BNUMBER:  B-281836 
DATE:  April 12, 1999
TITLE: Construction Technology Laboratories, Inc., B-281836, April
12, 1999
**********************************************************************

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:Construction Technology Laboratories, Inc.

File:     B-281836

Date:April 12, 1999

Richard J. Webber, Esq., Alison J. Micheli, Esq., and Evan Stolove, 
Esq., Arent Fox Kintner Plotkin & Kahn, for the protester.
Kevin P. Connelly, Esq., Stuart B. Nibley, Esq., and Adria Benner, 
Esq., Seyfarth, Shaw, Fairweather & Geraldson, for Professional 
Services Industry, Inc., an intervenor.
Steven M. Rochlis, Esq., Federal Highway 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.  Protest that agency improperly credited awardee for proposing the 
incumbent's key employees is denied where (1) the solicitation 
permitted offerors to propose personnel from whom the offeror had no 
commitment, provided the offeror included a compensation package and 
detailed transition plan found sufficient to enable the offeror to 
meet the staffing requirements before contract performance; (2) the 
awardee included such a package and stated in its proposal that it 
would attempt to hire the incumbent personnel; (3) the awardee's plan 
to provide salaries at or above the level provided by the incumbent 
reasonably was evaluated as sufficient to make it likely that the 
awardee would be able to hire the incumbent employees if it prevailed 
in the competition.

2.  Challenge to the agency's conclusion that three of the awardee's 
proposed key employees met the experience requirements set forth in 
the solicitation is denied where the record shows that the agency 
reasonably concluded that at least two of the three minimally complied 
with the experience requirements, and with respect to the third, any 
shortcoming in experience is de minimis and was reasonably reflected 
in the awardee's point score in the key personnel area.

3.  Protester's assertion that the agency improperly selected the 
lower-rated, lower-priced proposal, rather than the protester's 
higher-rated, higher-priced one, is denied where the record shows that 
the cost/technical tradeoff was based on an accurate understanding of 
the strengths and weaknesses of the two proposals. 

DECISION

Construction Technology Laboratories, Inc. (CTL) protests the award of 
a contract to Professional Services Industry, Inc. (PSI)  pursuant to 
request for proposals (RFP) No. DTFH61-98-R-00087, issued by the 
Federal Highway Administration (FHWA) for engineering and technical 
services to support research activities at FHWA's Turner-Fairbank 
Highway Research Center in McLean, Virginia.  CTL, the incumbent here, 
argues that the agency improperly evaluated PSI's proposal by 
crediting PSI with the strengths of the incumbent personnel, rather 
than evaluating PSI's proposal solely on the strengths of the 
personnel offered.  CTL also argues that there were additional errors 
in the technical evaluation, that the agency performed an improper 
cost realism analysis, and that the cost/technical tradeoff was 
unreasonable.

We deny the protest.

BACKGROUND

The Turner-Fairbank Highway Research Center performs analytical 
studies, laboratory testing, and field testing of highway structures, 
as well as modeling and materials sampling.  The Center also produces 
research reports and academic papers.  The RFP was issued on August 
27, 1998, to provide engineering and technical services in support of 
the Center's Structures Laboratory.  The RFP anticipated award of an 
indefinite-quantity, cost-plus-award-fee contract for a 2-year base 
period followed by three 1-year option periods, to the offeror whose 
proposal presented the overall best value to the government.  RFP  sec.  M, 
at 62.

The RFP identified four evaluation factors, in descending order of 
importance:  technical, cost, past performance, and small 
business/minority business/minority institution participation.  Id. at 
65.  The RFP further explained that the three non-cost factors were 
significantly more important than cost.  Id.  Under the most important 
evaluation factor, technical, the RFP identified six subfactors, in 
descending order of importance.  These subfactors, paraphrased, 
include:  (1) key personnel qualifications and experience; (2) program 
manager's experience; (3) experience managing large-scale highway 
structural research and laboratory service efforts; (4) knowledge and 
experience in four areas related to highway bridge structures; (5) 
expert consultant pool; and (6) resources.  Id. at 62-64.  

