BNUMBER:  B-278689; B-278689.2; B-278689.3 
DATE:  March 2, 1998
TITLE: Jason Associates Corporation, B-278689; B-278689.2; B-
278689.3, March 2, 1998
**********************************************************************

Matter of:Jason Associates Corporation

File:     B-278689; B-278689.2; B-278689.3

Date:March 2, 1998

Mark A. Rowland, Esq., and Lane L. McVey, Esq., McKenna & Cuneo, for 
the protester.
John R. Jefferies, Esq., Fennemore Craig, for Gutierrez-Palmenberg, 
Inc., an intervenor.
Jeffrey I. Kessler, Esq., and Maj. Harry W. Longbottom, Department of 
the Army, for the agency.
Tania L. Calhoun, Esq., and Christine S. Melody, Esq., Office of the 
General Counsel, GAO, participated in the preparation of the decision.

DIGEST

1.  Protest that source selection authority (SSA) acted improperly 
when, in response to eventual awardee's agency-level protest of the 
exclusion of its proposal from the competitive range, she reevaluated 
a portion of the proposal and reinstated it in the competitive range 
is denied; the SSA acted within her authority and her reevaluation was 
reasonable and consistent with the solicitation's evaluation factors.

2.  Protest that SSA improperly considered the proposals of the 
protester and the awardee to be tied under the performance risk 
evaluation factor when the performance risk assessment group found 
distinctions is denied where the record shows that the SSA's 
conclusions were reasonable and consistent with the solicitation's 
evaluation scheme; agency's failure to check all references listed in 
the proposal is unobjectionable.

3.  Protest that no contemporaneous documentation exists to show that 
the SSA followed the solicitation's weighted basis for award scheme in 
making her award decision is denied where her post-protest 
explanation, which is consistent with the contemporaneous 
documentation, provides a detailed rationale for her decision which is 
sufficient for our Office to conclude that her decision was both 
consistent with the solicitation and reasonable.

DECISION

Jason Associates Corporation protests the award of a contract to 
Gutierrez-Palmenberg, Inc. (GPI) under request for proposals (RFP) No. 
DAAD01-97-R-0001, issued by the Department of the Army to obtain 
environmental support services at the U.S. Army Yuma Proving Ground 
(USAYPG) in Yuma, Arizona.  Jason challenges various aspects of the 
Army's evaluation of GPI's proposal and its source selection decision.

We deny the protests.

BACKGROUND

The USAYPG conducts developmental and desert environmental testing of 
materiel, and must ensure that these testing activities and its 
facility operations comply with federal, state, and Army 
environmental/radiation statutes and regulations.  To this end, the 
USAYPG requires the services of an environmental support contractor to 
provide scientific, engineering, technical, and regulatory compliance 
assistance.  Tasks will generally fall within the areas of analyses, 
studies, remediation, evaluations of the effects of USAYPG activities, 
and preparation of reports and other required documents.  RFP  sec.  C.1. 

Commerce Business Daily announcements advised potential contractors 
that the Army intended to procure these services under a multi-phase 
acquisition set aside for small businesses.  Under Phase I of the 
acquisition, offerors' "mini-proposals" were to be evaluated pursuant 
to a color-coded rating scheme to determine the firms' technical 
capabilities under various weighted factors.[1]  Technically capable 
firms were to be down-selected to participate in Phase II of the 
acquisition.  

The contracting officer, who served as the source selection authority 
(SSA) for this procurement, conducted the Phase I evaluation.  The 
mini-proposals of Jason and GPI, the incumbent contractor providing 
these services, were evaluated as follows:

           Phase I Factors      GPI    Jason

           Contractor Experience (5)GreenBlue

           EPA Violations (5)  Green   Green

           Key Personnel (4)   Green   Green

           Quality Assurance Plan (4)BlueGreen

           Training Program (3)Green   Green

           Subcontracting (2)  Green   Blue
The contracting officer's contemporaneous documentation shows that she 
ranked GPI's Phase I proposal first and Jason's third overall.  Both 
firms were down-selected to participate in Phase II of the 
acquisition.

