TITLE:  ITT Federal Systems International Corporation, B-285176.4; B-285176.5, January 9, 2001
BNUMBER:  B-285176.4; B-285176.5
DATE:  January 9, 2001
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ITT Federal Systems International Corporation, B-285176.4; B-285176.5,
January 9, 2001

Decision

Matter of: ITT Federal Systems International Corporation

File: B-285176.4; B-285176.5

Date: January 9, 2001

C. Stanley Dees, Esq., Alison L. Doyle, Esq., and Suzette W. Derrevere,
Esq., McKenna & Cuneo, for the protester.

David S. Cohen, Esq. and John J. O'Brien, Esq., Cohen Mohr, and George J.
Affe, Esq., for Sprint Communications Co., L.P., an intervenor.

William Mayers, Esq., and Capt. Stephanie D. Hillmon, Defense Information
Systems Agency, for the agency.

Charles W. Morrow, Esq., and James A. Spangenberg, Esq., Office of the
General Counsel, GAO, participated in the preparation of the decision.

DIGEST

1. Protest that agency failed to conduct meaningful discussions is denied
where the discussions led the protester into the areas of its proposal that
required amplification and revision.

2. Agency reasonably evaluated the protester's proposal for
telecommunications services in accordance with the solicitation's evaluation
factors.

3. Price evaluation under solicitation for fixed-price telecommunications
contract, which compared the awardee's price to the others received, was
unobjectionable.

DECISION

ITT Federal Systems International Corporation protests the award of a
contract to Sprint Communications Co., L.P. under request for proposals
(RFP) No. DCA400-00-R-0003, issued by the Defense Information Systems
Agency, Defense Information Technology Contracting Organization-Europe
(DITCO), for telecommunication services. ITT challenges the conduct of
discussions, and the evaluation of ITT's technical proposal and Sprint's
price proposal.

We deny the protest.

The RFP, issued on November 18, 1999, sought to procure communications
services, including equipment, voice and data for United States forces in
Hungary, Bosnia-Herzogovina, and Croatia under a fixed-price,
indefinite-delivery, requirements contract, for a 2-year base period with
three 1-year option periods. RFP sect.sect. C.1.1, F.52.211-9200, L.52.216-1. By
this RFP, DITCO plans to replace the existing communications network and
equipment being operated and maintained by U.S. forces and Sprint (the
incumbent contractor) with a single commercial contractor. [1]

The RFP instructions required proposals to be submitted in three volumes
entitled engineering design concept (EDC), past performance, and price. The
RFP advised that the EDC response was to demonstrate the technical
configuration and design solution of the proposed network, was required to
be "comprehensive and complete in sufficient detail to demonstrate that the
proposed solution complies with all the requirements of the SOW [statement
of work]," and "must provide a paragraph by paragraph discussion of the
[SOW], illustrating how the proposal satisfies every [requirement]." The RFP
cautioned that "[r]estating the requirement identified in the [SOW] and
stating ‘will comply' or similar language, is unacceptable." Also, the
RFP advised that the EDC response "must incorporate a minimum 25% growth
factor to the user baseline provided in Section J of the solicitation; to
accommodate anticipated increases in the subscriber base over the
intervening 12 months from issuance of this solicitation to activation of
service under the new contract." [2] RFP sect. L.52.215-9204B.

The EDC response was required to be divided into three subsections entitled
management, technical, and cutover solution. In the management subsection,
the RFP required the offeror to provide specific "organizational layouts"
and to "provide a discussion of how increases to the monthly operation and
maintenance rate will be computed should the network subscriber base exceed
the baseline + 25% covered by the price proposal" and "how the reduction to
the operation and maintenance rate will be computed should the network
subscriber rate fall below the baseline covered by the price proposal." The
technical subsection was to "detail" the "proposed engineering solution" and
address each SOW paragraph "explaining how the Offeror will satisfy the
requirements." In the cutover solution subsection, the RFP advised that the
"cut-over plan must explain in detail how the Offeror plans to ensure
continuity of service to the current network users as service is
transitioned to the new network" and that the plan must reflect all
activities inherent in the cutover process and provide a "risk analysis" of
those activities which have a high likelihood of causing service outages.
Id.