The RFP, at section L, set forth specific educational and experience 
requirements for the program manager, and for the other key personnel, 
which included a research engineer, two research assistants, two 
expert technicians, and two research technicians.  Id. at 50-53.  As 
set forth below, although the RFP called for offerors to submit a 
letter of commitment from each individual proposed for a key position, 
it also permitted an alternate approach:

     Staffing proposals shall clearly identify each of the individuals 
     proposed for all Key Personnel positions identified below.  For 
     each Key Personnel position, the offeror's proposal must contain 
     a letter of commitment from the individual proposed demonstrating 
     that this individual is capable of meeting the full-time, on-site 
     requirement for that position.  In lieu of a commitment letter, 
     offerors must provide a detailed discussion of the proposed 
     compensation package and a detailed transition plan for meeting 
     the Key Personnel staffing requirements on or before the 
     effective date of the contract.  In all cases, resume's [sic] and 
     biographical summaries must be provided for the individual 
     proposed for each Key Personnel position demonstrating that the 
     individual proposed meets the qualifications and requirements 
     described herein.  The Staffing proposal must clearly demonstrate 
     that all individuals proposed meet the following minimum 
     qualifications and requirements . . . .  

Id. at 50-51.  In addition to proposing personnel, offerors were to 
address the technical requirements of the solicitation through a 
technical "dissertation."  Id. at 50.

The agency received two proposals in response to the RFP, CTL's and 
PSI's.  As the incumbent, CTL offered to provide the experienced key 
personnel currently performing the contract.  PSI proposed to retain 
in-place each of the incumbent's key personnel, but also provided a 
slate of alternate key personnel in case the incumbent key personnel 
declined employment with PSI.  PSI Initial Proposal, Vol. I at 1-2, 
6-8.  

After an initial evaluation, which noted that PSI's program manager 
and several of its alternate key personnel did not appear to meet 
experience requirements, the agency held discussions with both 
offerors.  During discussions, the agency expressly advised PSI of 
each of its identified concerns about the qualifications of PSI's 
proposed alternate personnel, and PSI's final revised proposal 
addressed each of these questions.  With respect to each of its key 
personnel, however, PSI reminded the agency that its preference was to 
retain the services of the incumbent individual if possible.  PSI 
Addendum to Technical Proposal, Response to Questions 1-3, at 1-4.

Upon conclusion of the final technical evaluation and a cost realism 
review, the agency's overall technical rating and the total estimated 
cost for these two proposals was:

                      Technical Score Total Est. Cost

          CTL              86            [deleted]

          PSI              72           $13,484,682
Price Negotiation Memorandum and Source Selection Statement, Dec. 17, 
1998, at 1.

Within the overall technical score, the agency viewed the two offerors 
as essentially equal under the most important technical subfactor, key 
personnel, "both having proposed identical staffing from the incumbent 
contract."  Id. at 15.  Under the second and third most important 
technical subfactors, program manager and experience managing 
large-scale highway structural research contracts, CTL's proposal was 
rated more highly than PSI's proposal.  After a detailed consideration 
of each proposal's relative strengths and weaknesses, the Source 
Selection Official accepted the evaluation panel's recommendation that 
PSI's lower proposed costs and sound proposal represented the best 
value to the government.  Id. at 17; Final Report of Technical 
Proposal Evaluation Committee and Recommendation for Award 
(hereinafter, the Final Evaluation Report), Dec. 16, 1998, at 7.  This 
protest followed.

DISCUSSION

Evaluation of Key Personnel

CTL argues that the agency improperly credited PSI with the experience 
of the incumbent key employees even though the incumbent employees 
were not the employees identified by PSI in its proposal.  In 
addition, CTL argues that the agency's evaluation of the employees 
named in PSI's proposal was unreasonable.  

The record in this case shows that PSI contacted each of the 
incumbent's five key personnel, received commitment letters from two 
of them, and appropriately refrained from identifying the others in 
its proposal.[1]  On the other hand, PSI repeatedly states in its 
proposal that it will attempt to hire all of the incumbent's key 
personnel, and provides evidence (including its plan to meet or exceed 
the employee's current compensation) of how it will accomplish this 
goal.  As stated above, the agency evaluation of PSI's proposal 
considered both its offer to hire the incumbent key personnel, and its 
alternate personnel, in concluding that the proposals were essentially 
equal in this area.