The RFP, issued May 29, 1997, explained that Phase II proposals were 
to be evaluated under three factors:  technical merit, performance 
risk analysis, and cost.  RFP Attachment (Att.) 2,  para.  2.  Technical 
merit, the most important factor, consisted of three equally important 
subfactors:  understanding of problems/objectives; specific contractor 
capabilities and experience in cited subject areas; and technical 
report/writing quality.  Id. at  para.  2.A.  The technical merit factor and 
its subfactors were to be color-rated as above.  Id.  The technical 
merit factor was significantly more important than the performance 
risk analysis factor, but performance risk would become more 
significant as technical merit tended to equalize.  The performance 
risk analysis factor was slightly more important than cost.  RFP Att. 
2,  para.  2.B.(4).  The contracting officer was to make a competitive range 
determination after the Phase II proposals were evaluated.  Offerors 
whose proposals were included in the competitive range were to be 
down-selected to participate in Phase III of the acquisition, oral 
presentations.  RFP Att. 2,  para.  3.a. and b.

A two-member evaluation board reviewed the nine Phase II proposals for 
technical merit.  The proposals of Jason and GPI were rated blue under 
both the understanding and experience subfactors.  Under the technical 
writing subfactor, however, Jason's proposal was rated green and GPI's 
proposal was rated red.

The prenegotiation objective memorandum discusses the Phase I 
evaluation, under which the contracting officer had previously ranked 
GPI's proposal first and Jason's third overall.  The memorandum also 
includes a detailed discussion of the results of the technical merit 
and cost aspects of the Phase II evaluation.[2]  Jason's Phase II 
technical proposal was ranked first overall, with a blue/green rating, 
and the proposals of three other offerors were ranked second and 
essentially equal overall with all blue ratings.  The proposals of GPI 
and two other offerors were ranked third and essentially equal overall 
with blue ratings under the understanding and experience subfactors 
but red ratings under the technical writing subfactor.  The remaining 
proposals were rated lower still.

The contracting officer included only the top four proposals in the 
competitive range.  She excluded the remaining proposals, including 
GPI's, because, among other things, the red ratings they received 
under the technical writing subfactor were based upon finalized sample 
writings that had been submitted in connection with other contracts.  
As a result, these ratings could not improve with discussions.  See 
Prenegotiation Objective Memorandum at 6.  

GPI filed an agency-level protest challenging the exclusion of its 
proposal from the competitive range.  Along with specific allegations 
not at issue here, GPI complained that the exclusion of its proposal 
based upon the quality of its sample writings was improper because 
some of them had been delivered and approved by USAYPG under the prior 
contract for these services.  As discussed further below, the 
contracting officer was troubled by this revelation and reevaluated 
GPI's sample writings.  She found them to be at least acceptable 
(blue), and reinstated the proposal into the competitive range.

A separate evaluation board conducted the Phase III evaluation of oral 
presentations and concluded that the proposals of GPI and Jason were 
tied for first place and equally meritorious.  As discussed further 
below, the performance risk assessment group (PRAG) evaluated both 
firms as presenting low performance risk but stated that Jason 
presented the lowest risk and GPI the third-lowest risk.  GPI's 
evaluated cost over the 7-year life of this fixed-price contract with 
time-and-materials task orders was $5.4 million, and Jason's was $6.6 
million.

Award was to be made to the offeror whose responses to the three 
phases of the acquisition represented the best buy to the government.  
RFP Att. 2,  para.  4.  The RFP set forth specific guidance for making the 
"best buy" determination:  

     Oral presentations are considered the most important, followed by 
     Phase II technical ratings and Phase I ratings.  Cost and past 
     performance are considered least important with past performance 
     being slightly more important than cost. . . .  Significant 
     differences in measured technical merit may or may not be deemed 
     affordable depending on the best interests of the Government. 

Id.

In the post-negotiation memorandum, which served as the source 
selection decision, the contracting officer explained the 
circumstances surrounding her reevaluation of GPI's sample writings 
and her decision to reinstate the firm's proposal into the competitive 
range.  The document does not discuss the Phase I and II technical 
evaluation results, which had previously been addressed in the 
prenegotiation objective memorandum, but does include a detailed 
discussion of the Phase III evaluation results.  Under the heading 
"Final Evaluation," the contracting officer summarily compared the 
Phase III technical rankings (GPI and Jason were "tied" for first 
place); the performance risk assessment (both GPI and Jason were low 
risk); and the offerors' evaluated costs.  The contracting officer 
concluded:

     Since GPI and Jason are essentially tied in technical merit and 
     performance risk, the final determining factor for contract award 
     is total evaluated cost.  GPI's evaluated cost is approximately 
     $1.3 [million] (24%) lower than Jason's over the anticipated life 
     of the contract. . . . 

