BNUMBER:  B-278896.2; B-278896.3; B-278896.4; B-278896.5 
DATE:  May 4, 1998
TITLE: Aerospace Design & Fabrication, Inc., B-278896.2; B-278896.3;
B-278896.4; B-278896.5, May 4, 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:Aerospace Design & Fabrication, Inc.

File:     B-278896.2; B-278896.3; B-278896.4; B-278896.5

Date:May 4, 1998

Paralee White, Esq., Michael A. Hordell, Esq., and Lisa K. Miller, 
Esq., Gadsby & Hannah, for the protester.
James S. Ganther, Esq., Ganther & Fee, for Dynacs Engineering Co., 
Inc., an intervenor.
Vincent A. Salgado, Esq., and Jerald J. Kennemuth, Esq., National 
Aeronautics and Space Administration, for the agency.
Ralph O. White, Esq., and Christine S. Melody, Esq., Office of the 
General Counsel, GAO, participated in the preparation of the decision.

DIGEST

1.  Protester's contention that the awardee misrepresented the 
availability of its key personnel is sustained where the record shows 
that the awardee had not obtained a commitment from the proposed 
individuals as it claimed, and where the misrepresentation, together 
with an evaluation error by the agency, resulted in a material 
misevaluation of the key personnel section of the awardee's proposal.  

2.  Agency contention that award fee negotiations on a prior contract 
were sufficient opportunity for the protester to comment on adverse 
information received from a past performance reference, as required by 
Federal Acquisition Regulation  sec.  15.610(c)(6) (June 1997), is 
rejected, and the protest sustained, where the protester was a 
subcontractor on the prior contract, not the prime contractor, and 
where the record shows that the subcontractor had no meaningful role, 
or opportunity to respond, during the award fee negotiations with the 
prime contractor.  

3.  Solicitation terms are latently ambiguous and result in unequal 
competition where the record shows that the offerors reasonably 
understood requirements and submitted proposals based on different 
assumptions that potentially skewed the agency's assessment under the 
relevant experience and past performance evaluation factor.

4.  Protester's argument that a cost realism adjustment made to its 
proposed costs was improper is denied where the record shows that the 
agency had a reasonable basis for the conclusion.

5.  General Accounting Office recommends reimbursement of proposal 
preparation costs as well as protest costs because unique 
circumstances create a situation where reevaluation and 
reconsideration of the selection decision cannot return the parties to 
their respective positions prior to the agency error.

DECISION

Aerospace Design & Fabrication, Inc. (ADF) protests the decision by 
the National Aeronautics and Space Administration (NASA) to make award 
to Dynacs Engineering Co., Inc., pursuant to request for proposals 
(RFP) No. 3-085970, seeking offers to provide scientific, engineering, 
technical, and administrative services for NASA's Lewis Research 
Center.  ADF argues that award to Dynacs is improper because the 
Dynacs proposal included material misrepresentations about its key 
personnel; the agency misevaluated proposals; and the agency failed to 
disclose during discussions certain weaknesses regarding ADF's past 
performance.

We sustain the protest.

BACKGROUND

The contract here is a follow-on to an earlier scientific, 
engineering, technical and administrative services contract awarded by 
NASA's Lewis Research Center to NYMA, Inc., under the Small Business 
Administration's (SBA) section 8(a) set-aside program.[1]  The RFP was 
issued on September 30, 1997, after NYMA, Inc. was acquired by a large 
business earlier in the year, and lost its status as a small 
disadvantaged business under SBA regulations.  The RFP anticipated a 
competitive procurement limited to 8(a) businesses leading to the 
award of a hybrid contract containing approximately 10-percent 
fixed-price and 90-percent cost-plus-award-fee task orders.  RFP Cover 
letter, Sept. 30, 1997, Attach. 1 at 1; RFP  sec.  B.2, L.14; RFP, Attach. 
1, Industry Briefing Questions, Oct. 8, 1997 at question 53.  The 
estimated maximum value of the effort was $45 million for the 27-month 
performance period.  Initial Contracting Officer's Statement, Jan. 26, 
1998, at 1.

Section M.3 of the RFP set forth three evaluation factors of equal 
importance:  mission suitability; cost; and relevant experience and 
past performance.  Of these three factors, cost and relevant 
experience and past performance were not scored, but were evaluated by 
the source evaluation committee (SEC) for review by the source 
selection official (SSO).  RFP  sec.  M.2.  The mission suitability factor 
was evaluated on a 1,000-point scale, with the following allocation of 
points among the subfactors (the elements of the subfactors were not 
separately scored):

     MISSION SUITABILITY                     Points

        Subfactor 1:  Understanding the Requirements   200
          --  Technical Approach
          --  Quality Assurance Plan

        Subfactor 2:  Management Plan           550
          --  Phase-In Plan
          --  Personnel Management
          --  Business Management
          --  Property Management
          --  Subcontracting

        Subfactor 3:  Key Personnel/Company Resources   250

             TOTAL                            1,000

RFP  sec.  M.3.  

After NASA's receipt and evaluation of 14 proposals in response to the 
RFP, the SEC, on December 8, selected 3 of the proposals for inclusion 
in the competitive range--ADF, Dynacs, and a third offeror.  The 
agency then held discussions with the competitive range offerors, and 
best and final offers (BAFO) were received on December 12.  After 
final evaluation by the SEC, the results of the competition were 
presented to, and discussed with, the SSO.  The final point scores and 
adjectival ratings are set forth below[2]:

                             DYNACS                 ADF

MISSION SUITABILITY
TOTAL                       [deleted]
                            Excellent            [deleted]
                                                 Very Good

   --Understanding the
     Requirements           [deleted]
                            [deleted]            [deleted]
                                                 [deleted]

   --Management Plan        [deleted]
                            [deleted]            [deleted]
                                                 [deleted]

   --Key Personnel/
     Company Resources      [deleted]
                            [deleted]            [deleted]
                                                 [deleted]

RELEVANT EXPERIENCE AND PAST PERFORMANCE
                            Excellent     
                                                 Very Good

PROBABLE COST               [deleted]            [deleted]
The table above, showing the final evaluation results, reflects one 
change made by the SSO.  When the SEC completed its evaluation, it 
awarded ADF a rating of good under the relevant experience and past 
performance factor.  The SSO, however, disagreed with the rating and 
raised ADF's score under this factor from good to very good.  Source 
Selection Statement, Dec. 16, 1997, at 8.  Based on the evaluation 
results shown above, the SSO selected Dynacs for award because of "its 
superior technical proposal, its excellent [r]elevant [e]xperience and 
[p]ast [p]erformance, and its lowest probable cost . . . ."  Id.  
These protests followed.