The RFP provided for award on a best-value basis considering the evaluation
factors: technical/management, past performance, and price.
Technical/management was said to be significantly more important than the
other two factors with past performance and price being of approximately
equal importance.

For technical/management, the RFP listed cutover approach, technical
approach, and management approach, in descending order of importance, as
subfactors, and stated:

  a. The technical proposal will be evaluated for understanding of
     requirements, extent to which it meets/exceeds minimum requirements and
     feasibility of approach.
  b. The Cutover subfactor evaluates the anticipated disruption of service,
     length of cutover process, contingency plans to restore command and
     control circuits in the event of an emergency, contractor's risk
     assessment risk steps in the process.
  c. The Technical subfactor evaluates the overall efficiency of the
     proposed design, growth capacity of the proposed network solution,
     response to each paragraph of the SOW, adequacy of drawings and
     diagrams, comprehensiveness of the Bill of Materials, level of
     government site support required to assist contractor equipment
     installation.
  d. The Management subfactor evaluates the efficiency of the offeror's
     proposed management of the contract, efficiency of organization,
     locations of key management personnel, scope of authority, ratio of
     managerial staff to workers, comprehensiveness of the proposed
     installation schedule, the responsiveness of the proposed procedures
     for pricing, processing and completing new work and additional service
     requests.

RFP sect. M.52.215.9207E. The past performance factor had three subfactors
listed in descending order of importance: business relations/customer
satisfaction, timeliness and quality of service, and cost control. Id.

Under the price factor, the RFP stated that the "[e]valuation of proposed
prices will include a review for reasonableness based on adequate
competition, and completeness" as well as for unbalancing. Id. The RFP also
advised that "[p]roposals which are . . . unrealistically high or low in
price may be deemed reflective of an inherent lack of technical competence,
or indicative of a failure to comprehend the complexity and risks of the
proposed work, and may be grounds for rejection of the proposal." RFP sect.
M.52.215.9207D.

After several amendments, DITCO received technical proposals on January 31,
2000 and price proposals on February 11 from four offerors, including ITT
and Sprint. Following the evaluation of proposals, DITCO conducted detailed
discussions with each offeror and received revised technical proposals on
March 3 and revised price proposals on March 8. DITCO determined that ITT's
proposal constituted the best-value and made award to that firm on April 11.
On April 18, Sprint filed a protest challenging the award on various grounds
at this Office, followed by several supplemental protests (B-285176,
B-285176.2, B-285176.3). Sprint and DITCO reached an agreement to resolve
the protests on June 14 and we subsequently dismissed the protests. As part
of the agreement, DITCO agreed to reopen the procurement, amend the RFP,
hold further discussions with each offeror, give each offeror the
opportunity to "revise all sections" of the proposals, and appoint a
different source selection authority (SSA). Agency Report, Tab 18,
Stipulation and Settlement. Detailed discussions were held with each offeror
in late June. [3] Agency Report, Tab 19, Discussion Issues.

