BNUMBER:  B-278897.4 
DATE:  May 12, 1998
TITLE: WP Photographic Services, B-278897.4, May 12, 1998
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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:WP Photographic Services

File:     B-278897.4

Date:May 12, 1998

Trisa J. Thompson, Esq., and J. Gregory Correnti, Esq., Seyfarth, 
Shaw, 
Fairweather & Geraldson, for the protester.
Marian Sullivan, Esq., and Martin McAlwee, Esq., Department of the Air 
Force, for the agency.
Linda C. Glass, Esq., and Paul I. Lieberman, Esq., Office of the 
General Counsel, GAO, participated in the preparation of the decision.

DIGEST

Agency reasonably determined to exclude protester's proposal from the 
competitive range where the agency concluded, on the basis of an 
evaluation which was reasonable and consistent with the solicitation 
evaluation criteria, that the proposal had no reasonable chance of 
being selected for award because major revision was  necessary to 
correct substantial deficiencies in the relatively high-priced 
proposal.  

DECISION

WP Photographic Services protests the exclusion of its proposal from 
the competitive range under request for proposals (RFP) No. 
F08650-96-R-0415, issued by the Department of the Air Force for visual 
information end products and technical services in support of 
pre-launch, launch, post-launch, and non-launch operations, also 
called the Visual Information Technical Contract (VITC).  WP contends 
that the elimination of its proposal from the competitive range lacked 
a reasonable basis and was otherwise improper.

We deny the protest.

The RFP, issued on May 20, 1997, contemplated the award of a 
fixed-price, indefinite-delivery, indefinite-quantity, labor-hour 
contract for a base period with four 1-year options.  The purpose of 
the contract is to obtain visual imaging end products for launch and 
non-launch events for the 45th Space Wing and NASA's Kennedy Space 
Center.  The RFP stressed that the VITC was one of the largest 
contracts of its type in the Air Force and the quality and timeliness 
of its products and services have a far-reaching effect.  The RFP 
further stressed that the critical nature of the requirement dictates 
that full support capability be available on short notice with quick 
turnaround delivery times and that the contractor must be fully 
capable of simultaneous operation for the various launch programs.  
One of the significant requirements of the solicitation was the 
offeror's preparation of a VITC statement of work (SOW) incorporating 
the stated requirements of the RFP.

The RFP provided for a best value award to be determined by an 
integrated assessment of the cost criterion, the specific criteria, 
assessment criteria, proposal risk, performance risk, and general 
considerations.  The RFP listed the following criteria:

        (1)  Technical/Management
             (a) Project Management
             (b) Image Acquisition/Processing/End Products

        (2)  Cost
             (a) Completeness
             (b) Reasonableness
             (c) Realism

        (3)  General Considerations

All technical evaluation factors, when combined, were approximately 
equal to cost.  General considerations were of lesser importance but 
were to be an important consideration in the award decision.  The RFP 
also provided that proposals would be evaluated for proposal risk, 
which would involve an assessment of the risk associated with the 
offeror's proposed approach to accomplish the requirements.  Proposals 
were also to be evaluated for performance risk, which would involve an 
assessment of the probability of the offeror successfully 
accomplishing the proposed effort based on the offeror's demonstrated 
relevant present and past performance.[1]  

[Deleted] initial proposals were received by the June 20, 1997 closing 
date.  After evaluation of the initial proposals, the Air Force 
determined that all proposals contained informational deficiencies and 
format errors.  Amendment No. 0003 was issued to clarify common 
problem areas and allow all offerors an opportunity to revise their 
proposals.  Each offeror submitted a revised proposal by the September 
19 closing date.  Each revised proposal was evaluated for performance 
and proposal risk in addition to being evaluated under a 
color/adjectival rating scheme for each of the evaluation factors.[2]  
A competitive range briefing was provided by the evaluators to the 
Source Selection Authority.  The proposals of [deleted] firms, 
including WP, were excluded from the competitive range.  The agency 
reports that the competitive range was determined on the basis of 
price and technical merit, including proposal deficiencies and their 
potential for correction and the possibility of selection for award.  
Offerors were notified of exclusion from the competitive range by 
letters dated December 12, 1997.  A debriefing was held with WP on 
January 23, 1998, in which the agency identified areas of WP's 
proposal needing improvement.  WP filed this protest on February 2, 
1998.[3]  

