BNUMBER:  B-278591 
DATE:  February 17, 1998
TITLE: Beneco Enterprises, Inc., B-278591, February 17, 1998
**********************************************************************

Matter of:Beneco Enterprises, Inc.

File:     B-278591

Date:February 17, 1998

Patrick S. Hendrickson, Esq., Kirton & McConkie, for the protester.
Marian E. Sullivan, Esq., Department of the Air Force, for the agency.
Glenn G. Wolcott, Esq., and Paul Lieberman, Esq., Office of the 
General Counsel, GAO, participated in the preparation of the decision.

DIGEST

Elimination of protester's proposal from competitive range is 
unobjectionable where agency reasonably determined that the proposal 
contained multiple deficiencies in three of five technical/management 
evaluation factors, including the two most important factors, as a 
result of which the proposal would require major revisions to meet the 
solicitation's minimum requirements. 

DECISION

Beneco Enterprises, Inc. protests the elimination of its proposal from 
the competitive range under request for proposals (RFP) No. 
FA4416-97-R-0015, issued by the Department of the Air Force as a 
Simplified Acquisition of Base Engineering Requirements (SABER) 
procurement for maintenance, repair, and minor construction work at 
various Air Force facilities in Maryland.  Beneco protests that the 
agency erroneously determined that Beneco's proposal was so deficient 
as not to have a reasonable chance of being selected for award. 
      
We deny the protest.

The RFP, issued by the Air Force on July 28, 1997, contemplated award 
of an indefinite delivery/indefinite quantity contract for a base 
period with four 1-year option periods.  The RFP provided that award 
would be made to the offeror whose proposal was most advantageous to 
the government, considering technical, management, and cost factors, 
with technical/management factors being of primary importance.  
Section M of the RFP listed the following technical/management 
evaluation factors in descending order of importance:  (1) project 
management ability; (2) project development/planning and minimal 
design; (3) subcontracting support capability; (4) experience and 
past/present performance; and (5) project execution and technical 
capability.[1]  Each evaluation factor and subfactor was to be rated 
on a color-coded scale[2] and assigned a risk rating.  The RFP advised 
offerors that proposals must demonstrate that the offeror has 
sufficient technical expertise, experience, and resources to perform 
the contract requirements, and is able to plan, organize, and use 
those resources in a coordinated and timely fashion, specifically 
noting that "[i]n no case shall words like 'we will comply with the 
requirements of the contract' or equivalent statements be acceptable 
to meet the requirements of the RFP."  

Several offerors, including Beneco, submitted initial proposals by the 
September 4 closing date.  Upon conducting an initial review, the 
agency identified numerous weaknesses and deficiencies in Beneco's 
proposal.  By letter telecopied to Beneco on October 13, the agency 
transmitted seven deficiency reports (DRs) and two clarification 
requests (CRs) related to specific portions of Beneco's proposal, 
advising Beneco, "You must explain and clarify questions and 
deficiencies on your proposal, in writing, via [f]acsimile not later 
than 5:00 PM, 14 Oct 97."[3] Beneco telecopied its responses to the 
agency at 11:16 a.m. the following day.   

Thereafter, the agency reevaluated Beneco's proposal taking into 
consideration Beneco's responses to the CRs and DRs, and concluded 
that Beneco's proposal still contained multiple weaknesses and 
deficiencies and that the proposal would require major revisions to 
meet the RFP's minimum requirements.  By memorandum dated October 20, 
the agency advised Beneco that its proposal had been eliminated from 
the competitive range.  Beneco subsequently requested a debriefing, 
which the agency conducted on November 6.  Beneco filed this protest 
on November 7.  

Beneco protests that the agency erred in determining that its proposal 
was so deficient as to have no reasonable chance of being selected for 
award and, therefore, that the agency improperly eliminated its 
proposal from the competitive range.  As discussed below, the record 
provides no basis to object to the agency's determination.[4]

Where a proposal is technically unacceptable as submitted and would 
require major revisions to become acceptable, the agency is not 
required to include the proposal in the competitive range.  Laboratory 
Sys. Servs., Inc., B-256323, June 10, 1994, 94-1 CPD  para.  359 at 2; see 
also Beneco Enters., Inc., 70 Comp. Gen. 574, 578 (1991), 91-1 CPD  para.  
595 at 6 (Beneco's proposal was properly eliminated from the 
competitive range in another SABER procurement for failing to 
demonstrate adequate understanding of solicitation requirements).  The 
evaluation of proposals and the determination of whether a proposal is 
in the competitive range are principally matters within the 
contracting agency's discretion, since agencies are responsible for 
defining their needs and for deciding the best method for meeting 
them.  In reviewing an agency's decision to eliminate a proposal from 
the competitive range, we will not evaluate the proposal anew, but 
instead will simply examine the agency's evaluation to ensure that it 
was reasonable and in accord with the provisions of the solicitation.  
Abt Assocs., Inc., B-237060.2, Feb. 26, 1990, 90-1 CPD  para.  223 at 3-4.  
A protester's mere disagreement with an agency's evaluation does not, 
without more, establish that the evaluation was unreasonable.  Keco 
Indus., Inc., B-261159, Aug. 25, 1995, 95-2 CPD  para.  85 at 4-5.    

