Inc., B-278260.2, February
25, 1998
**********************************************************************

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:Davies Rail and Mechanical Works, Inc.

File:     B-278260.2

Date:February 25, 1998

Sam Zalman Gdanski, Esq., and Jeffrey Gdanski, Esq., for the 
protester. 
George N. Brezna, Esq., Lis B. Young, Esq., and Kenneth M. Homick, 
Esq., Department of the Navy, for the agency.
Jacqueline Maeder, Esq., and Paul Lieberman, Esq., Office of the 
General Counsel, GAO, participated in the preparation of the decision.

DIGEST

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.

DECISION

Davies Rail and Mechanical Works, Inc. protests the award of a 
contract to Ederer, Inc. under request for proposals (RFP) No. 
N62472-97-R-1641, issued by the Department of the Navy, Navy Crane 
Center (NCC) for certain overhead electric traveling (OET) cranes.  
Davies contends that the proposals were not evaluated properly and 
that in making its best value determination, the agency failed to take 
into account all of the appropriate considerations.

We deny the protest.

The solicitation, issued May 22, 1997, contemplated the award of a 
fixed-price contract to design, fabricate, assemble, test, deliver, 
and install one 100-ton main hoist with a 50-ton auxiliary hoist OET 
crane, with an option for a 50-ton main hoist with a 10-ton auxiliary 
hoist OET crane.  Both cranes are to be installed at Norfolk Naval 
Shipyard, Norfolk, Virginia.  

Section M-1 of the RFP provided for award to the offeror whose 
proposal was determined to represent the best value to the government, 
price and other factors considered.  Section M-4 identified technical 
evaluation factors and subfactors as follows:

     1.  TECHNICAL APPROACH composed of the following five elements:  

        a.Describe your technical approach for meeting the required
          maximum wheel loads and minimum wheel spacings set
          forth in the specification.

        b.Describe the general procedures your company uses in
          designing cranes.  Provide the names and experience resumes 
          of the structural, mechanical and electrical engineers, who 
          will be involved in the design of these cranes. . . .  How 
does
          your company ensure that your designs are fully coordinated
          among the disciplines.  Provide the name, registration and
          background experience for each professional engineer 
responsible
          for the design of the cranes called for by the solicitation.

        c.Provide a description of your plant (capacity, location, 
etc.) and 
          the special facilities (paint facilities, calibration 
equipment, 
          cutting tables, cranes, etc.) available.

        d.Describe how the crane will be erected/installed.

        e.Describe your quality assurance system.

     2.  MANAGEMENT PLAN composed of the following elements:

        a.Describe your proposed schedule and milestones for 
completing
          this work within the timeframes set forth in this 
solicitation.
          Include in your description the scheduling method you plan 
to
          use to manage this project and a sample of a schedule used
          on a project of similar magnitude and complexity completed
          within the last three (3) years. 

        b.Provide resumes for the Project Manager, Lead Design 
Engineer,
          Quality Control Manager, Plant Superintendent and Field
          Superintendent, who will be assigned to this project.

     3.  CORPORATE EXPERIENCE

          List at least five (5) previous projects that were worked on 
          within the past five (5) years that demonstrate your ability 
          to design, manufacture, install and test cranes of a similar
          capacity and complexity as this project.  Provide phone 
numbers
          and points of contact for each project.  If subcontractors 
will be
          used, provide similar past experience data for the 
subcontractor.
          In addition, describe the projects on which you have worked
          together in the past.

Section M-4 advised that technical factors and price would be weighted 
equally and that the three technical factors and the subfactors of 
each factor would also be weighted equally with respect to each other.   
For award purposes, section M-1 provided that price would be evaluated 
by adding the total price for the option to the total price for the 
base requirement, but that evaluation of the option would not obligate 
the government to exercise the option.    