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.  Beneco Enters., Inc., B-278591, Feb. 17, 1998, 98-1 CPD   para.  91 
at 3.  When a proposal is technically unacceptable and would require 
major revisions to become acceptable, the agency is not required to 
include it in the competitive range.  Laboratory Sys. Servs., Inc., 
B-256323, June 10, 1994, 94-1 CPD  para.  359 at 2.  Even where a proposal 
is fully acceptable technically (or could be rendered so through 
discussions), it may properly be excluded from the competitive range 
if, in light of the competing proposals, the contracting officer 
determines that the proposal has no reasonable chance of award.  Curry 
Contracting Co., Inc., 
B-254355, Dec. 13, 1993, 93-2 CPD  para.  334 at 3.  In reviewing an 
agency's determination to exclude a proposal from the competitive 
range, we apply the standard used in reviewing all aspects of an 
agency's technical evaluation of proposals:  we review the record to 
determine whether the agency's judgment, including the judgment that a 
particular proposal did not have a reasonable chance of award, was 
reasonable, supported by the record, and consistent with the 
applicable evaluation criteria.  Tri-Services, Inc., B-256196.4, Sept. 
30, 1994, 94-2 CPD  para.  121 at 2.  

Here, under the first listed technical/management factor, project 
management, WP's proposal was evaluated with a color rating of red, 
with no strong points and several weak points.  A total of 24 
deficiency reports (DRs) and 60 clarifications requests (CRs) were 
generated as a result of WP's evaluation under this area.  Under the 
second factor, WP's proposal generated and received a color rating of 
red, with no strong points and numerous weak points.  WP also received 
a high proposal risk rating because the evaluators were concerned 
about quality, delay, and nonsupport issues.  WP did receive a low 
rating for performance risk based on its 
predominantly satisfactory past performance ratings.  Finally, WP's 
proposed price was higher than that of all but one of the other 
offerors.

The agency's determination that WP was outside of the competitive 
range with no reasonable chance for award was particularly based on 
WP's failure to demonstrate an approach to receiving workorders, 
deploying resources, and performing work resulting in consistently 
acceptable image files/end products in required time frames.  
Specifically, the agency found that WP:      

     a.  Fail[ed] to meet contract requirements by stating in . . . 
     its response to Amendment No. A0003 . . . that "WP Photo can not 
     promise in advance that we will positively make all timeliness" 
     relevant to 3 back-to-back launch and landing events and 
     non-launch events.

     b.  Propos[ed] the use of nonavailable Government-provided 
     services/support.

     c.   Fail[ed] to describe setup and operational processes to 
     include personnel,  equipment, and numbers and types of cameras, 
     lenses, trackers, and film for   each type of vehicle 
     launch/landing events.

     d.  Fail[ed] to describe technical processes relative to over and 
     above image    acquisitions.

     e.  Fail[ed] to describe technical processes relative to camera 
     and optical repair capabilities.

     f.  Fail[ed] to provide specifications for all film products 
     listed in Exhibits A, B,  and C.

     g.  Fail[ed] to provide a users guide for customers.

     h.  Fail[ed] to provide a phase-in plan ensuring a smooth and 
     nondisruptive     transition . . . .

     i.  Propos[ed] a limited management staff with numerous 
     responsibilities.  

This information was provided to WP during the debriefing held on 
January 23.

In its initial protest, WP argued that the Air Force's competitive 
range determination was flawed because it failed to consider costs or 
past performance and failed to evaluate the areas of 
technical/management as required by section M of the solicitation.  As 
explained above, the record establishes that the agency considered 
both cost and past performance in making the competitive range 
determination.  In addition, the agency evaluated the technical and 
management areas of the proposals as required by section M.

WP also argued that in view of the fact that the solicitation required 
offerors to write their own SOW and propose a plan based on general 
guidance from the solicitation which necessarily invites variations in 
proposal responses and an increase in CRs and DRs, the elimination of 
its proposal from the competitive range lacked a reasonable basis.  WP 
maintained that the deficiencies cited by the agency did not pose an 
insurmountable obstacle and could readily be addressed through 
discussions.  The agency maintains that WP's proposal did not 
reasonably address the essential requirements of the solicitation and 
contained substantial technical drawbacks that would require virtually 
an entirely new technical proposal in order to become technically 
acceptable.  