In CTL's view, the agency could not properly allow PSI to propose 
employees with whom it had no relationship, and could not properly 
evaluate PSI based on employees whose resumes or biographical 
summaries were not identified in PSI's proposal.  For the reasons set 
forth below, we disagree. 

The RFP, as quoted above, was clear and unambiguous in allowing an 
offeror to propose personnel from whom the offeror had no commitment.  
In lieu of a commitment, the RFP required only that the offeror 
explain how it intended to meet the key personnel requirements by the 
beginning of contract performance.  To the extent that CTL argues that 
agencies should not accept proposals to provide key personnel without 
a commitment from those personnel, CTL is raising an issue that was 
apparent on the face of the solicitation, and had to be raised prior 
to the initial closing date set for receipt of proposals.  4 C.F.R.  sec.  
21.2(a)(1) (1998). 

To the extent CTL is arguing that PSI did not, in fact, propose the 
incumbent key personnel, we again disagree.  Throughout its initial 
and final revised proposals, PSI reiterates its intent to provide as 
many of the incumbent key personnel as it is able to hire.  In 
addition, PSI's stated intent to provide the incumbent key personnel 
was not an idle claim, but was buttressed by a compensation plan 
designed to meet or exceed the compensation currently received by the 
incumbent key employees.  In our view, the agency reasonably concluded 
from this proposal that it would receive either the incumbent 
employees or the proposed alternates.  See Intermetrics, Inc., 
B-259254.2, Apr. 3, 1995, 95-1 CPD  para.  215 at 14-15.  

Since we conclude that the agency reasonably assumed it would receive 
either the incumbent employees or the alternates, we turn to whether 
it was reasonable for the agency to credit PSI with the strengths of 
the incumbent key personnel, rather than the proposed alternates.  Our 
review of prior challenges to evaluations of key personnel suggests 
that the more common approach to assessing a proposal which offers to 
hire as many incumbents as possible is to evaluate the strengths of 
the personnel whose resumes are provided by the offeror, rather than 
the strengths of the incumbent personnel pool.  See, e.g., Ebon 
Research Sys., B-261403.2, Sept. 28, 1995, 95-2 CPD  para.  152 at 5; 
Engineering Design Group, Inc., B-253066.3, Nov. 8, 1993, 93-2 CPD  para.  
307 at 6-7.  The difference here, in our view, is the solicitation 
language that permits an offeror to propose key employees from whom it 
has no commitment, provided the offeror makes a showing that it will 
be able to hire those individuals.  Once the agency concluded that PSI 
had made a sufficient showing that it was likely to succeed in hiring 
these individuals, we know of no reason why the agency could not 
proceed with considering them in the evaluation.  

Finally, we note that CTL correctly complains that PSI did not provide 
the resumes or biographical summaries of the incumbent personnel upon 
which it was evaluated, and which were required by the RFP's staffing 
language.  We will not conclude, however, that the agency acted 
unreasonably by considering these personnel under the evaluation 
scheme, given that the agency was well aware of the identity and 
qualifications of the incumbent key personnel.  See Wackenhut Servs., 
Inc., B-187299, Mar. 22, 1977, 77-1 CPD  para.  198 at 3-4.  

Our conclusion that it was reasonable for the agency to consider PSI's 
offer to hire the incumbent key personnel in evaluating PSI does not 
fully resolve CTL's challenge to the evaluation of PSI in this area.  
CTL correctly points out that there are new key personnel positions 
included in this solicitation for which there are no incumbents, and 
also argues that PSI's proposed alternate key personnel do not 
independently meet the experience requirements of the RFP.  

As stated above, the personnel to be evaluated under the key personnel 
subfactor included a research engineer, two research assistants, two 
expert technicians, and two research technicians.  RFP  sec.  L, at 50-53.  
The first two categories of personnel, research engineer and research 
assistant, present no further issue for our review.  For the single 
research engineer position, PSI stated its intent to hire the 
incumbent research engineer, and identified a backup individual.  
Since we conclude that PSI could reasonably propose the incumbent 
research engineer, and since there is no dispute that the incumbent 
individual meets the RFP's experience requirements, we need not reach 
the issue of whether the alternate research engineer met those 
requirements.  For the two research assistant positions, PSI provided 
letters of commitment for both of the incumbent research assistants, 
thus leaving no issue of unmet requirements.