On July 7, DITCO issued amendment No. 0008 to the RFP, which revised various
sections of the RFP. Special Provision 1, entitled Government Authorized
Outages, added by the amendment, stated that "[i]f an AO [authorized outage]
is required by the contractor during the installation phase, the contractor
will provide a detailed explanation, to include length of time and reason,
in their proposal." On July 14, DITCO issued amendment No. 0009, stating
"[t]he cut-over plan must detail the number and duration of any government
[AOs] that the offeror anticipates will be necessary to implement the
proposed network solution." This amendment also amended the cutover approach
subfactor to provide for the evaluation of proposed AOs, deleted the RFP
provision requiring the evaluation of "overall proposal risk," released the
prices previously submitted by all offerors, and included responses to
various offeror questions. This amendment was accompanied by an e-mail
message that stated that "[a]ttached in Amendment 0009, Portions of Section
J not in electronic format will be sent by fax. . . . Sample of reports
required . . . [are] provided for information." Protester's Comments, Tab 3,
e-mail. The documents faxed pursuant to this e-mail message included a
sample report (entitled "numbers count report") denoting more current
information than had been previously provided offerors via section J of the
RFP related to the "number of active (wired) ports" and "active email
accounts" at various bases. [4] Protester's Comments, Tab 4, Number Count
Report. Amendment No. 0010 also contained questions and answers concerning
the revised RFP, which, among other things, indicated that this current user
count should be used in preparing proposals. RFP amend. 0010, Q&A
Nos. 0078, 0151. Final technical and price proposals were submitted in
August.

A reconstituted six-member source selection evaluation board (SSEB)
evaluated the final technical and price proposals. Based upon a revised
source selection plan (SSP), the SSEB rated the proposals under the weighted
evaluation factors utilizing a color-coded descriptive rating system: blue,
green, yellow, orange and red. [5] The SSP described the color ratings as
follows:

 Blue      The proposal must demonstrate the capability for delivering a
           level of performance exceeding that normally expected from a
           very well qualified contractor. The proposal must significantly
           exceed the desired performance levels and the excess must be
           considered to be of real benefit to the technical objectives of
           the contract. Any weaknesses present must clearly be considered
           insignificant.

 Green     The proposal is considered to be capable of being implemented
           substantially as proposed. The offeror is well qualified and the
           proposal more than adequately demonstrates his ability to
           perform in a manner which meets substantially all Government
           requirements.

 Yellow    The proposal is adequate in its treatment of the specific
           factor/subfactor. Weaknesses or deficiencies are present;
           however, they are either individually or cumulatively relatively
           non-critical in nature and are easily correctable. Weaknesses
           are perhaps the result of a lack of overall proposal preparation
           experience.

 Orange    The proposal is barely acceptable. Significant weaknesses and/or
           deficiencies are present; however, they are considered
           correctable without a complete rewrite of the applicable aspect
           of the proposal.

 Red       The proposal contains weaknesses and/or deficiencies in such
           numbers or of such significance that a complete re-proposal
           would be necessary to make the proposal marginally acceptable.

Agency Report, Tab 26, Source Selection Plan, at 12. The SSEB rated
proposals by having each member identify strengths, weaknesses and
deficiencies and assign a color rating for each criterion of each
technical/management subfactor and for past performance. The SSEB then
developed consensus ratings based upon discussions among the members of the
strengths and weaknesses of each proposal for every evaluation criterion and
factor. Agency Report at 10.

Based on the evaluation, Sprint was ranked second of the proposals received
with a yellow rating for the cutover approach technical/management subfactor
and green ratings in management approach and technical approach subfactors,
and with yellow ratings in the past performance customer satisfaction and
timeliness subfactors and a green rating for the past performance cost
control subfactor. ITT was ranked third with yellow ratings for all the
technical/management subfactors and green ratings for all the past
performance subfactors.

A price analysis was performed by the agency's "Rates and Tariff Analysis
Branch," which calculated a discounted life cycle cost for each proposal.
DITCO found that the "overall competitive environment was sufficient to
ensure price reasonableness." Taking into account the discounted life cycle
costs of the proposals, Sprint's proposal had the lowest evaluated price at
$61,947,846 and ITT was third lowest at $75,352,396. These prices
represented a 31-percent and 25-percent drop, respectively, in these
offerors' previously submitted prices. [6] In performing the price analysis,
DITCO compared the offerors' prices. DITCO performed a "rough order of
magnitude" analysis, based upon a comparison of the offered prices to
current contract prices, which revealed that the offerors' prices were
within a reasonable range (from 20-percent higher to 9-percent lower) of the
current contract price.
After considering the reasonableness and accuracy of each offeror's price,
the SSEB determined that prices were reasonable and realistic. Agency Report
12-15.