     Based on the above, GPI is considered to represent the best buy 
     to the Government.  GPI has been evaluated as one of the two 
     highest offerors in technical merit and is considered low risk 
     for contract performance.  GPI's total evaluated price is 
     approximately 24% lower than the next low offeror, who is 
     considered essentially equal to GPI in technical merit and 
     performance risk.  

Post-Negotiation Memorandum at 10-11. 

The November 13 award to GPI was followed by Jason's initial protest 
and two supplemental protests.  Jason argues that (1) the SSA 
improperly reevaluated GPI's Phase II proposal as to technical writing 
and improperly reinstated it into the competitive range; (2) the SSA 
erroneously considered both offerors to be tied under the performance 
risk analysis factor; and (3) the SSA improperly failed to follow the 
RFP's weighted basis for award scheme.[3]  We deny the protests based 
upon our review of the procurement record, the pleadings of all 
parties, and the testimony elicited at a hearing in this matter.

DISCUSSION

Reevaluation of GPI's Phase II Proposal

Jason asserts that the contracting officer was not authorized to 
reevaluate the technical writing aspect of GPI's Phase II proposal; 
that she improperly failed to contemporaneously document her 
reevaluation; and that her reevaluation was unreasonable because it 
was conducted solely to dispose of GPI's agency-level protest.

It is well-settled that source selection officials in negotiated 
procurements are not bound by the recommendations or evaluation 
judgments of lower-level evaluators, but may make their own judgments, 
subject to the tests of rationality and consistency with the stated 
evaluation factors.  Grey Advertising, Inc., 55 Comp. Gen. 1111, 
1120-1121 (1976), 76-1 CPD  para.  325 at 11-12;  Environmental Chemical 
Corp., B-275819, Apr. 1, 1997, 97-1 CPD  para.  154 at 5.  Here, the record 
shows not only that the contracting officer, as the SSA for this 
procurement, was within her rights to reevaluate GPI's proposal, but 
that her reevaluation was reasonable.  

GPI's agency-level protest was the contracting officer's first 
indication that two of the three sample writings, which the 
lower-level evaluators deemed so filled with errors and mistakes as to 
be unacceptable, had been submitted and approved by the very same 
contracting activity which now criticized them--USAYPG.  Tr. at 83.  
This revelation troubled the contracting officer to such a degree that 
she decided to reevaluate the sample writings herself.  Tr. at 20.  
She asked a lower-level evaluator to highlight each area of the sample 
writings that caused him to downgrade GPI's proposal.  Her review of 
the highlighted passages, as well as the evaluator's contemporaneous 
margin notes, led her to conclude that his evaluation was "overkill" 
and largely reflected a difference in writing styles; in her view, the 
problems that did exist in the documents should not have resulted in 
GPI's exclusion from the competitive range.  Tr. at 21-22, 91-92.  She 
believed that the sample writings were at least 
acceptable--blue--under the RFP's definition.  Tr. at 26.  In this 
regard, proposals were to be rated blue if the sample writings 
reflected an acceptable knowledge of proper writing skills and 
techniques, as well as the subject matter.  RFP Att. 2 at  para.  2.A.  The 
contracting officer did not contemporaneously document her 
reevaluation.

Jason does not directly challenge the reasonableness of the 
contracting officer's conclusion that GPI's sample writings were 
acceptable under the terms of the RFP, but, rather, complains that she 
improperly failed to contemporaneously document her reevaluation.  

Where there is inadequate supporting documentation for an award 
decision we cannot conclude that the agency had a reasonable basis for 
the decision.  Hattal & Assocs., 70 Comp. Gen. 632, 637 (1991), 91-2 
CPD  para.  90 at 7.  However, where post-protest explanations provide 
sufficient detail by which the rationality of an evaluation decision 
can be judged, it is possible to conclude that the agency had a 
reasonable basis for the decision.  Quality Elevator Co., Inc., 
B-276750,
July 23, 1997, 97-2 CPD  para.  28 at 3-4.  Post-protest explanations that 
provide a 
detailed rationale for contemporaneous conclusions, as is the case 
here, simply fill 
in previously unrecorded details, and will generally be considered in 
our review of the rationality of selection decisions, so long as those 
explanations are credible and consistent with the contemporaneous 
record.[4]  See Northwest Management, Inc.,
B-277503, Oct. 20, 1997, 97-2 CPD  para.  108 at 4 n.4.  Here, the 
contracting officer's post-protest explanation of her reevaluation is 
sufficient to show that it was reasonable.  See Quality Elevator Co., 
Inc., supra.  As a result, her reinstatement of the firm's proposal 
into the competitive range is unobjectionable.  