Eight proposals, including those of Davies and Ederer, were received 
by the June 24  closing date.  The proposals were evaluated by a 
source selection board (SSB), comprised of a technical evaluation 
board (TEB), which reviewed the technical proposals, and a price 
evaluation board, which evaluated the price information.  The 
technical ratings for the proposals at issue were as follows:

        Technical Approach Management Plan   Corporate Experience

Davies  Acceptable         Acceptable        Acceptable

Ederer  Outstanding        Acceptable        Acceptable
Both the Davies and Ederer proposals were rated "acceptable" overall, 
with the Ederer proposal ranked "first" because of its "outstanding" 
rating under technical approach.  Specifically, the TEB noted that 
Ederer had provided extensive information beyond what the solicitation 
required explaining how it proposed to meet the wheel load 
specifications for both cranes.  Also, the TEB noted that Ederer's 
in-house design staff was well qualified, Ederer had sufficient plant 
capacity to perform all of the work in-house, it had provided detailed 
information on crane erection/installation procedures, and its quality 
assurance plan met the requirements of the solicitation.

The TEB indicated that Davies's proposal provided sufficient 
information concerning how it proposed to meet the crane wheel loads 
and the offeror's in-house design staff and its proposed 
subcontractors were qualified.  The TEB noted that Davies did not have 
the plant capacity to manufacture either crane in-house and it 
proposed to subcontract the majority of the work.  While the TEB 
concluded that the multiple subcontracting proposed by Davies was a 
concern and presented a risk because the number of subcontractors 
would increase the amount of coordination required and increase the 
difficulty of resolving any post-acceptance problems, Davies's 
proposal was evaluated as technically acceptable.

Based on the technical and price evaluations, three proposals, 
including those of Davies and Ederer, were determined to be in the 
competitive range.  Written discussions, focused on price concerns, 
were conducted with these three offerors.   No technical questions 
were raised in discussions because the proposals were evaluated as 
fully acceptable and the proposed approaches of the offerors showed 
that they understood the difficulties in meeting the specifications 
and had provided alternatives to overcome the anticipated design 
problems.  In addition, exact weights could not be resolved until 
after the awardee submitted a crane design to the agency for approval.  
Best and final offers (BAFO) were requested and received from Davies 
and Ederer on September 15.[1]   Both offerors reduced their prices in 
their BAFOs and the technical evaluations remained unchanged.[2]   

The SSB recommended that award be made to Ederer because both 
proposals were evaluated as technically acceptable and Ederer offered 
the lower price.[3]  The source selection authority agreed with the 
recommendation and award for the 100-tone crane was made to Ederer on 
September 23 in the amount of $1,759,794.[4]  Upon learning of the 
award, Davies filed an agency-level protest.  Davies received a 
debriefing from the NCC on October 2 and filed this protest with our 
Office the following day.

Davies first challenges the agency's technical evaluation of both 
proposals, alleging, among other things, that Ederer's proposed 
100-ton crane does not conform to the RFP requirements concerning 
wheel loads and that the NCC improperly applied an unstated evaluation 
criterion in its evaluation of the protester's proposal.   

The evaluation of technical proposals is a matter within the 
contracting agency's discretion since the agency is responsible for 
defining its needs and the best method of accommodating them.  Loral 
Sys. Co., B-270755, Apr. 17, 1996, 96-1 CPD  para.  241 at 5.  In reviewing 
an agency's technical evaluation, we will not reevaluate the proposal, 
but will examine the record of the evaluation to ensure that it was 
reasonable and in accordance with stated evaluation criteria, and not 
in violation of procurement laws and regulations.  Id.  The protester 
bears the burden of proving that an evaluation is unreasonable; mere 
disagreement with the agency does not render the evaluation 
unreasonable.  Ogden Support Servs., Inc., B-270354.2, Oct. 29, 1996, 
97-1 CPD  para.  135 at 3.  Here, as discussed below, the record provides no 
basis to call into question the propriety of the agency's evaluation.  

WHEEL LOADS

The RFP required each offeror to describe its technical approach to 
meeting the maximum permitted wheel load and minimum wheel spacing 
specified in the solicitation.[5]  In response to a question 
concerning required wheel loads, the NCC, in amendment No. 0001, 
stated that it wanted "a general idea" of how each offeror intended to 
meet the allowable wheel load and spacing requirements.  The agency 
explains that it knew that the wheel load requirement would be 
difficult to meet for the crane as specified, and it believed that if 
the calculated wheel loads submitted in the proposals were too high, 
there were different approaches that could be taken to reduce the 
wheel loads.  It was for this reason that amendment No. 0001 specified 
that the agency sought only a "general idea" of how an offeror 
intended to meet the wheel load requirement, which would enable the 
agency to determine if the offeror understood the wheel load problems 
and could adapt its design to meet the requirements.    