EVALUATION OF KEY PERSONNEL

ADF argues that Dynacs misrepresented the level of commitment from 
three of its proposed key managers, leading the agency to improperly 
award Dynacs more credit in the key personnel portion of the 
evaluation than the proposal merited.  In addition, ADF claims that 
the effect of these misrepresentations rippled through other mission 
suitability assessments, causing Dynacs's score under this factor to 
be improperly inflated.  ADF also argues that Dynacs crafted the key 
personnel section of its proposal in an effort to wrongly gain credit 
for a manager it was not offering in its proposal.  As a result, ADF 
argues that the evaluation should be overturned, and Dynacs should be 
barred from any subsequent competition for these services.

Dynacs and NASA reply that the Dynacs proposal did not misrepresent 
the availability of either the three key managers, or the manager that 
was not offered.  In addition, both point out that each of the three 
key managers whose commitment ADF questions eventually agreed to come 
to work for Dynacs after award.  Thus, the agency and intervenor argue 
that there was no "bait and switch" of key personnel for this 
contract, and there was no prejudice resulting from any alleged 
misrepresentation of the level of commitment of the three key 
managers. 

In our review of protests involving service contracts where the most 
qualified personnel are often those currently performing the services, 
we are mindful of the difficulty faced by a nonincumbent contractor in 
securing a qualified workforce sufficient to win the competition.  
ManTech Advanced Sys. Int'l, Inc., B-255719.2, May 11, 1994, 94-1 CPD  para.  
326 at 5; CBIS Fed. Inc., B-245844.2, Mar. 27, 1992, 92-1 CPD  para.  308 at 
5.  Nevertheless, an offeror's misrepresentation concerning personnel 
that materially influences an agency's consideration of its proposal 
generally provides a basis for proposal rejection or reevaluation of 
the award decision based on the faulty proposal.  ManTech Advanced 
Sys. Int'l, Inc., supra, at 5, 13 (misrepresentation of personnel 
commitments, reevaluation recommended); CBIS Fed. Inc., supra, at 6-7, 
17 (misrepresentation of personnel availability, reevaluation 
recommended); Ultra Tech. Corp., B-230309.6, Jan. 18, 1989, 89-1 CPD  para.  
42 at 5 (misrepresentation of availability of key person and use of 
name in proposal without permission, termination recommended absent 
other agency findings); Informatics, Inc., B-188566, Jan. 20, 1978, 
78-1 CPD  para.  53 at 13 (misrepresentation of results of a survey of the 
availability of incumbent's personnel, exclusion recommended).

For the reasons set forth below, we find that Dynacs misrepresented 
the nature of the commitment it received from three of the four 
incumbent personnel it proposed.  We also find that Dynacs included in 
its proposal one of the incumbent's key personnel despite his specific 
request that it not do so.  Further, we conclude that these actions, 
together with the related evaluation errors by the agency, resulted in 
a material misevaluation of the key personnel portion of Dynacs's 
proposal. 

The RFP for this procurement did not specify the number of key 
personnel an offeror should propose, but instead left the matter to 
the offeror's discretion.  RFP  sec.  M.3 at M-4; RFP, Attach. 1, Industry 
Briefing Questions at questions 6-7.  Offerors were required to 
include in their proposals "the responsibilities, qualifications, 
availability, level of involvement and number of key personnel," RFP  sec.  
L.27 at L-20, and were advised that this information would be 
evaluated.  RFP  sec.  M.3 at M-4.  There was no requirement in the RFP for 
offerors to provide written commitments for key personnel.

In its proposal, Dynacs identified five key personnel, consisting of a 
project manager, and four area managers--one each for Aeronautics, 
Aerospace Technology, Aeropropulsion Systems, and Space Experiments.  
Dynacs Proposal, Vol. I at 23-27.  Each of the four proposed area 
managers was an incumbent employee (working for NYMA, Inc.) on the 
predecessor contract.  Id. at 24.  For three of these proposed area 
managers, Dynacs represented--using identical wording in each 
case--that "Dynacs has received [Dr. A's] [Dr. B's] [Dr. C's] 
commitment to become a member of the Dynacs team upon contract award."  
Id. at 25-26.  

After ADF cast doubt upon the nature of the commitments that were made 
to Dynacs, our Office convened a hearing to receive testimony from 
representatives of Dynacs, and from each of the three key individuals 
mentioned above as to the nature of the commitments in question.  

During the hearing, two of Dynacs's representatives testified that 
prior to submitting the proposal they contacted each of the three 
individuals by telephone and eventually met face-to-face with all 
three.  Hearing Transcript (Tr.) at 23-24, 26, 31, 110-11, 113.  For 
each individual, one of the Dynacs representatives testified that he 
asked--using similar words in each instance--"if we [Dynacs] were 
fortunate enough to win the contract, would he [Dr. A], in fact, come 
to work for Dynacs . . . ."  Tr. at 114.[3]  However, in each case, 
the Dynacs witness testified that there was no exchange of information 
about salary, benefits, or the precise position which might be 
offered, other than inquiring whether the individual might like to 
continue performing his current job.  Tr. at 110, 112, 116-17, 119, 
133.  

The Dynacs witness who conducted the face-to-face meetings initially 
testified that none of these three individuals were asked if their 
names could be used in the proposal, and none gave permission for 
their names to be used.  Tr. at 118-19.  The same witness then 
conceded that one of the individuals--Dr. A--expressly denied Dynacs's 
request to provide information for use in the proposal, and refused to 
grant permission to Dynacs to identify him in its proposal.  Tr. at 
119; see also Tr. at 70.  Dr. A himself testified and confirmed that 
he met with the Dynacs representative (Tr. at 157), and told Dynacs 
that he was exclusively committed to another offeror, and that Dynacs 
could not use his name, or his resume, in its proposal.  Tr. at 158.  
He also testified that when the Dynacs representative asked if he 
would "consider working for them if they won," he agreed that he 
"would consider it."  Id.  Finally, Dr. A testified that he did not 
know he had been offered as a key person in Dynacs's proposal until 
after the contract had been awarded, when--as a representative of the 
outgoing contractor--he was participating in a meeting to plan the 
transfer of the contract to the new awardee.  Tr. at 161-62.