Jason also alleges that the reevaluation was unreasonable because it 
was done "solely" to dispose of GPI's protest.  Jason asserts that if 
the contracting officer had genuine concerns about the quality of the 
evaluation, she would have reevaluated the two proposals which were 
rated equal to GPI's and also excluded from the competitive range.  

Contracting officials in negotiated procurements have broad discretion 
to take corrective action where the agency determines that such action 
is necessary to ensure fair and impartial competition.  Rockville 
Mailing Serv., Inc., B-270161.2,
Apr. 10, 1996, 96-1 CPD  para.  184 at 4.  When the contracting officer was 
presented with information in GPI's agency-level protest which 
provided her a basis to question the evaluation of its sample 
writings, she properly did so.  As she stated during the hearing, she 
had no basis to reevaluate the other proposals because their 
elimination from the competitive range was based, as well, upon their 
high evaluated costs.  Tr. at 93.  The evaluated costs of these two 
proposals were $400,000 and $2.2 million higher, respectively, than 
the competitive range offeror with the highest evaluated cost.     

Performance Risk

Offerors were required to describe prior and current contracts 
relevant to the tasks listed under the solicitation's statement of 
work (SOW), and to identify contact persons for each contract.  RFP  sec.  
L.O.D.(2).  This information would be reviewed to assess the quality 
of each offeror's past performance.  RFP Att. 2,  para.  2.B.  According to 
its report, the PRAG reviewed the past performance information 
provided by each offeror to determine the relevance of each reference 
to the solicitation's requirements, and sent out two types of 
questionnaires, one concerning the offeror's performance with respect 
to contract administration matters, and one concerning the offeror's 
performance with respect to technical matters.  PRAG Report,  para.  3, 4.

With respect to Jason's proposal, the PRAG reviewed six contracts and 
five sets of questionnaire responses.  The PRAG rated Jason's proposal 
above average under both the technical and administrative 
questionnaires--and low performance risk overall--based upon the fact 
that it and its subcontractor received almost all above average 
ratings on the questionnaire responses.  The PRAG report does not 
discuss the nature of Jason's contracts or how their nature factored 
into the low risk rating.  Id. at  para.  10.  With respect to GPI's 
proposal, the PRAG reviewed five contracts and three sets of 
questionnaire responses.  The PRAG rated GPI's proposal above average 
under the technical questionnaire because a majority of its ratings 
were above average, and average under the administrative questionnaire 
because its ratings were evenly divided between above average and 
average--GPI's proposal was rated low performance risk overall.  
Again, the PRAG report does not discuss the nature of GPI's contracts 
or how their nature factored into the low risk rating.  Id. at  para.  11.  

The final paragraph of the PRAG report states that Jason had the 
lowest performance risk and GPI the third-lowest performance risk.  
Id. at  para.  13.  During the hearing, the contracting officer was asked to 
explain the apparent inconsistency between this statement and her 
statement in the source selection decision that the two offerors were 
"tied" with respect to performance risk.

The contracting officer explained that she expected the PRAG report to 
include a discussion of the relevance of the contracts that were rated 
to the work the agency planned to have the contractor perform, but the 
report merely focused on the number of average and above average 
ratings each offeror received.  Since simply counting the number of 
average and above average ratings would not give a true picture of 
each offeror's past performance, she read the underlying 
questionnaires herself.  Tr. at 28-29, 31, 51-53.   

The only set of questionnaires returned for Jason concerned a contract 
for public affairs support, which did not have a lot of relevance to 
the work required here.  Tr. at 29-30.  However, three sets of 
questionnaires were returned for one of Jason's subcontractors 
concerning contracts for work directly relevant to certain portions of 
the SOW.  Id.  The remaining set of questionnaires, from the 
Department of Energy (DOE), was not for Jason or any of its 
subcontractors, but for a different firm altogether.  While the PRAG 
had apparently considered these questionnaires, the contracting 
officer found no mention of the firm in Jason's proposal, so she did 
not consider them.  Tr. at 42-43.  With respect to GPI, three sets of 
questionnaires were returned, each of which concerned a contract 
relevant to the environmental support services required here.  In 
particular, the contracting officer considered the most relevant of 
these contracts to be the prior contract for these same services at 
USAYPG.  Tr. at 43, 105.  