Ederer provided initial calculations in its proposal which show a 
wheel load of [DELETED] pounds, versus the 78,350 pound permitted 
maximum.  Ederer indicated that it could not state at the time it 
prepared its proposal that it had a solution for the 100/50-ton crane 
wheel loading requirement, but Ederer listed a number of possible 
solutions to meet the required wheel load, including [DELETED], and 
stated that "if [NCC] work[s] with us, we can find a solution."   As 
noted above, the agency evaluated Ederer's proposed approach as 
clearly indicating an understanding of the problem and, based on the 
response, including the calculations Ederer submitted, as going beyond 
what was required by the RFP.

Davies argues that Ederer's proposal does not conform to the 
solicitation wheel load requirement.  The protester contends that the 
RFP clearly states the wheel load requirement and does not, as the 
agency contends, "merely [require] the offeror to state his 
understanding of wheel loads, and possible solutions to the problems."  
The protester argues that the agency's request for a "general idea" 
simply means that, while offerors need not provide in their proposals 
the exact calculations of how the proposal would meet the maximum 
wheel loads, offerors were still required to show compliance with the 
maximum loads.  Because Ederer's proposal did not state that it would 
conform to the solicitation, the protester argues that Ederer's 
proposal should have been found technically unacceptable.  

A solicitation must be read as a whole and in a reasonable manner, 
giving effect to all its provisions.  Kerry Lindahl, B-276057, May 7, 
1997, 97-1 CPD  para.  165 at 6.  Here, the RFP specified a wheel load but 
required only a description of the offeror's approach for meeting that 
requirement, and amendment No. 0001 clarified that all that was 
required was a "general idea" of what the offeror would do to meet the 
specified wheel load.  The overall effect of these provisions is that 
an offeror was only required to explain its approach to meeting the 
specified wheel load in the form of a general, preliminary plan, which 
would be adjusted as necessary once a crane design was finalized.  
Davies's position that Ederer's proposal cannot be accepted because it 
fails to evidence precise satisfaction of a solicitation requirement 
reflects an unreasonably narrow reading of the RFP specifications.  In 
this regard, while Ederer's proposal recognizes that its proposed 
design does not conform, as permitted by the solicitation, Ederer 
explains how it plans to adjust its design to meet the specific 
requirement.

As NCC points out in its report, wheel load cannot be calculated until 
the final weight of the crane is known.  The weight will not be known 
until a design is submitted by the contractor and approved by the 
agency.  In this regard, the solicitation stated that the crane design 
would be submitted for government review and that the offeror's 
personnel would meet with government engineers to resolve any 
noncompliance with the crane specifications.  It is essentially for 
this reason that the agency did not believe that it would be 
productive to conduct discussions with any offeror regarding precisely 
how it would satisfy the wheel load requirement.  That is, once the 
agency was satisfied that the offeror's approach showed sufficient 
understanding of what was required to achieve the wheel load 
requirement, no useful purpose would be served in discussing details 
until after the agency review session was conducted with the awardee.  
In sum, the agency reasonably evaluated Ederer's proposal as 
technically acceptable with respect to the proposed approach to 
meeting the specified wheel load.     

Moreover, while Davies asserts that its proposal demonstrated 
compliance with the wheel load specifications, in fact, there are 
inconsistencies in Davies's proposal and it provides no basis to 
conclude that Davies was offering a compliant design.  At section 
1.A.1 of its proposal, Davies makes the blanket statement that the 
maximum wheel load of its 100-ton crane will be 78,350 pounds.  
However, Davies does not provide wheel load calculations to verify 
compliance; instead, the proposal at section 1.A.1 states that the 
"maximum allowed wheel load is approached if the  trolley dead load is 
65,000 lbs.  And the bridge dead load is 130,000 lbs.  Our preliminary 
estimate dead loads are very close to these upper bound dead loads."