For the two remaining categories, expert technicians and research 
technicians, a more detailed review is needed.  For the expert 
technician positions, the record shows that PSI contacted the 
incumbent expert technician (there was only one under CTL's existing 
contract), but was asked not to include his name in PSI's proposal.  
Affidavit of Dr. Mohammad S. Khan, Mar. 8, 1999, at 3.  PSI honored 
the request, left the name out of its proposal, identified alternative 
expert technicians, and reiterated its intent to attempt to hire the 
incumbent individual should PSI receive the contract award.  
Consistent with the approach outlined above, we find reasonable the 
agency's conclusion that PSI may rely upon the experience of the 
current incumbent expert technician to meet the requirements for one 
of the two positions.  

For the second expert technician position, the initial evaluation 
concluded that neither of PSI's alternate proposed technicians met the 
RFP's requirement for 5 years experience in structural testing.  
Initial Report of Technical Proposal Evaluation Committee, Oct. 30, 
1998, at 3.  After discussions, PSI explained that one of the proposed 
alternate technicians, Mr. Clifton Troy, would be its preferred 
partner for the incumbent technician, and provided a detailed 
explanation of his structural testing experience since 1994.  PSI 
Final Revised Proposal at 1-2.  On the strength of this explanation 
the agency concluded that "Mr. Troy's experience [is] not ideal, but 
it meets the minimum requirements of the RFP."  Final Evaluation 
Report, supra, at 3.  CTL argues that this conclusion was unreasonable 
because the response does not establish that Mr. Troy has amassed 5 
years of experience in structural testing, as opposed to occasional 
experiences over the last 5 years.

We find reasonable the agency's ultimate conclusion that Mr. Troy 
meets the experience requirement for structural testing.  As stated 
above, Mr. Troy has been employed by PSI since 1994, and the company 
claims that he had gained extensive experience in laboratory and field 
testing during that 5-year period.  In responding to the agency's 
questions, PSI provided detailed examples of the kind of structural 
testing Mr. Troy has performed.  While we recognize that PSI's 
proposal does not establish that Mr. Troy has done nothing but 
structural testing during the last 5 years, we think the protester's 
argument in this regard overstates the RFP's requirement.  We think 
the record here is sufficient for the agency to reasonably conclude 
that Mr. Troy's experience is sufficient to meet the RFP requirements. 

For the last category of key personnel, the research technicians, our 
review is similar to our review of the expert technicians.  As above, 
PSI contacted the incumbent research technician, was asked not to use 
his name, and did not do so, even though it stated its intent to hire 
the incumbent research technician if possible.  As above, we conclude 
that the agency reasonably credited PSI with having met the 
requirement for one of the two positions with the incumbent.  With 
respect to whether either of PSI's two alternate research 
technicians[2] met the RFP's experience requirements, the agency 
initially concluded that neither had the required experience working 
in a structural testing laboratory.  After discussions, PSI provided 
additional information, and the agency concluded that the reply was 
sufficient to show that the alternate research technicians were not 
ideal, but were minimally qualified.  As above, CTL argues that this 
conclusion was unreasonable.

Given that the agency reasonably credited PSI with proposing the 
incumbent for one of the two research technicial positions, our review 
of the record here need focus only on whether one of PSI's alternate 
research technicians could reasonably be found to meet the experience 
requirement for this position.  In this regard, we note that while the 
position of research technician is the lowest level of the required 
key personnel--as evidenced by the fact that the proposed individuals 
needed only a minimum of a 2-year technical degree and no specified 
period of experience--the RFP identified several specific requirements 
for the technicians.  In addition to the educational requirement, the 
RFP called for:

     Experience . . . in instrumentation used for structural testing . 
     . . demonstrated experience performing structural testing in a 
     laboratory environment, including erection of steel, casting 
     concrete, installing strain gauges and instrumentation, and 
     operation of data acquisition equipment.  IBM PC compatible 
     computer skills are also required for this position, including 
     spreadsheet, data analysis, CAD, and maintaining data base 
     software.  Experience in welding, concrete laboratory testing 
     practice, mechanical property tests of metallic materials, 
     non-destructive evaluation, and surveying are required for at 
     least one of the RT position.