The record supports the agency's determination to exclude WP's 
proposal from the competitive range.  In response to a solicitation 
that specifically cautioned offerors about the need for timely 
delivery of image files/end products, WP stated in its proposal, in 
bold print, that it could not promise in advance that it would 
positively make all time frames.  This provided the agency with a 
reasonable basis to conclude that WP was not committing to fulfilling 
an essential requirement of the solicitation.  Further, as outlined 
above, the agency downgraded WP's proposal for numerous failures to 
provide for essential requirements of the solicitation, such as:  
failing to provide a user's guide; failing to provide technical 
descriptions for meeting government equipment maintenance support; 
failing to provide technical descriptions for meeting presentation 
services; failing to provide a contingency plan; and failing to 
provide maximum daily production capacity.  Further, WP's proposal 
generated almost three times as many DRs and CRs as any other 
offeror's and was [deleted].  There were no strong points in WP's 
proposal and its proposal risk assessment was high because the 
evaluators concluded that WP's approach would result in nonsupport, 
delays, inconsistent quality, delayed launch analysis/news releases, 
and increased equipment failure.  WP did not directly challenge or 
rebut the agency's substantive findings about its inadequate response 
to essential requirements, other than asserting that the CR's and DR's 
were duplicative, and simply arguing that these matters could have 
been addressed during discussions.  However, in light of its 
determination that WP's proposal was technically unacceptable with no 
strong points and numerous weak points, and would need major revisions 
to become acceptable, the agency reasonably eliminated the proposal 
from the competitive range on the basis that the proposal did not have 
a reasonable chance for award.

In its comments on the agency report, WP argues that the Air Force 
failed to treat all offerors fairly and equally because the agency 
admitted [deleted] proposals back into the competitive range that 
received the same color code assessment as did WP, and that WP 
received a superior technical/management risk assessment than 
[deleted] of those offerors.  While the protester is correct in that 
the [deleted] proposals admitted back into the competitive range had 
the same color code assessment as did WP, the record shows that those 
[deleted] offerors were more favorably evaluated within the same 
range.  [Deleted] offerors' proposals generated significantly fewer 
CRs and DRs, [deleted], than did WP and [deleted] proposals were 
credited with having several strong points whereas WP's proposal did 
not have any strong points.  WP also alleges that it was not treated 
fairly because it had a superior technical/management risk assessment 
than the [deleted] proposals readmitted to the competitive range.  
However, while WP's proposals did receive a better performance risk 
rating than those [deleted] offerors, those proposals received a 
moderate performance risk rating and were [deleted] cited as having 
predominately satisfactory ratings.  Considering all of the other 
legitimate concerns that the evaluators had with WP's proposal and the 
relative rankings of the other proposals, we see no basis to conclude 
that WP has been treated unfairly.

Finally, in its comments, the protester for the first time responds to 
the agency's stated DRs.  In the majority of the instances, WP 
maintains that the agency's concerns could be resolved during 
discussions and in other instances WP contends that the generated DR 
did not reflect a specific solicitation requirement.  As explained 
above, even where a proposal can be rendered technically acceptable 
through discussions, it still may properly be excluded from the 
competitive range, where, when compared to competing proposals, the 
contracting officer determines that it has no reasonable chance for 
award.  Curry Contracting Co., Inc., supra.  In any event, WP's 
challenge to these evaluations are untimely.  During a debriefing held 
on January 23, 1998, WP was specifically advised about the concerns 
the agency had with its technical proposal.  WP was also provided with 
debriefing charts that detailed all areas where the agency determined 
WP had failed to adequately addressed the requirements.  In its 
initial protest filed with our Office on February 2, WP did not 
specifically challenge the evaluation of its proposal.  Our Bid 
Protest Regulations require that protests not based upon alleged 
improprieties in a solicitation be filed not later than 10 days after 
the basis of protest is known or should have been known (whichever is 
earlier) or not later than 10 days after a statutorily required 
debriefing.  4 C.F.R.  sec.  21.2 (a)(2) (1997).  Here, during the 
debriefing, the protester was advised of the specific technical 
shortcomings of its approach and the CRs and DRs provided in the 
report merely elaborated on the areas previously identified by the 
agency as deficient.  Consequently, WP was required to raise the 
particular objections concerning the evaluation of its proposal within 
10 days of the debriefing.

The protest is denied.

Comptroller General 
of the United States

1. The possible evaluation ratings for proposal risk and performance 
risk were high, moderate, and low.

2. The color/adjectival ratings were blue/exceptional, 
green/acceptable, yellow/marginal, and red/unacceptable.

3. The other two offerors whose proposals were excluded from the 
competitive range also filed protests that were subsequently dismissed 
when the agency decided to include those proposals in the competitive 
range.