BNUMBER:  B-281241.2 
DATE:  January 25, 1999
TITLE: Ritchie Sawyer Corporation, B-281241.2, January 25, 1999
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Matter of:Ritchie Sawyer Corporation

File:     B-281241.2

Date:January 25, 1999

Thomas J. Ritchie for the protester.
Calvin D. Trowbridge III, Esq., U.S. Trade and Development Agency, for 
the agency.
Robert C. Arsenoff, Esq., and Paul I. Lieberman, Esq., Office of the 
General Counsel, GAO, participated in the preparation of the decision.

DIGEST

Protest against agency technical evaluation is denied where protester 
merely disagrees with the agency evaluators' conclusions, the 
reasonableness of which are supported by the record.

DECISION

Ritchie Sawyer Corporation (RSC) protests the award of a contract to 
Ghenene & Associates under request for proposals (RFP) No. 
TDA-98-Q-064, issued as a total small business set-aside by the U.S. 
Trade and Development Agency (TDA) for a program audit of a central 
African grant which had been awarded in 1995 to perform a feasibility 
study to develop a cellular/telecommunications switching system, and 
of a subsequent follow-up contract to a U.S. company.  The protester 
primarily alleges that the agency failed to properly consider the 
protester's low price in making the award determination and otherwise 
misevaluated the protester's technical proposal.

We deny the protest.

The RFP, issued on August 6, 1998, contemplated the award of a 
fixed-price contract for a program audit to be completed by January 
30, 1999.  Award was to be made to the offeror whose technically 
acceptable proposal offered the technical/price relationship that was 
determined to be most advantageous to the government.  RFP  sec.  M.2, at 
29.  The solicitation further provided that price was "secondary to 
technical" and that award would not necessarily be made to the 
lowest-priced offeror.  Id.  Offerors were cautioned that they should 
submit initial proposals on their most favorable terms as award might 
be made without discussions.  Id.

Technical merit was to be evaluated using two factors:  (1) Company 
and Engagement Team Qualifications (up to 80 points); and (2) Proposal 
(up to 20 points).  These factors were subdivided into weighted 
subfactors.  The Qualifications factor was divided as follows:  (a) 
education, training and auditing;
(b) demonstrated experience in providing accounting, auditing and 
management services; (c) education and training in telecommunications 
systems engineering;
(d) demonstrated international business experience with an emphasis on 
African business experience; and (e) demonstrated editorial 
experience.  The Proposal factor was divided as follows:  (a) 
demonstration of a clear understanding of the scope of the contract, 
demonstration of the qualifications of the company and staff, and full 
description of the proposed approach and procedures for completing the 
program audit; and (b) demonstration through the writing of a well 
written proposal that offeror is capable of delivering a high quality 
final report.  RFP  sec.  M.1, at 28. 
     
The RFP required the submission of a detailed employee biographical 
data sheet for each individual proposed to directly perform under the 
contract.  RFP  sec.  J.1, at 20. 
Also, the proposal instructions prescribed the submission of a table 
detailing and demonstrating each team member's experience in providing 
services similar to those for the contract to be awarded; in 
particular, the table required offerors to identify the member's 
assignment worked, the contract under which it was worked, the 
specific tasks performed and the hours worked and date of engagement.
RFP  sec.  L.7, at 26.

Six proposals were received by the August 27 closing date.  
Evaluations were conducted, as a result of which the following 
consensus assessment was reported on August 31:
                              
                             Subfactor ScoresTotal Tech.      Price

Offeror   1(a) 1(b) 1(c) 1(d) 1(e) 2(a) 2(b)        

Ghenene   15   19   14   18   10   14   5      95   $  52,750

Offeror A 14   19   13   17    9   13   5      90   $135,907

Offeror B 14   19   14   12    9   13   5      86   $157,580

Offeror C 13   14   12   17    8   10   2      76   $ 59,300

RSC       13   16    0    0    4    7   2      42   $ 38,410

Offeror D 12   15    0    0    0    1   1      29   $ 57,261
Agency Report, Tab 9.

In her September 14 award analysis, the contracting officer (CO) 
stated:

     The lowest [priced] proposal from [RSC] was not technically 
     acceptable and promised to add required expertise if awarded.  
     Though this is a fixed price contract, it is not inconceivable 
     that this contractor could ask for additional funding to 
     successfully complete the scope of work required to TDA's 
     satisfaction.  Even if no  additional funding was granted, 
     considerable time would most likely be lost in bringing the 
     report up to TDA's expectations for this work.

Agency Report, Tab 10.  In addition, the CO "determined that the 
Ghenene bid of $52,750 was the lowest [priced] technically acceptable 
offer."  Id.  Award was subsequently made to Ghenene and, following a 
debriefing, RSC filed this protest.