Additionally, at section 1.B of its proposal, Davies included a 
document titled "Travel Drive Analysis" in a plastic pocket envelope 
with scaled drawings of its proposed crane, which included weights for 
the trolley dead load and the bridge dead load.  While the agency 
states that it used the information provided by Davies at section 
1.A.1 in evaluating the proposals,[6] in response to the protest, the 
agency used the weights provided in the Travel Drive Analysis document 
to calculate the protester's proposed wheel loads.  Based on the 
weights provided in the Travel Drive Analysis document, the 
protester's proposed wheel loads were also higher than the maximum 
permitted 78,350 pounds.  The agency asserts that the weights given in 
the Travel Drive Analysis document provide an appropriate basis to 
calculate the wheel loads because that document was packaged with 
Davies's preliminary drawing for the 100-ton crane and the two 
appeared to go "hand in hand."  

Our Office conducted a telephonic hearing at which witnesses for the 
protester and the agency testified concerning the agency's evaluation 
of proposals with respect to the wheel load requirement.  The 
protester conceded during the hearing that it could not tell whether 
the Travel Drive Analysis document was, in fact, included with its 
proposal.  The protester argues that even if the document was included 
in the proposal, the agency should have known from its "7-26-1996" 
date that the document and the figures on it were related to a 
previous solicitation and not relevant here.  Additionally, the 
protester argues that the Travel Drive Analysis document is 
incomplete, containing only inputs and that the agency should have 
recognized that the document was incomplete and did not provide a 
basis for calculating the proposed wheel load.    

We disagree that the date notation alone establishes that the Travel 
Drive Analysis document was not related to this proposal, especially 
where, as here, the agency reports that the document was contained in 
the plastic pocket with Davies's scaled drawing of its proposed 
100-ton crane.  As to the protester's suggestion that the agency 
should have recognized that the document was incomplete and discussed 
this with the protester, as noted above, the agency used the document 
to calculate wheel loads based on the figures in this document only 
after the protest was filed.  During evaluation, the proposal was 
considered acceptable on the basis that the approach proposed was 
compliant.  Thus, there was no reason to seek clarification in this 
regard during discussions.    

Where a proposal contains conflicting provisions which call that offer 
of compliance into question, the offer is ambiguous.  TRS Research, 
B-274845, Jan. 7, 1997, 97-1 CPD  para.  6 at 3.  Here, the protester 
submitted two possible sets of proposed figures.  One set, provided at 
section 1.A.1 of the protester's proposal apparently meets the 
requirement.  The second set of figures does not meet the wheel load 
requirement.  Thus, Davies's proposal did not provide the exact 
equipment weights and calculations to demonstrate compliance.  Because 
the agency was seeking only a satisfactory approach to achieving the 
specified wheel loads, rather than a fully compliant design, it 
reasonably evaluated both proposals as satisfactory with respect to 
the load requirement, consistent with the amended RFP.   Davies could 
not have been prejudiced by this approach because, under its 
interpretation of the RFP requirements, neither proposal could have 
been evaluated as technically acceptable.  

Davies makes numerous other allegations of unreasonable assessments of 
specific aspects of Ederer's proposal, including, for example, that 
the agency unreasonably evaluated Ederer's proposal as to design 
procedures, plant description, crane installation, subcontractors, and 
personnel.  The protester also alleges that the award to Ederer does 
not represent the best value to the government.  While we will not 
discuss all of Davies's allegations, we have reviewed them all and, as 
illustrated by the following examples, we find that the record 
supports the agency's technical evaluation of the proposals and its 
award determination. 

As quoted above, the RFP evaluation criteria call for offerors to 
describe their general design procedures, their plant, how the crane 
will be erected/installed, and their subcontractors and personnel.  
Both Davies and Ederer received generally acceptable ratings on these 
factors, with the TEB noting that each proposal met the requirements 
for each subfactor.  Davies argues that Ederer's proposal was too 
highly rated on each of these subfactors.  For example, Davies argues 
that it provided more specific design procedures than Ederer and, 
therefore, the two proposals should not have received identical 
ratings.