Drs. B and C also testified that they had not committed to work for 
Dynacs and that neither was aware he had been named as a key manager 
in Dynacs's proposal.  Tr. at 288, 299-300.  Dr. B testified that 
after award to Dynacs he was concerned about keeping his job and 
supporting his family, and had no idea whether he would be hired by 
the new awardee.  Tr. at 305-07.  On the other hand, both Drs. B and C 
testified that it was their purpose in meeting with Dynacs to be 
included in the proposal, and both hoped they had been included.  Tr. 
at 288, 312.  Unlike Dr. B, Dr. C testified that it was his 
understanding that he would be named in the Dynacs proposal, even 
though he did not consider himself committed to Dynacs in the event it 
prevailed in the competition.  Tr. at 285, 288.

As a starting point in our analysis, the record in this case, 
including the testimony received at the hearing, clearly refutes 
Dynacs's claim of a commitment between the company and Drs. A, B, and 
C.

With respect to Dr. A, the record not only shows that Dynacs 
misrepresented that it had received a commitment from this individual, 
but Dynacs's own witness admitted that Dr. A expressly refused to 
provide permission for the company to include him in its proposal, and 
refused to provide background information that could be used for that 
purpose.  Tr. at 119.  At best, after Dr. A refused to respond to 
several entreaties, he agreed to "consider" working for Dynacs in the 
event it prevailed in the competition.  Tr. at 158.  In short, there 
is no way to reconcile the proposal's claim[4] that "Dynacs has 
received [Dr. A's] commitment to become a member of the Dynacs team 
upon contract award" with the testimony received from both Dr. A (Tr. 
at 158) and Dynacs's own witness (Tr. at 114).  

Even with respect to Drs. B and C, the record does not support 
Dynacs's claim of a commitment.  As set forth above, both testified 
that they had not provided a commitment to Dynacs, and neither was 
aware of having been identified in the proposal.  Tr. at 288, 299-300.  
Although Drs. B and C both explained that they "hoped" they had been 
named in the proposal (Tr. at 288, 312), the clear import of the 
testimony received by our Office was that neither of these 
individuals, nor Dr. A, knew whether they would have a job after 
learning of Dynacs's selection for award.  In fact, the record shows 
that Dr. A first learned of his "commitment" while participating in a 
meeting--as a representative of the outgoing contractor--to plan the 
smooth transfer of services to the new awardee.  Tr. at 161-62.

Finally, even Dynacs's description of its efforts here undercuts its 
claim of commitments.  Dynacs's own witness testified that there was 
no agreement with any of these three incumbent personnel regarding 
salary, benefits, or the precise job involved in this commitment.  Tr. 
at 110, 112, 116-17, 119, and 133.  In similar circumstances, we have 
upheld an agency determination that an agreement to work for an 
offeror if it prevails in the competition--assuming successful salary 
and benefit negotiations--is no more than a promise to negotiate for 
employment, and not a binding commitment.  Scientific Management 
Assocs., Inc., B-238913, July 12, 1990, 90-2 CPD  para.  27 at 7.  
Accordingly, we find that the totality of the evidence convincingly 
shows that Dynacs's misrepresented the level of commitment for three 
of the five key personnel in its proposal.[5]  See ManTech Advanced 
Sys. Int'l, Inc., supra, at 10; Ultra Tech. Corp., supra, at 4-5. 

Our analysis of the misrepresentation here turns next to an assessment 
of the effect on the evaluation.  Despite NASA's assertion that 
Dynacs's claimed commitments did not change the outcome of this 
competition, the record does not support this contention.  As 
explained below, there was very little basis to distinguish between 
these two offerors under the mission suitability evaluation factor, 
other than the rating under the key personnel/company resources 
subfactor.  In addition, an evaluation error by the agency improperly 
magnified the effect of Dynacs's claimed commitments.  Finally, 
Dynacs's misrepresentation of its commitments had a ripple effect in 
the evaluation that pushed the ultimate assessment of its proposal 
even farther afield.  As a result, we conclude that the agency's 
reliance on, and inflation of, the misrepresentations in Dynacs's 
proposal led to a misevaluation of the relative merits of the two 
proposals.

First, both Dynacs and ADF received [deleted] ratings under the first 
two subfactors within the mission suitability evaluation factor.  The 
scores were [deleted] under the first subfactor, and [deleted] points 
apart under the second subfactor [deleted].  All of the remaining 
difference between their mission suitability scores is accounted for 
by the [deleted] point difference under key personnel/company 
resources subfactor.  While Dynacs also received credit for a strong 
project manager, there is no doubt that the mission suitability scores 
of these two offerors would have been much closer if Dynacs had not 
received a strength for its highly qualified key personnel, and the 
proposals may have received the same adjectival rating.  

Next, we note that an evaluation error by the agency magnified the 
effect of Dynacs's claimed commitments by giving even greater credit 
to Dynacs's proposal in this area than was appropriate.  Evaluation 
worksheets developed to assess Dynacs's proposal include the notation, 
"Very Good Key personnel Quals. (signed commitments from 3 incumbent 
mgrs. & 2 others."  Worksheets, Agency Report Tab 23 at 3.  This 
notation in the evaluation worksheets eventually found its way into 
the Source Selection Statement.  Specifically, in reviewing the merits 
of Dynacs's proposal under the key personnel and company resources 
subfactor, the SSO states:

     Dynacs proposed an outstanding Project Manager with extensive 
     technical and business management experience on similar 
     contracts.  Dynacs also proposed a team of highly qualified key 
     personnel.  Signed commitments were obtained from all key 
     personnel proposed.  Numerous other contracts currently performed 
     by Dynacs provide a broad base of technical and personnel 
     resources to support the SETAR II contract.

Source Selection Statement, Dec. 16, 1997, at 5 (emphasis added).  
This is the entirety of the SSO's consideration of this evaluation 
subfactor for Dynacs.

While the inclusion of the reference to "signed commitments" in the 
final selection decision document strongly suggests that the agency 
erroneously evaluated the proposal in this area, the Chairman of the 
SEC testified at the hearing that the notation was simply an 
administrative error.  Tr. at 197.  Specifically, he testified that 
the notation about signed commitments was listed on the worksheets for 
both ADF and Dynacs, but was correct only for ADF; he also testified 
that the worksheet error in Dynacs's evaluation was inadvertently 
carried forward to the final source decision document, but did not 
reflect the views of the SEC or the SSO.  Tr. at 197-99.  