A source selection advisory council (SSAC), along with the SSEB, the
contracting officer, and the SSA, after reviewing and discussing the
evaluation results, concluded that Sprint's second best combined technical
and past performance ranking and lowest price constituted the best value.
DITCO awarded Sprint the contract on September 13. See Agency Report at
15-18(a); Agency Report, Tab 31, Business Clearance Memorandum, at 5. This
protest from ITT followed.

ITT argues that DITCO failed to conduct meaningful discussions with ITT
and/or misevaluated ITT's proposal in virtually every respect where a
weakness or deficiency was found under the technical/management factor. One
of the focuses of the protest concerns ITT's cutover approach, the most
heavily weighted subfactor under the RFP, for which ITT received a yellow
rating. ITT argues that DITCO failed to conduct meaningful discussions with
regard to its cutover plan because during discussions DITCO did not
expressly identify all of the weaknesses listed in the SSEB report to
justify the yellow rating for ITT's cutover approach. Protest at 10-13;
Protester's Comments at 10-32.

In negotiated procurements, whenever discussions are conducted by an agency,
the discussions are required to be meaningful, equitable, and not
misleading. The Communities Group, B-283147, Oct. 12, 1999, 99-2 CPD para. 101
at 4. Federal Acquisition Regulation (FAR) sect. 15.306(d)(3) requires the
contracting officer to indicate or discuss significant weaknesses,
deficiencies, and aspects of the proposal . . . that could, in the opinion
of the contracting officer, be altered or explained to enhance materially
the proposal's potential for award." To satisfy the requirement for
meaningful discussions, the agency need only lead an offeror into the areas
of its proposal requiring amplification or revision; all-encompassing
discussions are not required, nor is the agency obligated to "spoon-feed" an
offeror as to each and every item that could be revised to improve its
proposal. See Arctic Slope World Servs., Inc., B-284481, B-284481.2, Apr.
27, 2000, 2000 CPD para. 75 at 8-9; The Communities Group, supra. This is
particularly true where, as here, one aspect of the evaluation is to test
the offeror's technical understanding. See TRI-COR Indus., B-259034.2,
Mar. 14, 1995, 95-1 CPD para. 143 at 5-6.

ITT complains that none of the various weaknesses the SSEB attributed to its
proposal under the cutover approach subfactor were sufficiently identified
during discussions. Some of the 18 ITT cutover plan weaknesses the SSEB
listed for
ITT's proposal included [DELETED] and [DELETED]. In addition, one
deficiency, [DELETED] was found. Agency Report, Tab 27, SSEB Report, at
5-12. The 11 strengths, 18 weaknesses, and 1 deficiency in ITT's cutover
approach resulted in ITT receiving a "yellow" rating, which under DITCO's
evaluation scheme represented an "adequate," that is acceptable, proposal
with easily correctable or non-critical weaknesses or deficiencies. [7]

During the second round of discussions, DITCO specifically informed ITT that
its cutover approach "need[ed] greater detail on how major items are to be
brought on line and put into service on network," that the agency "need[s]
more detail to analyze" whether the cutover plan includes unreasonable
performance expectations, that the cutover schedule was "aggressive" and
that the cutover approach did not ask for AOs. Id., Tab 19, ITT Discussion
Issues, at 2-3. We think that DITCO conducted meaningful discussions with
ITT regarding its cutover approach, in that DITCO led ITT into the precise
areas of ITT's cutover approach where the weaknesses (many of which
concerned a lack of detail) were found. [8] Although ITT argues that DITCO's
questions were too broad to allow ITT to meaningfully address the precise
weaknesses attributed to its proposal, as stated above, the requirement for
meaningful discussions does not require the offeror the opportunity to learn
each and every weakness associated with its proposal during discussions,
particularly where as here one aspect of the evalution was to test the
offerors' technical understanding. [9]

ITT protests in the alternative that DITCO unreasonably evaluated its
cutover approach with regard to most of the weaknesses found. Protester's
Comments at 21-24; Supplemental Protest at 3, 5.