In its protest, RSC challenges what it terms the technical/price 
"tradeoff" represented by the award to Ghenene based on its 
higher-ranked, higher-priced proposal; in this regard, the protester 
argues that the agency failed to give proper consideration to RSC's 
low price.  RSC also challenges the evaluation of its own proposal in 
various respects.

With respect to the challenge to the "tradeoff," while the material 
prepared for the cover letter to the agency report suggests that some 
consideration was given to the significance of RSC's lower price, the 
contemporaneous record is clear that no preaward tradeoff analysis 
transpired.  What the agency in fact concluded was that, as quoted 
above, the RSC proposal "was not technically acceptable."  Because, 
consistent with section M.2 of the RFP, technical acceptability was a 
prerequisite to any award, if RSC's proposal was reasonably determined 
to be unacceptable, RSC could not properly have been considered for 
the award irrespective of its price.  A proposal that is technically 
unacceptable cannot be considered for award, even where it is the 
lowest-priced proposal and thus would offer cost savings to the 
government.  Spectrum Controls Sys., Inc., B-275505, Feb. 27, 1997, 
97-1 CPD  para.  89 at 3-4.  Because Ghenene offered the lowest priced 
technically acceptable proposal, there was no need for a 
price/technical tradeoff, and the contemporaneous record shows that 
none occurred.

Accordingly, the appropriate question here is whether the record 
supports the agency's finding that RSC's proposal was technically 
unacceptable.  The evaluation of technical proposals is a matter 
within the discretion of the contracting agency since the agency is 
responsible for defining its needs and the best way of accommodating 
them.  In reviewing an agency's evaluation, we will not reevaluate 
proposals, but instead will examine the agency's evaluation to ensure 
it was reasonable and consistent with the solicitation's stated 
evaluation criteria.  An offeror's mere disagreement with the agency 
does not render the evaluation unreasonable.  Teleport Communications 
Group, B-277926.2, Sept. 17, 1998, 98-2 CPD  para.  72 at 3.

Although the evaluators found that RSC had good accounting and audit 
experience, they found that the proposal did not provide details 
regarding education in telecommunications systems engineering.  They 
further found that RSC's proposal lacked a demonstrated international 
business experience, particularly on telecommunications projects.  
They downgraded the proposal for failing to identify a professional 
editor, failing to provide the required detailed biographic data 
sheets and merely providing cursory biographical material, and failing 
to provide a detailed table of experience as required by the RFP.  
Finally, they found that the technical proposal merely parroted the 
RFP's scope of work without demonstrating an understanding of what was 
required or clearly demonstrating RSC's approach to the project.

With respect to telecommunications systems education and training, RSC 
concedes that its proposed engineer has no such credentials, takes 
issue with the need for such specific expertise, and argues that, 
should the need arise during performance for a trained engineer with 
this expertise, the firm has the ability to retain an expert.  With 
respect to international business experience, and African experience 
in particular, the protester refers to its conceded lack of such 
experience and argues that this requirement is minor in nature insofar 
as most of the work will not be performed overseas.

With respect to the failure to identify a professional editor in its 
proposal, RSC again characterizes this as minor and notes that its 
management proposal stated that it would hire an editor upon contract 
award. With respect to the failure to submit detailed biographical 
data sheets, RSC essentially disagrees with the agency's conclusion 
that the materials submitted in lieu of the sheets were insufficiently 
detailed.

With respect to the failure to submit a detailed table of experience, 
RSC simply points out that, as it stated in its proposal, a lack of 
time precluded it from gathering the necessary information to complete 
the table and that, also as the proposal stated, the firm would be 
prepared to do so if retained in the competitive range for further 
consideration.  Finally, RSC does not deny that its proposal parroted 
the RFP's scope of work.

If we view the protester's objections as essentially taking the 
position that the RFP requirements which it failed to satisfy were 
unnecessary or overly restrictive, RSC's post-award protest is not 
timely because protests based on alleged improprieties in a 
solicitation which are apparent prior to the time set for receipt of 
initial proposals must be filed prior to that time.  Bid Protest 
Regulations, 4 C.F.R.  sec.  21.2(a)(1) (1998).

In the alternative, RSC's assertions merely reflect its disagreement 
with the evaluators regarding the significance of the shortcomings in 
RSC's proposal.  RSC  does not dispute that the requirements that its 
proposal failed to satisfy were clear, with assigned weights in the 
RFP.  Rather, the protester simply characterizes the conceded and 
obviously material shortcomings in its proposal as minor in nature, or 
as matters that it could later rectify; this subjective disagreement 
simply does not provide any basis to conclude that the agency 
evaluation was unreasonable.  Teleport Communications Group, supra. 
 
The protest is denied.

Comptroller General
of the United States