The testimony of the SEC Chairman conflicts with the contemporaneous 
evaluation evidence found in both the worksheets and in the final 
selection document.  We consider the entire record in attempting to 
resolve such conflicts, including later explanations and arguments, 
but we accord greater weight to contemporaneous evaluation and source 
selection materials than to explanations prepared in response to 
protest contentions.  Cygnus Corp., B-275181, Jan. 29, 1997, 97-1 CPD  para.  
63 at 8; DynCorp, B-245289, B-245289.2, Dec. 23, 1991, 91-2 CPD  para.  575 
at 7 n.13.  While we consider the testimony of the SEC Chairman to be 
entirely credible, we have no contemporaneous evidence that the SSO, 
or the evaluators, believed this written finding to be in error.  Nor 
did the agency, at any time prior to the hearing, advise that this 
conclusion was in error, despite the submission of an initial and two 
supplemental agency reports.  Given that the Source Selection 
Statement is the foundation of any agency award decision, and should 
not have been signed by the SSO if it did not accurately reflect his 
considerations, we cannot justify disregarding the statements in it, 
as well as those in the written evaluation materials, that NASA 
evaluators--and more importantly, the SSO--concluded Dynacs had 
offered written commitments for its key personnel, and that NASA 
valued those commitments, where the only evidence in conflict with the 
contemporaneous materials is the testimony of one individual made 
during the course of the protest.  Instead, we must accord greater 
weight to the contemporaneous documents that were prepared to reflect 
the considered judgment of the agency.  See Boeing Sikorsky Aircraft 
Support, B-277263.2, B-277263.3, Sept. 29, 1997, 97-2 CPD  para.  91 at 15.

Finally, as stated above, we conclude that these misrepresentations in 
Dynacs's proposal had a ripple effect in the evaluation as well.  For 
example, the record here shows that after contract award Dynacs was 
surprised to learn the magnitude of the incumbent employees' salaries 
and concluded that it had significantly underestimated their salaries 
in its proposal.  Tr. at 249.  Thus, Dynacs found it necessary to 
explore a cost increase with NASA immediately after award.  Tr. at 
103-04, 249.  If the proposal had accurately reflected the salaries of 
these personnel, or acknowledged that the incumbent employees might be 
asked to take significant pay cuts, the proposal might not have been 
viewed as having [deleted] for its total compensation package or its 
thorough personnel management practices.[6]  See Final Evaluation 
Report, Dec. 5, 1997, at 20.  

Before ending this analysis, we address NASA's and the intervenor's 
contentions that there was no prejudice here because each of the three 
key managers eventually accepted employment with Dynacs, such that no 
"bait and switch" occurred.  As NASA correctly points out, our Office 
will not sustain a protest unless the protester demonstrates a 
reasonable possibility of prejudice, that is, unless the protester 
demonstrates that, but for the agency's actions, it would have had a 
substantial chance of receiving the award.  McDonald-Bradley, 
B-270126, Feb. 8, 1996, 96-1 CPD  para.  54 at 3; see Statistica, Inc. v. 
Christopher, 102 F.3d 1577, 1581 (Fed. Cir. 1996). 

While the ultimate conclusion here that ADF might have had a 
substantial chance of receiving the award depends upon the resolution 
of other protest issues in ADF's favor, as discussed in greater detail 
below, the eventual decision of these key individuals to accept 
employment with Dynacs is not dispositive of the question of 
prejudice.[7]   ManTech Advanced Sys. Int'l, Inc., supra, at 12-13; 
see Informatics, Inc., supra, at 13 ("it is also inappropriate to take 
note of [the awardee's] post-selection efforts in regard to 
recruitment of [the incumbent's] employees").  

Here, the prejudice occurred when Dynacs received evaluation credit 
for nonexistent commitments from key employees, and in one case, for 
naming a key employee who had expressly denied Dynacs permission to 
use his name in its proposal.  Thus, Dynacs was placed on the same 
footing as ADF, which did, in fact, accurately represent in its 
proposal that it had signed commitments from its proposed key 
personnel.  

RELEVANT EXPERIENCE AND PAST PERFORMANCE

ADF raises several arguments related to NASA's evaluation under the 
relevant experience and past performance factor.  Specifically, ADF 
contends that both proposals were evaluated unreasonably in this area; 
that the agency failed to advise ADF during discussions of unfavorable 
past performance information ADF had not previously been given an 
opportunity to rebut, in violation of Federal Acquisition Regulation 
(FAR)  sec.  15.610(c)(6) (June 1997); and, that the solicitation contained 
a latent ambiguity with respect to the submission of past performance 
information that caused ADF to receive a lower rating than was 
received by Dynacs.  As set forth below, we deny ADF's challenges to 
the specific evaluation assessments made by NASA, but we sustain its 
contentions that it was misled by a latent ambiguity in the RFP 
regarding the submission of past performance information, and that the 
agency was required to discuss certain of ADF's unfavorable past 
performance reviews during negotiations.

In describing the expected structure of proposal submissions for this 
procurement, the RFP anticipated a three-volume submission with page 
limits on two of the three volumes.  RFP  sec.  L.26(a).  The third volume 
of each proposal was to address the offeror's relevant experience and 
past performance, and was not to exceed five pages.  Id.  In addition, 
offerors were required to identify two references, on forms supplied 
within the solicitation, for each prime and subcontractor 
participating in the proposal.  RFP  sec.  L.31.  This provision also 
explained that the completed reference forms would not be counted 
against the five-page limit for this portion of the proposal.

ADF's proposal identified itself as the prime contractor, and NYMA, 
Inc. (the incumbent) and a second company as subcontractors.  ADF 
Proposal Vol. III at 1.  As required by the RFP, ADF included two 
references for itself, and two references for each of its two 
subcontractors.  ADF's two references both involved contracts where it 
had been the subcontractor--one reference was NYMA (ADF's 
subcontractor here) for the SETAR I effort; the other reference was 
[deleted].  ADF then used its five-page discussion to expand on the 
information related to its two references, and those of its two 
subcontractors.  Id. at 1-5.  In contrast, Dynacs did not propose to 
use subcontractors for the SETAR II effort.  Thus, its proposal 
included the two references required by the RFP, while its five-page 
discussion was used to expand on those two references and on Dynacs's 
experience with six other related contracts.  Dynacs Proposal Vol. III 
at 1-5.