An agency's method for evaluating the relative merits of competing proposals
is a matter within the agency's discretion, since the agency is responsible
for defining its needs, and the best method for accommodating them. When an
evaluation is challenged, we will examine the record to determine whether
the agency's judgment was reasonable and consistent with stated evaluation
criteria and with procurement statutes and regulations. The protester's mere
disagreement with an evaluation does not establish that an evaluation was
unreasonable. Arctic Slope World Servs., Inc., supra, at 5.

As indicated, the SSEB assigned ITT's proposal a yellow rating under cutover
approach and in many instances this occurred because ITT's proposal failed
to provide a sufficient level of detail in its proposal to justify more than
the yellow (albeit acceptable) rating, even after receiving meaningful
discussions on this point. Other noted weaknesses included the agency's
concerns about ITT's reliance on the [DELETED] for backup, and ITT's failure
to adequately address AOs. The one deficiency related to ITT's
miscalculation of the number of phone drops at two sites, so as to be below
the 125-percent baseline required by the RFP.

Contrary to ITT's argument, the RFP clearly required a detailed cutover
approach; thus, it was reasonable to find weaknesses in ITT's cutover
approach where details were lacking. [10] With regard to the other
weaknesses, while ITT argues that the RFP permitted relying upon the
[DELETED] as a backup, the agency could reasonably view this approach as
less than optimum. See Supplemental Agency Report at 13-15. Further, while
ITT argues that it understood an AO to involve the removal of a system,
station or facility and that it did not anticipate the removal of a system,
but "anticipated individual circuit and trunk disruption of short duration,"
Protester's Comments at 23, the SSEB did not agree that ITT's proposal
showed that it could accomplish these tasks within a short time,
particularly given the proposal's lack of detail. See Supplemental Agency
Report at 15-18. With regard to the deficiency, ITT confirms that its
proposal was not based upon the current user base information but upon
outdated user information previously provided the offerors under section J
of the RFP. [11] See Protester Comments at 27-28. Thus, based on our review,
we find ITT's cutover approach was reasonably evaluated.

ITT raises numerous other arguments challenging the evaluation of its
proposal, attacking each and every weakness attributed to its proposal by
the SSEB for each technical approach subfactor. We discuss only some for
illustrative purposes, but we have examined each of the protester's
arguments in detail, and find no basis to disturb the award. [12]

For example, ITT challenges the yellow rating the SSEB assigned to its
proposal under the management approach subfactor. This subfactor had four
separately evaluated criteria: (1) installation efficiency and schedule, (2)
pricing new work and additional local service requests (LSR), (3) business
environment, and (4) management of the contract. While ITT's proposal
received green ratings for the first and third of these criteria, it
received a yellow rating for the second criterion and an orange rating for
the fourth criterion. The SSEB "rolled up" these ratings into an overall
yellow rating for the management approach subfactor. ITT challenges the
yellow and the orange ratings that caused its proposal to be rated only
yellow, contending that its subfactor rating should have been green. Our
review finds the agency's evaluation of this subfactor to be reasonable.