The record shows that Ederer provided a 13-step description of its 
work flow and organization, which specified, among other things, 
specification review, preliminary and final design, establishment of a 
job/project schedule, identification/assignment of personnel, 
manufacturing, inspection, testing, and installation.  Davies provided 
a two-page description of its procedures and a design process flow 
chart, including such topics as gathering information, analysis, 
preliminary design, test preliminary design, and detail design 
(manufacturability, availability, materials/components and 
reliability).  The agency acknowledges that Davies's procedures may be 
more detailed, but points out that the RFP sought only a description 
of general procedures.  Thus, the agency argues, and we agree, that 
Ederer provided a suitable response, with sufficient information for 
the agency to find the proposal acceptable.  Davies's disagreement 
with this evaluation does not make it unreasonable.

Similarly, Davies argues that Ederer's description of its plant was 
insufficient.  The record shows that Ederer, while providing little 
general information about its plant, did indicate its production and 
plant capabilities by listing previous work.  For example, Ederer 
indicated that it had produced cranes up to [DELETED]-ton capacity, a 
[DELETED]-foot span and a [DELETED]-foot lift.  Based on this 
information, the agency reasonably concluded that Ederer's plant was 
acceptable.

As to crane erection/installation, Davies contends that Ederer's plan 
for the 100-ton crane is not feasible because it proposes to use two 
[DELETED] cranes to lift girders and other equipment and parts.  
Davies believes these cranes are too big for the available space.  In 
this regard, the agency notes that, while the floor plan may appear 
too congested for cranes of this size, any erection problems are 
typically resolved during pre-installation meetings when the 
contractor can arrange to temporarily relocate interfering equipment.  
In any event, Davies also proposed to use two large cranes ([DELETED]) 
for crane installation.  While the protester offers a different 
approach and maintains that Ederer's cranes are too large, the 
protester's judgment regarding the feasibility of Ederer's 
installation plans does not establish that the agency's assessment was 
unreasonable.

Davies also alleges that, while Ederer provided resumes for its 
personnel, it did not identify which employees would serve as project 
manager, lead design engineer, quality control manager, plant 
superintendent, and field superintendent, as required by the RFP.  In 
fact, the RFP did not require letters of commitment or any other fixed 
designations for these positions.  Rather, the evaluation language in 
question calls for the offeror to provide resumes for qualified 
individuals for these positions.  Ederer provided nine resumes, 
indicating that all but one of its employees had 28 or more years 
experience.  The resumes also identified Ederer's project manager, 
structural engineer, mechanical engineers, electrical engineers, 
quality assurance manager, and plant superintendent.  The awardee did 
not specifically identify its field superintendent or its lead 
engineer.  However, NCC did not regard this as a problem because the 
resumes submitted indicated that several of Ederer's [DELETED] 
engineers qualified as lead engineer and that the program manager was 
also qualified to perform the duties of field superintendent.  Because 
the resumes establish that Ederer has sufficiently qualified 
individuals for these positions on its staff, the agency reasonably 
concluded that the required positions were covered.  We see nothing 
improper with this evaluation.

Davies complains that Ederer failed to identify and provide past 
experience data for any subcontractors that it planned to use.  Ederer 
plans to use two subcontractors, [DELETED].  Although Ederer did not 
identify these subcontractors or provide past experience data, its 
proposal was rated acceptable in this regard.  The agency explains 
that it did not believe that these subcontractors had to be addressed 
in the proposal because they are not involved in the major work 
required under the contract.  Specifically, transportation and 
erection were of significantly less concern to the agency than design 
and fabrication.  Further, the agency had specific knowledge that 
Ederer had successfully delivered cranes in the past, indicating to 
the agency that the awardee knew how to transport and erect them.  
Ederer had also submitted a detailed installation plan with its 
proposal.  In sum, the agency reasonably concluded that Ederer had 
adequately demonstrated its subcontractor capability, notwithstanding 
that Ederer did not list its shipping and installation subcontractors.   

UNSTATED EVALUATION CRITERION 

Davies also argues that the solicitation did not limit the 
subcontracting permitted under the contract and that the NCC 
improperly evaluated Davies's proposal for any risk that could be 
associated with subcontracting.  The protester argues that risk 
assessment is an unstated evaluation criterion, and that the agency 
should have raised this concern in discussions.  