RFP  sec.  L, at 52 (emphasis added). 

One of the alternates proposed by PSI for the research technician 
position is Mr. Sinara Ly.  In its response to the discussion question 
regarding the extent of his experience working in a structural testing 
laboratory, PSI explained that Mr. Ly's background is related to 
civil, construction, and structural materials testing.  PSI Final 
Revised Proposal at 4.  Also, despite the 2-year degree requirement, 
Mr. Ly has a bachelor's degree in civil engineering, and a master's 
degree in structural engineering.  In addition to his experience in 
construction inspection, Mr. Ly is certified as a concrete tester by 
the Washington Area Council of Engineering Laboratories.  

The protester is correct in its assertion that none of the information 
provided by PSI definitively answers the question regarding Mr. Ly's 
experience performing structural testing in a laboratory environment.  
Even if Mr. Ly lacks experience performing structural testing in a 
laboratory environment, however, we fail to see how this lapse is 
anything more than de minimis, arising as it does in one of several 
technical areas applicable to only one of the seven key personnel 
positions, and given that Mr. Ly meets the numerous other requirements 
in the RFP for this position.  Further, as the record shows, PSI 
received a lower point score (24.25 points of 30 available points) for 
the category of key personnel than did CTL (25.75 points of 30 
available points).  While the 30 total points available under the key 
personnel subfactor are not separately allocated among personnel 
categories, it is reasonable to assume that the difference in scores 
here reflects, in part, the relatively minor shortcoming of one of 
PSI's seven proposed key personnel.

Evaluation of Program Manager

CTL also argues that the agency improperly concluded that PSI's 
proposed program manager met the experience requirements of the RFP.  
Specifically, CTL contends that PSI's program manager did not have "5 
years demonstrated successful experience managing structural testing 
facilities," as required by the solicitation.  RFP  sec.  L, at 51.  

The initial evaluation of PSI's proposal noted that its program 
manager appeared to lack experience managing structural testing 
facilities.  In response to the discussion question pointing out this 
perceived weakness, PSI's Final Revised Proposal (at pages 4-5) 
explained that the program manager has as much as 16 years of 
structural experience, with a significant background in structural 
testing, and many years of management experience.  Based on this 
response, the agency concluded the program manager meets the RFP's 
experience requirement.  Final Evaluation Report, supra.  In the 
protester's view, however, the response does not clearly demonstrate 
that the program manager has at least 5 years experience managing 
structural testing facilities.  

We agree with the protester that there is some ambiguity remaining 
about whether PSI's program manager has demonstrated that he has the 
required experience in this category.  On the other hand, we think 
this is an area where the agency could reasonably conclude that the 
requirement has been minimally met.  In this regard,  PSI's response 
provides significant evidence of experience in precisely the areas 
covered by the RFP, even though it does not definitively answer 
whether the necessary time period managing such effort--as opposed to 
participating in it--was met.  In addition, the source selection 
document notes that the individual proposed has significant experience 
managing laboratory facilities; he is currently serving as the manager 
of PSI's Investigative Structural Testing and Evaluation Division, 
where he is responsible for managing the testing of all types of 
structural elements, systems, and materials, and has managed a number 
of laboratory facilities, including the agency's own Non-Destructive 
Evaluation Testing Laboratory, also located at the Turner-Fairbank 
Highway Research Center.  Source Selection Statement, supra, at 9, 16.  
Based on this information, we cannot say that it was unreasonable for 
the agency to conclude that the program manager "marginally meet[s] 
the RFP with respect to experience managing a structural testing 
facility," Final Evaluation Report, supra, at 3 (emphasis added).  In 
addition, as we noted above regarding the evaluation of Mr. Ly, the 
agency recognized that PSI's program manager is less experienced than 
CTL's program manager and reflected the relative difference in merit 
in the point scores allotted to the two offerors under the program 
manager subfactor under the technical evaluation factor.[3]  Id.  
Under these circumstances, we conclude that the evaluation was 
reasonable.