With regard to the pricing new work and additional LSRs criterion, while
some strengths were noted, ITT's plan was found to have failed to address
how many LSRs could be processed above the required minimum. Agency Report,
Tab 27, SSEB Report, at 17-18. ITT argues that its proposal should not have
been downgraded for this reason since it met the minimum RFP LSR
requirements and that DITCO was improperly seeking a commitment to a
specific number of additional LSRs over the minimum. Protester's Comments at
33-36. We disagree. There is no evidence that the agency sought a particular
commitment beyond the LSR minimum and, as noted, ITT's proposal was not
rated less than acceptable for failing to address this matter, but was
assigned a yellow rating. While the RFP did not require an offeror
commitment to a specific number of LSR's over the minimum, DITCO
specifically informed offerors in amendment No. 0010 that their proposals
"must address how quantities in excess of [the minimum] 50 will be handled."
[13] RFP amend. No. 0010, Q&A No. 104. Thus, the agency reasonably assigned
ITT's proposal a yellow rating under this criterion. [14]

ITT also challenges its orange rating under the management approach
subfactor criterion "management of the contract." The SSEB assigned this
rating because no strengths, one weakness, and two deficiencies were noted.
The deficiencies were that the proposal was "[n]ot clear on how O&M
[operation and maintenance] rates will change to reflect user base changes.
Definitization [of this matter] after award [was] unacceptable" and that
"[n]o algorithm [was] provided." See Agency Report, Tab 27, SSEB Report, at
22. DITCO reports that ITT's proposal was downgraded because it discussed
only some of the factors to be considered when increases or decreases to the
O&M rates were negotiated after award and did not provide a computation or
algorithm of such increases and decreases, as contemplated by the RFP.
Supplemental Protest Agency Report at 28. ITT argues this evaluation was
unjustified because the RFP allegedly did not require such an algorithm, but
instead required, as appeared in ITT's proposal, a "discussion of the
process by which the company would capture increased or decreased costs
associated with volume changes and develop appropriate responses."
Supplemental Protest at 6. This argument lacks merit. First, the RFP
requires the management section of an offeror's proposal to "provide a
discussion of how increases to the monthly operation and maintenance rate
will be computed," RFP sect. L.52.215-9204B.1.f(i), not simply a discussion of
the process. Second, the record shows that DITCO put ITT on notice of how it
planned to interpret the provision in both rounds of discussions, asking ITT
to provide an algorithm or formula to be used in adjusting O&M rates and
advising ITT that its proposal was noncompliant in this respect. See Agency
Report, Tab 7, ITT Clarification Questions, at 5; Tab 19, ITT Discussion
Issues, at 1. Thus, DITCO was justified in assigning ITT an orange rating
for this criterion and the agency reasonably rated ITT yellow under the
management approach subfactor.

Since we conclude the record shows that DITCO reasonably evaluated ITT's
proposal under the cutover approach and management approach subfactors, we
need not consider ITT's contentions concerning the evaluation of its
proposal under the technical approach subfactor. Even if ITT's proposal
should have been rated green under the techncial approach subfactor, as
contended by ITT, it would not be found technically equal to Sprint's EDC
proposal, given Sprint's unchallenged green ratings for the management
approach and technical approach subfactors and yellow rating for the cutover
approach subfactor. Given Sprint's significant price advantage and
superiority under the most heavily weighted technical/mangement factor, the
source selection would not be affected even if ITT's proposal were rated
green under the technical approach subfactor. [15]

ITT finally protests that the price evaluation performed by DITCO was
improper because the agency failed to perform an adequate reasonableness,
realism or risk assessment of Sprint's low-priced proposal, even though
Sprint's low-priced proposal decreased by approximately 31 percent from its
previous proposal price.

The nature and extent of an agency's price analysis is largely a matter of
agency discretion, dependent upon the facts of a particular procurement. The
FAR provides a number of price analysis techniques that may be used to
determine whether prices are fair and reasonable, including a comparison of
prices received with each other and/or with a rough yardstick. FAR sect.sect.
15.404-1(b)(2)(i), (iii). Here, the record shows that the agency compared
the low price of Sprint--who was the incumbent contractor and who the agency
had determined had an acceptable level of understanding during the technical
evaluation--with the other prices submitted (one of which was less than 5
percent higher than Sprint's), noted that three of the four offerors
significantly lowered their prices in their revised proposals, and found
that Sprint's price was within a reasonable range of the incumbent contract
price. Under the circumstances, we see no reason to question the price
evaluation. See Ventura Petroleum Servs., Inc., B-281278, Jan. 21, 1999,
99-1 CPD para. 15 at 5.