In evaluating the proposals under this factor, NASA awarded ADF 
[deleted].  Each [deleted] included an indication about which of the 
three companies--ADF, NYMA, or the third company--possessed the 
[deleted].

Final Evaluation Report, Dec. 5, 1997, at 22.  As a result, the SEC 
awarded ADF an overall score of good under the relevant experience and 
past performance evaluation factor.  Id.  As explained above, the SSO 
disagreed with the SEC's conclusion, and in his selection decision he 
raised the score to very good.  Source Selection Statement, supra, at 
8.  In contrast, Dynacs received an overall score of excellent based 
on the SEC's assessment that the proposal contained [deleted] and 
[deleted].

During the course of this protest, NASA expanded on its basis for the 
evaluation.  First, it explained that it reasonably took note of ADF's 
lack of prime contract experience, and concluded that NYMA's 
experience as a prime contractor could not be used to fill that need 
for ADF.  Initial Contracting Officer's Statement, Jan. 26, 1998, at 
3-4.  The agency also explained that it tempered NYMA's very favorable 
reviews of ADF's past performance because of NYMA's obvious economic 
interest in ADF's prevailing in the competition.  Contracting 
Officer's First Supp. Statement, Feb. 23, 1998, at 5-6.  In addition, 
it explained that it was reasonably concerned about [deleted].  In the 
[deleted] response to the request for past performance information, 
the company indicated that ADF [deleted].  Id. at 6.  In NASA's view, 
there was no need to advise ADF of its concerns about [deleted] during 
discussions because this issue had been aired during award fee 
negotiations with [deleted], the prime contractor.  Initial 
Contracting Officer's Statement, supra, at 4.

With respect to ADF's contentions that the evaluation conclusions 
reached about the past performance proposals were unreasonable, our 
review consists of examining the record to determine whether the 
agency's judgment was reasonable and consistent with stated evaluation 
criteria and applicable statutes and regulations.  ESCO, Inc., 
B-225565, Apr. 29, 1987, 87-1 CPD  para.  450 at 7.  We have reviewed each 
of ADF's claims and find that the agency's conclusions were 
appropriate and reasonable, based on the information before it.  Since 
most of ADF's contentions involved its own less than favorable 
evaluation, we set forth two examples below.

First, despite ADF's contentions to the contrary, we see nothing 
unreasonable about NASA's concern that ADF lacked experience 
performing a contract of this magnitude as the prime contractor.  
Among other things, NASA expects a significant downsizing of the SETAR 
II effort halfway through performance of this contract (Tr. at 194), 
and predicted that the attendant management challenges would best be 
met by an offeror with past experience as a prime contractor, rather 
than as a subcontractor.  Initial Contracting Officer's Statement, 
supra, at 4.  

As a second example, we also see nothing unreasonable about the 
agency's decision to temper the favorable past performance reviews 
given ADF by NYMA.  As the record shows, NYMA has a direct economic 
stake in a favorable outcome for ADF.  In addition, this tempering of 
NYMA's review of ADF should not have been a complete surprise to the 
company.  Our review of the reference form included within the RFP 
reveals that the form asks the company supplying the past performance 
information if a corporate or business relationship exists between the 
supplier of the information and the company being evaluated, and if 
so, to explain the relationship.  RFP  sec.  J, Attach. F at 1.  Simply 
put, this inquiry provides an appropriate safeguard against an abuse 
of the past performance reporting system, and we think the agency 
evaluators made reasonable use of the information it generated in this 
situation.

With respect to whether the agency's evaluation of relevant experience 
and past performance was compromised by a latent ambiguity in the RFP, 
and by its decision not to disclose certain unfavorable past 
performance information to ADF during discussions, we reach a 
different conclusion.  As set forth below, we conclude that ADF's 
reasonable interpretation of the RFP caused its past performance 
proposal to be evaluated more unfavorably than Dynacs's proposal, and 
we conclude that the agency's award fee discussions with a prime 
contractor on an earlier contract were not sufficient to provide 
notice to ADF--the subcontractor in that procurement--of NASA's 
concerns.

An ambiguity exists where two or more reasonable interpretations of 
the terms or specifications of the solicitation are possible.  
Moreover, a party's particular interpretation need not be the most 
reasonable to support a finding of ambiguity; rather, a party need 
only show that its reading of the solicitation provisions is 
reasonable and susceptible of the understanding that it reached.  
Sciaky, Inc., B-261787.2, Nov. 8, 1995, 95-2 CPD  para.  269 at 4. 

The evidence in the record shows that potential offerors were 
concerned about the relationship between the reference forms to be 
supplied with an offeror's proposal, and the five-page narrative, 
prior to the submission of proposals.  RFP, Attach. 1, Industry 
Briefing Questions, Oct. 8, 1997, questions 8, 35, and 40.  In 
response to question number 8 during this briefing, NASA answered in 
the affirmative when a potential offeror asked if the narrative 
information should augment the information provided on the forms.  As 
described above, ADF used its five-page narrative to provide greater 
detail about the underlying contracts with its two references, and 
greater detail about the two references for each of its two 
subcontractors; Dynacs, on the other hand, used its narrative to 
expand on its two references, and then provided information about six 
other prior contracts it considered relevant to the SETAR II effort.  
Both ADF and Dynacs argue that their narratives were used to "augment" 
their references.

ADF argues that because it was limited to providing information about 
its two references, and because it concluded that its most important 
references would be those where it had worked as a subcontractor on 
the previous SETAR I effort [deleted], it did not have an opportunity 
to provide past performance information on other contracts that would 
have shown its experience as a prime contractor.  Conversely, ADF 
argues that Dynacs's interpretation permitted it to unfairly submit 
past performance information about eight different prior contracts, 
and to demonstrate a broader range of experience to NASA's evaluators.  
NASA responds that ADF's interpretation of the solicitation was 
unreasonable on the basis that the common understanding of the meaning 
of the word "augment" is to increase.  Thus, NASA contends that the 
only meaning offerors could reasonably take from the RFP was that they 
could provide information about additional contracts in their past 
performance narratives.