Based upon her determination of the relevance of the questionnaires 
and the underlying contracts they described, as well as the comments 
made on the questionnaires, the contracting officer stated that she 
saw nothing to show that one contractor posed lower risk than the 
other and she considered them to be equally low risk contractors.  Tr. 
at 30-31, 52-53.  The source selection decision, which stated that the 
two offerors were "tied" in this regard, merely reflected that view.

In its post-hearing supplemental protest, Jason argues that the 
contracting officer improperly failed to review the past performance 
information in its proposal when she made her determination as to the 
relevance of the firm's prior contracts.  Jason asserts that, in so 
doing, she overlooked numerous relevant contracts performed by the 
firm.  Jason also contends that the contracting officer improperly 
failed to contact DOE to obtain the correct set of questionnaires for 
Jason; had she done so, Jason asserts, it might have received a lower 
performance risk rating than GPI.

A source selection official may reach her own conclusions about how 
much weight to accord PRAG information, provided her conclusions are 
reasonable and do not improperly disregard the RFP's evaluation 
scheme.  Litton Sys., Inc., Amecom Div., B-275807.2, Apr. 16, 1997, 
97-1 CPD  para.  170 at 12.  The record here provides us no basis to 
question the contracting officer's conclusions.

Each offeror was on notice that the subject of the performance risk 
evaluation was the quality of its past performance, and that this was 
to be ascertained by asking its customers for information regarding 
the firm's performance on relevant contracts.  As indicated above, the 
PRAG reviewed the past performance proposals for relevance in order to 
determine to which contact persons questionnaires should be sent, and 
decided to review six contracts listed in Jason's proposal and five 
contracts listed in GPI's proposal.  The contracting officer duly 
reviewed the questionnaires returned to the agency, and we have no 
basis to disagree with her conclusions.  A review of Jason's past 
performance proposal, which set forth the relevance of its prior 
contracts to the work required here, would have provided her with 
little information concerning the objective quality of the firm's 
performance on these contracts.  There is no legal requirement that 
all references listed in a proposal be checked.  HLC Indus., Inc., 
B-274374, Dec. 6, 1996, 96-2 CPD  para.  214 at 7.  For this same reason, 
the contracting officer was under no obligation to contact DOE to 
obtain the correct questionnaire responses for Jason's contract.  
Moreover, as our review of the record shows that the DOE contract at 
issue was relevant to only some SOW requirements, we have no basis to 
conclude that its consideration would have resulted in a meaningfully 
better performance risk rating for Jason.  See Northport Handling, 
Inc., B-274615, Dec. 18, 1996, 97-1 CPD  para.  3 at 3-4.     

Award Decision

Jason argues that no contemporaneous documentation exists to show that 
the contracting officer followed the RFP's weighted basis for award 
scheme in making her award decision.

As explained above, award was to be made to the offeror whose 
responses to the three phases of the acquisition were found to 
represent the best buy to the government.  Oral presentations (Phase 
III) were considered most important, followed by the Phase II 
technical ratings, the Phase I ratings, and past performance, which 
was slightly more important than cost.  RFP Att. 2,  para.  4; Tr. at 14-15.  
Significant differences in technical merit might or might not be 
deemed affordable depending upon the best interests of the government.  
RFP Att. 2,  para.  4.

The source selection decision's failure to discuss the results of 
Phases I and II of the acquisition suggested that the SSA had not 
considered these results in making her award decision.  Since the 
contracting officer's statement filed in response to the protest 
indicated that she did consider these results, she was asked to 
address this matter at the hearing. 