Cost Realism Evaluation

CTL argues that the agency's cost realism review was inadequate 
because there is no evidence in the record that the agency understood 
the reasons for the difference in the two offerors' respective fringe 
benefits and overhead costs.  As a result, CTL contends that the 
agency failed to understand that CTL's higher overhead translated to 
greater benefits for its employees, and that those greater benefits 
may not have been offset by the higher salaries PSI was offering CTL's 
incumbent employees.

Federal Acquisition Regulation  sec.  15.305(a)(1) requires: 

     When contracting on a cost-reimbursement basis, evaluations shall 
     include a cost realism analysis to determine what the Government 
     should realistically expect to pay for the proposed effort, the 
     offeror's understanding of the work, and the offeror's ability to 
     perform the contract.  

The cost realism analysis included in the record here shows that the 
agency considered in detail each of the cost elements of the CTL and 
PSI proposals.  Cost Evaluation Materials, Agency Report, Tab F.  In 
each case, the analysis compared the proposed cost elements to costs 
applicable to other contracts between the agency and these two 
offerors.  In addition, since CTL's indirect rates had not been 
audited by the agency since 1992, the agency requested a indirect rate 
review by an outside accounting firm, and used the review to further 
analyze CTL's proposed rates.  In short, our review of the cost 
realism analysis reveals nothing about the review that could be termed 
improper or unreasonable.

In our view, CTL's complaint is not with the review of cost realism, 
but with the evaluation assessment that PSI's proposed higher salaries 
for CTL's incumbent key employees would be sufficient to permit PSI to 
hire those employees.  According to CTL, PSI is hiring its incumbent 
employees at approximately 20 percent more in direct salary than those 
employees would have been paid if CTL had won the contract.  CTL's 
Comments on the Agency Report, Mar. 1, 1999, at 28.  While CTL 
apparently believes that the difference between its and PSI's overhead 
rates shows that these employees must be receiving fewer fringe 
benefits, this fact, even if true, does not invalidate either the cost 
realism review or the evaluation assessment that PSI would be able to 
retain the incumbent employees.  We find that the agency reasonably 
concluded that PSI's higher salaries would allow it to retain the 
incumbent personnel, and PSI's ability to do so since contract award 
supports this conclusion.  

Cost/Technical Tradeoff

CTL argues that the cost/technical tradeoff by which the agency 
selected PSI's lower-rated, lower-cost proposal, over the 
higher-rated, higher-cost proposal of CTL, was improper.  
Specifically, CTL claims that the tradeoff decision was based on 
wrongly assuming that the proposals were equal under the key personnel 
subfactor; minimizing the difference between the offerors' proposed 
project managers; and ignoring CTL's superiority under the fourth most 
important technical subfactor. 

Our review of cost/technical tradeoff decisions is limited to a 
determination of whether the tradeoff is reasonable and consistent 
with the solicitation's evaluation criteria.  Loral Aeronutronic, 
B-259857.2, B-259858.2, July 5, 1995, 95-2 CPD  para.  213 at 16.  For the 
reasons set forth below, we conclude that the tradeoff decision was 
proper.

As stated above, although CTL received an overall score of 86, 
compared to PSI's score of 72, the source selection official concluded 
that the two offerors were essentially equal under the key personnel 
subfactor, the most important of the technical subfactors, because 
both "proposed identical staffing from the incumbent contract."  
Source Selection Statement, supra, at 15.  CTL argues that this 
conclusion is erroneous given the difference between the two offers 
under the key personnel subfactor.  

In our view, the agency's conclusion that the proposals were 
essentially equal under the key personnel subfactor is supported by 
the point scores awarded to the two offerors, and the reliance by both 
on the same pool of incumbent key personnel.  First, as noted above, 
at the conclusion of the final evaluation CTL was awarded a point 
score of 25.75 points (out of 30 available), while PSI was awarded 
24.25 points.  These point scores reflected the considered judgment of 
the agency evaluators with respect to the pool of seven key personnel 
proposed by CTL and PSI.  Given that our review of each of the 
evaluation conclusions led us to uphold the individual assessments 
underlying these scores, we conclude that the overall assessment that 
these two offerors are essentially equal is also reasonable.  