We disagree.  Our review of the RFP, including the questions and 
answers attached to it, the proposals themselves, and the evaluation 
materials, leads us to conclude that ADF's interpretation of the RFP's 
instructions to offerors was as reasonable as the interpretation 
offered by NASA and Dynacs.  In fact, not only could an offeror 
reasonably conclude that the scope of the narrative was limited to the 
contracts identified on the reference forms, but this reading is 
consistent with the tone of the other questions raised during the 
industry briefing.  While we will not set forth their entire text 
here, our reading of the related questions 35 and 40, and the agency's 
response to them, supports ADF's interpretation of the RFP's 
instruction about the relationship between the proposal narrative and 
the reference forms.[8]  

While we recognize that any prejudice to ADF was ameliorated somewhat 
by its ability to provide detail in its narrative regarding the past 
experience of its subcontractors, a review of the two proposals leads 
us to conclude that if ADF had the opportunity, within the constraints 
of the page limitation, to detail a broader portrait of its past 
experience--as Dynacs did in its proposal--ADF may have been able to 
avoid some of the unfavorable evaluation conclusions NASA raised 
regarding its proposal.  Compare ADF Proposal, Vol. III at 1-5 with 
Dynacs Proposal, Vol. III at 1-5.  In addition, this situation was 
exacerbated by NASA's reasonable decision to accord less weight to the 
favorable review from NYMA because of the ongoing economic 
relationship between the two companies.  ADF, which reasonably limited 
its narrative to detailing two prior contracts--only to have one of 
the two references largely, but reasonably, discounted--was then 
compared to an offeror who reasonably expounded on eight related 
contracts.  Under circumstances such as these, we conclude that the 
differing reasonable assumptions of these offerors about the RFP's 
requirements did not permit competition on an equal basis.  Sciaky, 
Inc., supra, at 4; Wheeler Bros., Inc.; Defense Logistics 
Agency--Recon., B-214081.3, Apr. 4, 1985, 85-1 CPD  para.  388 at 6.

Our final consideration in the area of relevant experience and past 
performance is whether NASA was required to advise ADF during 
discussions of the unfavorable review of its past performance from one 
of its references.  For the reasons below, we believe this information 
should have been discussed during negotiations.

There is no dispute between the parties about the general requirement 
found at FAR  sec.  15.610(c)(6)--namely, that agencies holding discussions 
must permit offerors an opportunity to respond to past performance 
information obtained from references on which the offeror has not had 
a previous opportunity to comment.  See generally American Combustion 
Indus., Inc., B-275057.2, Mar. 5, 1997, 97-1 CPD  para.  105 at 9-11.  
Instead, NASA argues that ADF received its comment opportunity when 
the issue in question was raised during the award fee discussions on a 
prior contract.

During the course of the hearing held in connection with this protest, 
both the SEC Chairman and the contracting officer's technical 
representative (COTR) described the award fee sessions held during 
both NYMA's and [deleted] prior contracts--the referenced contracts 
for which ADF served as a subcontractor.  Tr. at 240-43, 256-61.  The 
testimony was that, as a general matter, a subcontractor does not 
attend the award fee evaluation sessions between the agency and the 
prime contractor.  Tr. at 241.  The COTR also explained that NASA does 
not become involved in award fee discussions between prime contractors 
and subcontractors, and that a subcontractor has no opportunity to ask 
NASA to review the outcome of these discussions.  Tr. at 259-61.  In 
addition, the COTR admitted that since NASA does not attend award fee 
discussions between prime contractors and their subcontractors, the 
agency does not know the nature of the exchange between the two 
parties.  Tr. at 259-60.

Generally, award fee discussions may be sufficient, in some 
circumstances, to meet the requirements of FAR  sec.  15.610(c)(6).  In 
fact, FAR  sec.  42.1503(b)--found within FAR Subpart 42.15, which 
describes a formal past performance reporting system to be implemented 
beginning January 1, 1998, and which was not in place at the time NASA 
negotiated this contract--expressly provides that such award or 
incentive fee evaluations will suffice to meet the requirement for an 
opportunity to comment.  Despite this guidance, however, we do not 
agree that an agency can satisfy this requirement for an opportunity 
to comment when the award fee discussions upon which it relies were 
held with a different party--i.e., the prime contractor on the earlier 
contract, for whom ADF served as a subcontractor.

We reach this conclusion based on the testimony received in this case 
which indicates that award fee discussions with a prime contractor--at 
least as conducted by NASA--do not generally afford a subcontractor 
any meaningful role in the exchange that is held as part of the award 
fee evaluation.  In our view, the second-hand transmission of 
information from the prime contractor to the subcontractor will not 
normally provide the kind of opportunity for exchange and review 
anticipated by the requirements of FAR  sec.  15.610(c)(6).  Accordingly, 
we conclude that NASA was required to raise during discussions with 
ADF information received from ADF's references on which the firm had 
no prior opportunity to comment.  This information includes, at a 
minimum, the information provided by [deleted] that formed the basis 
for the evaluation weakness that ADF might have [deleted].

COST ADJUSTMENT

ADF contends that NASA unreasonably adjusted its proposed costs upward 
by $1.99 million, and that the biggest portion of the adjustment was 
based on a determination that ADF [deleted].  SEC Final Report, Dec. 
15, 1997, at 5.  Based on our review of the record, and the testimony 
received at the hearing, we conclude that the adjustment challenged by 
ADF was reasonable.

The RFP here anticipated award of a hybrid contract expected to 
contain approximately 10-percent fixed-price and 90-percent 
cost-plus-award-fee task orders.  RFP Cover letter, Sept. 30, 1997, 
Attach. 1 at 1; RFP  sec.  B.2, L.14.  Although the RFP identified an 
average work year of 2,080 hours and a workforce of 315 employees, RFP  sec.  
L.28 at L.22, offerors were allowed to use whatever number of hours or 
employees they thought was appropriate.  Offerors were also allowed to 
develop their own estimates of the number of productive hours for the 
effort, and to provide support for the number of claimed hours.[9]  
RFP, Attach. 1, Industry Briefing Questions at question 20.

In its proposal, ADF explained that it was using "a [deleted].  ADF 
Proposal, Vol. II, Cost, Oct. 30, 1997, at 6.  Section 3.2 of the 
proposal identified a total skill mix of [deleted] employees.  Id. at 
4.  The skill mix used by ADF [deleted].  RFP  sec.  L.28.