The contracting officer explained that when she finished evaluating 
the Phase I proposals she ranked GPI's proposal first and Jason's 
third, a fact that she contemporaneously documented.  When she 
received the results of the Phase II technical evaluation, she ranked 
Jason's proposal first and excluded GPI's proposal from the 
competitive range, a fact that she also contemporaneously documented.  
After her reevaluation, she considered Jason's proposal to be ranked 
first and GPI's to be tied for second, a ranking consistent with the 
contemporaneous documentation.  Tr. at 35.  She reviewed the strengths 
that caused GPI's proposal to be rated higher under Phase I--its 
experience in the context of key personnel and subcontractors--and the 
strengths that caused Jason's proposal to be rated higher under Phase 
II--its technical writing skills.  Id.  She did not consider that 
either of these strengths made one offeror superior to the other; 
while GPI's reports might not be as well-written as Jason's, GPI's 
experience would "pull that through."  Id.  As a result, the 
contracting officer stated, in her mind Jason and GPI were tied 
technically prior to her receipt of the Phase III results.  Id.  
However, her decision-making from the point of the reevaluation to the 
point of receiving the Phase III evaluations was not documented.  The 
contracting officer explains that she normally would have addressed 
these matters in the prenegotiation objective memorandum but, at the 
time that document was written, GPI's proposal had been excluded from 
the competitive range and the closeness between the two proposals was 
not an issue.  After the reevaluation, she "completely forgot" to 
readdress the matter in the post-negotiation memorandum.  Tr. at 63.  
The fact that she began her discussion of the final evaluation with 
the Phase III results reflected her belief that the two proposals were 
tied up to that point.  Tr. at 36.

The contracting officer's post-protest explanation of her 
decision-making is not a new, post hoc rationale for her source 
selection, but simply fills in previously unrecorded details that are 
entirely consistent with the contemporaneous evaluation documentation.  
As a result, we find her explanation sufficient to show that her 
source selection decision was both reasonable and consistent with the 
solicitation's weighted basis for award scheme.  See Northwest 
Management, Inc., supra.  In this regard, Jason maintains that the 
contracting officer's selection of GPI reflects her failure to follow 
the weighted basis for award scheme for two reasons.  First, Jason's 
Phase I proposal was rated green and GPI's blue under the quality 
assurance factor.  Second, Jason's proposal was rated green under one 
Phase II factor and GPI's proposal was rated blue under all three 
factors, and the Phase II technical results were more important than 
the Phase I results. 

Color-coded ratings, like point scores, are used as a guideline for 
intelligent decision-making by source selection officials; award 
should not and need not be based solely on these ratings or scores.  
See AlliedSignal, Inc., B-272290, B-272290.2, Sept. 13, 1996, 96-2 CPD  para.  
121 at 7.  Rather, a selection should reflect the procuring agency's 
considered judgment of whether significant technical differences exist 
in the proposals that identify a particular proposal as technically 
superior regardless of close scores or ratings among proposals.  Id.  
The contracting officer here specifically found that GPI had excellent 
experience under Phase I, both in the context of key personnel and 
subcontracts, and that this strength gave GPI the edge over Jason's 
strength in the area of quality assurance.  In this regard, the 
combined weight of the key personnel and subcontracts factors is 
nearly twice that of the quality assurance factor.  Tr. at 73-74.  
Moreover, the contracting officer states that she considered the 
experience difference that GPI had under Phase I to be enough to 
offset the difference between the two proposals under Phases I and II.  
Tr. at 79.  Jason's apparent disagreement with her conclusion does not 
render it unreasonable.  See Global Assocs., Ltd., B-256277, June 6, 
1994, 94-1 CPD  para.  347 at 4.    

The protests are denied.

Comptroller General
of the United States

1. Proposals were to be rated "green" if they significantly exceeded 
the minimum requirements under a given factor; "blue" if they were 
acceptable; and "red" if they failed to meet the minimum requirements.  
The weight of each Phase I evaluation factor is set forth in 
parentheses in the table below.

2. The performance risk assessment was still in process, but a 
preliminary review showed that the performance risk for all offerors 
whose proposals were selected for inclusion in the competitive range 
would be low to negligible. 

3. We need not consider Jason's allegation that the contracting 
officer improperly relied upon a USAYPG environmental attorney's 
parallel reevaluation of GPI's sample writings.  Testimony provided 
during a hearing that our Office conducted in connection with these 
protests shows that the contracting officer did not rely upon that 
attorney's reevaluation, but used it merely to confirm her own 
reevaluation, which is at issue here.  Hearing Transcript (Tr.) at 24, 
117-118, 134.  

4. In contrast, we give less weight to new, post hoc rationales and 
conclusions reached for the first time in response to a protest.  See 
Boeing Sikorsky Aircraft Support, B-277263.2, B-277263.3, Sept. 29, 
1997, 97-2 CPD  para.  91 at 15.