First, we note that, even when risk is not specifically listed in the 
solicitation as an evaluation criterion, an agency is not precluded 
from considering any proposal risk arising from an offeror's approach 
or demonstrated lack of understanding that is intrinsic to the stated 
evaluation factors.  Ogden Support Servs., Inc., supra, at 7.  Here, 
the NCC reasonably concluded that Davies's use of subcontractors to 
perform the majority of the work required under the RFP represented an 
approach which, because of the fragmentation of services, presented 
greater risk for the agency.  In any event, Davies's acceptable rating 
under this factor did not have any effect on the award determination.  
That is, while Ederer's proposal received an outstanding assessment 
under this criterion, versus Davies's acceptable rating, the ratings 
for both proposals were otherwise equal and the two proposals were 
rated equally overall.  Even if Davies's proposal had earned an 
outstanding rating on technical approach, the proposal would have 
remained technically equal but higher priced than the awardee's, and 
Ederer's proposal would remain the best value.  Accordingly, Davies 
was not prejudiced by any possible shortcomings in this regard, and 
this objection provides no basis to sustain Davies's protest.  Lithos 
Restoration, Ltd., 71 Comp. Gen. 367, 371 (1992), 92-1 CPD  para.  379 at 
5-6.
 
BEST VALUE DETERMINATION

Finally, Davies argues that the award to Ederer at Ederer's total 
price of $3,110,624, does not represent the best value to the 
government.  Specifically, the protester offered an alternate offer 
with a discounted price of $3,000,192 for the award of both cranes 
simultaneously, and it offered an extended 18-month warranty on 
structural and mechanical components.[7]  Davies argues that the 
extended warranty has value to the government which was not taken into 
account in the best value determination.  

The RFP did not provide for offers based on the simultaneous award of 
the base and the option requirements.  Rather, the RFP stated that 
both base and option prices would be evaluated but that the evaluation 
of option prices would not obligate the government to exercise the 
option.  The agency is required to make award based solely on the 
factors included in the solicitation.  Department of State--Recon., 
B-243974.4, May 18, 1992, 92-1 CPD  para.  447 at 5.  Moreover, in addition 
to the fact that not all offerors were given the same opportunity to 
propose on this basis, at the time of award the agency did not have 
funds to make an award for the option.  Accordingly, there was no 
basis to consider this purported discount.  Similarly, Davies's 
extended warranty was not considered because it was not an evaluation 
factor and its consideration was not permitted for other offerors.  
Thus, contrary to Davies's assertion, its price was not lower than the 
awardee's price, and it was not denied evaluation credit for features 
for which it should have received credit.  Because the proposals were 
reasonably evaluated as technically equal and Ederer proposed a lower 
price than the protester, there is no basis to question the award 
determination.  

The protest is denied.

Comptroller General 
of the United States

1. The other firm included in the competitive range withdrew its offer 
during discussions.

2. Davies also submitted an alternate proposal which offered a 
3.6-percent price discount if the NCC awarded the base requirement and 
the option at the same time.  Because NCC did not have sufficient 
funds at the time of contract award to award both the base and the 
option and because Ederer had not been given an opportunity to provide 
an offer based on the simultaneous award of both the base and option, 
the agency did not consider Davies's alternate offer.

3. Ederer's total price for the base and option requirements was 
$3,110,624 ($1,759,794 for the base requirement and $1,350,830 for the 
option).  Davies's BAFO contained a total price entry of $3,112,232, 
which is the price NCC used in its evaluation.  In fact, Davies's base 
price is $1,713,215 and its option price is $1,437,240 thus its actual 
total price is $3,150,455.  

4. The option for the 50-ton crane was not included in the initial 
award because the agency needed approximately $250,000 in additional 
funds, and NCC had been advised on September 18 that it could lose 
over $1 million that had been set aside for the 50-ton crane.  
Additional funding subsequently became available, whereupon  NCC 
awarded the option to Ederer.

5."Wheel load" is the overall weight that the crane applies on the 
crane rail system in the building through the bridge wheels.  Several 
variables, such as crane weight and lifted load weight, may be 
combined and modified to determine the wheel load of a crane.  The 
maximum wheel load permitted in the solicitation is 78,350 pounds.

6. The Navy did not perform any precise wheel load calculations in 
evaluating the proposals.  

7. The RFP required a 12-month warranty.