During negotiations, NASA asked ADF to explain the assumptions used in 
its proposal regarding a standard workyear.  In a second question, 
NASA also noted ADF's use of a productive workyear of [deleted] hours, 
and asked:

     Where are the non-productive hours costed (i.e., which cost 
     category and which cost element within the cost category) and how 
     many hours are costed in each cost category.  BE VERY SPECIFIC!!

NASA Letter to ADF, Dec. 9, 1997, Attach. 1, questions 4-5.

In response, ADF confirmed its use of [deleted] hours for a standard 
workyear, as set forth at [deleted], and provided a fact sheet to 
detail its deductions from the [deleted] figure to reach the [deleted] 
productive hours included in its proposal.  In reviewing this list of 
reductions, NASA learned that in two instances--[deleted].  SEC Final 
Report, Dec. 15, 1997, at 5; Tr. at 219.

During the hearing, the Chairman of the SEC explained that the panel's 
cost specialist concluded that ADF could not reasonably [deleted], and 
also concluded that it was not reasonable to compare ADF's resulting 
lower proposed costs with the proposed costs of the other two 
offerors.  Tr. at 219-21.  Thus, for purposes of the agency's most 
probable cost review, NASA [deleted].  Id.  ADF argues that this 
adjustment was unreasonable.

When an agency evaluates proposals for the award of a 
cost-reimbursement contract, an offeror's proposed estimated costs are 
not dispositive, because regardless of the costs proposed, the 
government is bound to pay the contractor its actual and allowable 
costs.  FAR  sec.  15.605(c) (June 1997).  Consequently, a cost realism 
analysis must be performed by the agency to determine the extent to 
which an offeror's proposed costs represent what the contract should 
cost, assuming reasonable economy and efficiency.  CACI, Inc.--Fed., 
B-216516, Nov. 19, 1984, 84-2 CPD  para.  542 at 5.  Contracting officers 
are required to document this evaluation, FAR  sec.  15.608(a)(1) (June 
1997), and, when properly documented, our review of an agency's 
exercise of judgment in this area is limited to determining whether 
the agency's cost evaluation was reasonably based and not arbitrary.  
General Research Corp., B-241569, Feb. 19, 1991, 91-1 CPD  para.  183 at 5, 
recon. denied, American Management Sys., Inc.; Department of the 
Army--Recon., B-241569.2, B-241569.3, May 21, 1991, 91-1 CPD  para.  492 at 
7-8; Grey Adver., Inc., B-184825, May 14, 1976, 76-1 CPD  para.  325 at 
27-28.

We conclude that there was nothing unreasonable about NASA's 
adjustment to ADF's proposed costs [deleted].  As a point of 
comparison, we note that in two other areas--[deleted]--NASA accepted 
ADF's explanation [deleted].  For the two categories at issue here, 
however, we think NASA's approach was a sensible attempt to ensure 
that the proposal reflected all of the probable costs that might be 
incurred.  [deleted], NASA reasoned that the government would still be 
liable for the cost of the time because [deleted].  Thus, NASA decided 
that ADF's proposal should reflect a cost for the time in some 
category in the proposal--rather than [deleted], as ADF did.  Our 
review of this logic leads us to conclude that NASA's probable cost 
adjustment in this area was reasonable.  

ADF's contention that the [deleted] should have been accepted by NASA 
is also undercut by the terms of its own proposal.  ADF's claim is 
premised upon an assumption that the agency had no basis in the record 
to support a conclusion that [deleted].  However, NASA's 
interpretation that these were [deleted] was clearly understood by 
ADF, as shown in its cost proposal at page 6.[10]  In addition, ADF's 
sparse explanation during the negotiations for its decision to offer 
the [deleted] hours as [deleted] cannot reasonably be viewed as 
sufficient to override NASA's concern [deleted].  Thus, we conclude 
there was nothing unreasonable about the agency's decision to add to 
the proposal the probable costs associated with this time.

Finally, ADF argues that its challenge to NASA's probable cost review 
should be sustained because the agency did not adequately document its 
decision.  FAR  sec.  15.608(a)(1) requires contracting officers to 
document cost evaluations.  While we agree that a more complete, 
written, contemporaneous record of the cost considerations at issue 
here should have been prepared, we cannot agree that there is no 
evidence in the record of the judgments that were made.  NASA included 
in its final source selection materials an explanation of its 
adjustments--albeit cryptically brief--and none of the more detailed 
explanations offered during the course of this protest conflicted with 
those materials.  Accordingly, we conclude that NASA met its 
requirement to document the decisions it made in sufficient detail to 
allow us to judge the rationality of the agency's determinations.  PHP 
Healthcare Corp., B-251933, May 13, 1993, 93-1 CPD  para.  381 at 7.

CONCLUSIONS AND RECOMMENDATION

As explained above, we conclude that Dynacs misrepresented the level 
of commitment it received from its key personnel, which, together with 
the agency's erroneous conclusion that the proposal offered "signed 
commitments," led to a material misevaluation of Dynacs's proposal 
under the key personnel subfactor within the mission suitability 
evaluation factor.  We also conclude that the misevaluation of the key 
personnel portion of Dynacs's proposal had a ripple effect in other 
areas of the mission suitability evaluation as well.  Further, we 
conclude that NASA was required to discuss with ADF adverse 
information received from its past performance references upon which 
ADF had been given no meaningful opportunity to comment.  Finally, we 
conclude that ADF was misled by a latent defect in the solicitation 
instructions regarding the past performance portion of the proposal 
that resulted in ADF's receipt of a lower score under the relevant 
experience and past performance evaluation factor than it might 
otherwise have received.

In attempting to fashion the appropriate remedy here, we begin with 
ADF's assertion that Dynacs should be barred from further 
participation in this procurement based on its misrepresentation of 
the availability of its proposed key personnel, following our holding 
in Informatics, Inc., supra.  While the preliminary clearance process 
Dynacs used here did not rise to the level of a commitment between it 
and its proposed key personnel, we do not find the same level of 
disregard for the truth that we found in the Informatics case.  In 
that case, the awardee responded to an agency question during 
discussions asking the nature of the commitments received from the 
incumbent personnel.  The awardee asserted that it had surveyed 60 of 
95 incumbent personnel to ascertain their availability, and--in a 
detailed written explanation of the results of that survey--claimed 
that a substantial percentage of those employees were either committed 
or would probably join the company.  In fact, our review showed that 
59 of the employees had not even been contacted by the awardee during 
the period the awardee claimed to have conducted its survey.  Dynacs's 
misrepresentations, in contrast, were less pervasive in nature, and 
were compounded by agency actions during the evaluation.  Under these 
circumstances, we do not believe it would be appropriate to bar Dynacs 
from further participation in this competition.