With its report responding to Beneco's protest, the agency provided 
the evaluation record regarding the decision to eliminate Beneco's 
proposal from the competitive range.  The record shows that Beneco's 
proposal received ratings of "red/ unacceptable" under three of the 
five evaluation factors, including the most important factor, "project 
management ability," (where Beneco's proposal was rated 
"red/unacceptable" under three of the five subfactors), and the second 
most important evaluation factor, "project development," (where 
Beneco's proposal was rated "red/unacceptable" under both of two 
subfactors).  We have reviewed the record and find no basis to 
question the reasonableness of the agency's evaluation of Beneco's 
proposal.  

For example, regarding the most important evaluation factor, "project 
management ability,"  the RFP required that offerors include a quality 
control plan which would include the "number of active projects 
assigned to each quality control inspector."  Beneco's proposal did 
not respond to this requirement.  DR No. 2, transmitted to Beneco on 
October 13, stated, among other things:  "Offeror fails to describe 
the number of active projects that will be assigned to each Quality 
Control Inspector."  Beneco responded to this portion of the DR 
stating: 

     At this point, it is impossible to predict the number of jobs 
     that will be assigned to each quality control staff member.  The 
     number of jobs assigned is determined by a variety of factors, 
     including complexity of the job, size, and schedule. 

In short, Beneco expressly declined to provide specific, material 
information required by the RFP.  Accordingly, there is no basis to 
question the reasonableness of the agency's assessment of a 
"red/unacceptable" rating for this evaluation factor.

As another example, under the second most important evaluation factor, 
"project development and planning," the solicitation required that 
offerors "[i]dentify a plan, contents, and time frame for updating 
property records."  Beneco's proposal failed to address this 
requirement.  Among other things, DR No. 5 advised Beneco:  "Offeror 
fails to identify a plan for updating property records."  Beneco's 
response to DR No. 5 contained no discussion of any plan to update 
property records and, accordingly, Beneco's proposal was rated 
"red/unacceptable" under this evaluation factor.  The agency report 
responding to Beneco's protest included a memorandum prepared by the 
agency following Beneco's November 6 debriefing which quotes Beneco's 
representative as expressly acknowledging during the debriefing that 
Beneco's proposal did not respond to this solicitation requirement.  
Beneco's comments on the agency report do not address this matter.  
Accordingly, the record provides no basis to question the 
reasonableness of the agency's evaluation with regard to this 
evaluation factor.  

The agency also found Beneco's proposal deficient for failure to 
adequately comply with solicitation requirements that offerors:  
provide plans for obtaining the services of all major engineering 
disciplines; submit adequate plans for responding to emergency 
warranty calls; discuss the qualifications of superintendents; submit 
complete design submittal packages; submit plans for meeting normal 
and quick response times for designs; and submit adequately documented 
design concepts.  We have reviewed the record regarding the agency's 
evaluation of Beneco's proposal regarding these deficiencies and see 
no basis to question the reasonableness of the agency's evaluation.  
On the contrary, the record establishes that the agency reasonably 
determined that Beneco's proposal would require major revisions in 
order to comply with the solicitation's minimum requirements and, 
therefore, reasonably eliminated Beneco's proposal from the 
competitive range.  

The protest is denied. 

Comptroller General
of the United States  

1. Each factor contained multiple subfactors.

2. Blue/exceptional; green/acceptable; yellow/marginal; and 
red/unacceptable.

3. Beneco states that the agency contacted Beneco's Director of 
Business Development by telephone during the morning of October 13, 
advised him that the agency would be transmitting the CRs and DRs, and 
asked "whether Beneco would be able to return them by tomorrow."  
Beneco's representative responded, "We will do what we can."

4. Beneco also complains that the agency afforded Beneco insufficient 
time to respond to the CRs and DRs; however, this portion of the 
protest is not timely filed.  To the extent Beneco believed that the 
time period established for responding to the CRs and DRs was 
inadequate, it was required to protest that matter before the time set 
for receipt of the additional information.  4 C.F.R.  sec.  21.2(a)(1) 
(1997); Alamo Acoustical Restoration Co., B-228429, Feb. 16, 1988, 
88-1 CPD  para.  150 at 3.  Here, when asked by the contracting officer 
whether it could respond by the following day, Beneco's representative 
said "We will do what we can" and, in fact, submitted responses before 
noon the following day.  Since Beneco opted not to protest the matter 
until November 7, this allegation is untimely and not for 
consideration on the merits.