In addition, the conclusion that the two proposals were essentially 
equal in this area was not based solely on point scores; instead, the 
record shows that for five of the seven key employees, the agency 
reasonably concluded that the two offerors were offering the same pool 
of incumbent personnel.  For the remaining two positions that did not 
exist under the previous contract, neither CTL's proposal nor PSI's 
was found without blemish.  As discussed in detail above, PSI's 
non-incumbent expert technician and research technician were both 
considered to only marginally meet the RFP's experience requirement.  
Although CTL's non-incumbent expert technician and research technician 
were considered to fully meet the RFP's requirements, the evaluators 
noted that both were temporary placements, and lowered CTL's score in 
this area to reflect the fact that the qualifications of the permanent 
staff remained unknown.  Final Evaluation Report, supra, at 2.  Under 
these circumstances, we see nothing unreasonable about the source 
selection conclusion that CTL and PSI are essentially equal under the 
most important key personnel subfactor.  

Under the second most important technical evaluation subfactor, 
program manager, the agency concluded that CTL's program manager was 
superior to the program manager proposed by PSI.  Id. at 3-4; Source 
Selection Statement, supra, at 16.  Despite this evaluated 
superiority, the source selection official noted that the program 
manager is only expected to spend a maximum of 17 percent of his time 
at the research center, and concluded that the program manager's 
greater experience, together with CTL's greater experience in the 
field of structural engineering, was not worth the $[deleted] premium 
associated with award to CTL.  Source Selection Statement, supra, at 
16.  In our view, given that the source selection official 
appropriately considered the superiority of CTL's program manager 
before concluding that the manager was not worth the additional 
premium associated with award to CTL, this is a matter committed to 
the discretion of source selection officials that we will not disturb, 
absent a showing that the decision was irrational or inconsistent with 
the evaluation criteria.  There has been no such showing here.

Finally, CTL argues that the source selection decision overlooked 
CTL's technical superiority under the fourth most important technical 
evaluation subfactor, knowledge and experience in four areas related 
to highway bridge structures.  In the agency's final evaluation of the 
proposals under this subfactor, it noted that CTL had "a higher degree 
of experience and knowledge of highway bridge structures than PSI" but 
also explained that both "have significant experience and knowledge in 
this area and meet the requirements of the RFP."  Final Evaluation 
Report, supra, at 4-5.  In addressing this subfactor in its comparison 
of the two proposals, the source selection statement states that "both 
offerors were considered acceptable in their demonstrated knowledge 
and experience in the four areas related to highway bridge research."  
Id. at 16.  According to CTL, this statement improperly overlooks the 
fact that CTL received 12.5 out of 15 available points for this 
subfactor, while PSI received only 9 points, and thus shows that the 
tradeoff decision was improper.

In our view, while the source selection statement's description of 
both offerors as "acceptable" under this subfactor does not repeat the 
evaluators' observation that CTL had a "higher degree of experience 
and knowledge" in this area, it nevertheless reasonably reflects the 
evaluators' conclusion--that both offerors have "significant 
experience and knowledge" in the area and both meet the RFP 
requirements.  Since we cannot say that the source selection statement 
was wrong or erroneous in its description of this portion of the 
evaluation, we will not overturn the tradeoff decision on this basis.

The protest is denied.

Comptroller General
of the United States

1. The RFP's roster of seven key personnel (not counting the program 
manager), expanded by two the number of personnel designated as key 
under CTL's existing contract.  For purposes of this discussion, key 
personnel does not include the program manager.  Although the program 
manager position was identified as a key employee, the position was 
evaluated separately under a subfactor which was less important than 
the key personnel subfactor.  RFP  sec.  M at 62. 

2. PSI also proposed a third individual as a back-up research 
technician, but we need not reach the question of this individual's 
experience, or the propriety of identifying three research technicians 
for two positions, since we conclude that the incumbent technician and 
one of PSI's alternate technicians met the RFP's requirements.

3. Under the program manager subfactor, worth a total of 25 points, 
CTL received a score of 20.75 based on the strength of its incumbent 
program manager tempered by evaluator concerns that the individual 
appeared to lack experience managing complex teams including 
consultants.  PSI received a score of 17.5 based on the assessment 
that its program manager only marginally met the RFP's experience 
requirements.  The narrative attached to these scores shows that the 
evaluators viewed CTL as the clearly superior offeror under this 
subfactor.  Id. at 3-4.