We recognize, however, that if a new round of BAFOs is received and 
reevaluated Dynacs will continue to benefit from its earlier 
misrepresentations.  For example, each of the key employees named by 
Dynacs has since accepted employment with the company.  As a result, 
any reevaluation of the proposal would appropriately continue to 
reflect a high level of certainty that these individuals will be 
available to perform as the proposal promised.  In addition, some of 
the ripple effects from the claimed availability of these employees 
that we noted earlier will remain appropriately credited to the 
proposal.  Thus, it does not appear that a reevaluation can return the 
parties to their positions before the agency's error.  

Specifically, if proposals were reevaluated it is unlikely that Dynacs 
would, at this juncture, lose any points in the area of mission 
suitability.  Thus, even if we assume that ADF could recapture nearly 
every available lost point in this area, a reevaluation would result 
in a tie under the mission suitability factor (with ADF's rating being 
raised to excellent, and Dynacs retaining its excellent rating).  
Similarly, even assuming that ADF's rating under the relevant 
experience and past performance factor was raised from very good to 
excellent, the result again would be a tie between the two offerors.  
Finally, given that we find nothing unreasonable in the agency's 
evaluation of probable costs, Dynacs's probable cost would remain 
lower than ADF's by approximately [deleted].  Under these 
circumstances, while we find that ADF was prejudiced by the evaluation 
errors at the time they were made, we see no basis to conclude that 
ADF could prevail in a recompetition.  Accordingly, we do not believe 
it would be appropriate to recommend a reevaluation or that Dynacs's 
contract be terminated.  Instead, we recommend that ADF be reimbursed 
for the cost of preparing its proposal to participate in this 
competition.  Continental Maritime of San Diego, Inc., B-249858.2, 
B-249858.3, Feb. 11, 1993, 93-1 CPD  para.  230 at 8, aff'd, B-249858.4, 
Mar. 10, 1993.    

We also recommend that the protester be reimbursed the reasonable cost 
of filing and pursuing its protest, including attorneys' fees.  4 
C.F.R.  sec.  21.8(d)(1) (1997).  In accordance with 4 C.F.R.  sec.  21.8(f)(1), 
ADF's certified claim for such costs, detailing the time expended and 
the costs incurred, must be submitted directly to the agency within 60 
days after receipt of this decision.  

The protest is sustained.

Comptroller General
of the United States

1. Thus, the predecessor contract and the current contract have been 
referred to, respectively, as SETAR I and SETAR II (for scientific, 
engineering, technical, administrative, and related tasks).

2. Since the third competitive range offeror did not participate in 
this protest, and since its proposal was generally evaluated less 
favorably than the proposals of ADF and Dynacs, we have not included 
the evaluation results for the third offeror's proposal in this 
decision. 

3. The testimony regarding the other two individuals was as follows:  
"[w]e basically met with [Dr. B] to determine if he would be willing 
to come to work for Dynacs should we be fortunate enough to win the 
contract," Tr. at 109; and "[w]e had requested that he [Dr. C] also, 
if we were fortunate enough to win the contract, would he, in fact, 
come to work for our company,"  Tr. at 111-12.  

4. Dynacs's Proposal, Vol. I at 25.

5. For the record, we deny the protester's allegation related to 
Dynacs's fourth key area manager--i.e., that Dynacs crafted its 
proposal to attempt to receive credit for an individual it did not 
offer, and thus Dynacs misrepresented (and NASA misevaluated) the 
availability of this individual.  In this instance, the proposal 
clearly explained that the individual in question was not available to 
perform the contract, and clearly identified the individual Dynacs was 
proposing instead.  Dynacs Proposal, Vol. I at 26-27.  The SSO 
apparently recognized that the agency evaluators might still be hoping 
that the unavailable individual would materialize, and stated in the 
final selection document that he "consider[ed] the potential 
nonavailability of a key Microgravity Project Manager in the Dynacs 
proposal to be of greater significance than the SEC."  Source 
Selection Statement, Dec. 16, 1997, at 8.  Given this record, we see 
no basis to conclude, as ADF argues, that the SSO's recognition of the 
manager's potential nonavailability suggests that NASA viewed him as 
available--and thus misevaluated the proposal.

6. As a further example, the record shows that at least one of the 
three incumbent key employees at issue here accepted a significant 
reduction in salary in order to remain employed on the contract.  Tr. 
at 164-65, 173.  Again, if an issue like this had been apparent in the 
proposal, the evaluators might have been concerned about the company's 
ability to retain incumbent personnel, and Dynacs might not have 
received the strong evaluation it obtained.

7. As we have stated in prior cases, we are aware that the reality in 
the current government contract market is that incumbent personnel to 
a large degree follow the award of contracts.  ManTech Advanced Sys. 
Int'l, Inc., supra, at 13.

8. Specifically, questions 35 and 40, and the responses thereto, 
indicate a concern by an offeror, or offerors, that a competitor using 
subcontractors will have a greater opportunity to identify 
references--and to expand on them in the narrative
--than will an offeror that does not propose subcontractors.  The 
underlying premise in this concern is that an offeror that does not 
propose subcontractors will not be able to identify other contract 
experiences in the narrative, and thus will have less of an 
opportunity to demonstrate its past performance.  Reading the 
solicitation as a whole, we think these questions lend support to 
ADF's narrow reading of the RFP's instructions about the narrative 
portion of the proposal.

9. There is no definition in the RFP for the term "productive labor 
hours."  In a conference call with all the parties on April 20, 1998, 
NASA representatives explained that productive labor hours were, in 
essence, those direct labor hours that remained after the allocation 
of all other hours to overhead accounts or to categories where both 
the agency and the offeror agreed there would be no direct labor 
charge for the time to the government.  

10. As quoted above, and despite ADF's assertions to the contrary, we 
conclude that page 6 of ADF's cost proposal indicates that [deleted].  
To the extent that ADF argues that NASA unreasonably interpreted the 
proposal to be based on [deleted], we deny the protest.  For the 
record, we also note that nothing about NASA's adjustment means that 
an offeror cannot fulfill the agency's requirements using [deleted], 
as ADF asserts.