The protest is denied.

Anthony H. Gamboa

Acting General Counsel

Notes

1. The existing communications network and equipment include U.S. forces
tactical communications equipment; commercial equipment and personnel; and
local post, telephone and telegraph commercial services.

2. Section J of the RFP listed a variety of items concerning the
requirements to be provided offerors in electronic format. Pursuant to this
section, the offerors were provided the "Current User Base."

3. The agency reports that the detailed discussions held with ITT lasted
between 3 and 4 hours, but no contemporaneous notes were maintained of the
discussions, except for a matrix listing the agency's discussion items that
was provided to ITT as a basis for the discussions. Supplemental Agency
Report at 2.

4. This was information similar to that listed on the previously provided
"Current User Base."

5. The prior evaluation was performed utilizing a 1,000-point scale that
allocated 800 points to the technical proposal and 200 points to past
performance.

6. One of the other offerors also lowered its price by 31 percent.

7. Sprint's cutover approach also received a yellow rating and weaknesses
similar to those noted in ITT's cutover approach were recorded, for example,
lack of details.

8. We only identify a few of the weaknesses associated with ITT's cutover
plan for purposes of our discussion, but we have examined the discussions
and the weaknesses attributed to ITT's proposal in detail and find that
meaningful discussions were conducted. Also, the deficiency and some of the
weaknesses were problems first introduced in ITT's final proposal revision
after discussions were concluded, and there was no duty to reopen
discussions to address these matters. See Ouachita Mowing, Inc., B-276075,
B-276075.2, May 8, 1997, 97-1 CPD para. 167 at 4.

9. ITT also argues that the discussions were misleading because DITCO
informed ITT that some areas of its cutover approach complied with the
requirements. We disagree. The finally noted weaknesses were not those
specific items for which ITT was advised its cutover approach was compliant.
In any case, the onus was on ITT to reexamine its cutover plan in light of
the concerns regarding its cutover plan expressed by the agency and the
RFP's requirement to provide a detailed plan. See The Communities Group,
supra, at 4.

10. Our review discloses that another proposal (not Sprint's), which
contained a much more detailed cutover approach, received a green rating for
this subfactor.

11. While ITT argues that it did not have to consider the most recent user
information in preparing its proposal because DITCO did not properly amend
the RFP to incorporate that information, ITT admits that the information was
provided in the "numbers count report" faxed with section J when amendment
No. 0009 was distributed. Supplemental Protest at 6. Moreover, in amendment
No. 0010, DITCO, in response to question No. 0078 specifically advised
offerors that they "should use information in section J as most current user
count," and in response to question No. 0151 noted that user counts have
changed by as much as 25 percent. Thus, it was not reasonable for ITT to
base its revised proposal on information that it knew was outdated.

12. This is also true for the alternative arguments that ITT raises
regarding whether meaningful discussions were conducted in the area ITT
alleges were evaluated unreasonably. As was the case for cutover approach,
the record reflects that DITCO conducted meaningful discussions regarding
these other factors by reasonably leading ITT into the areas of its proposal
that needed amplification or revision. See Agency Report, Tabs 7 and 19, ITT
Discussion Issues.

13. DITCO also specifically informed ITT of this concern during the first
round of discussions. Agency Report, Tab 7, Response to Clarification
Questions, at 4.

14. In part because it did provide a good description of its capability to
handle LSRs over the minimum, Sprint's proposal received a green rating
under this criterion. Also, the record evidences that ITT's yellow rating
was partially based on the fact that it had fewer strengths than the
proposals that received green ratings for this criterion. See Agency Report,
Tab 27, SSEB Report, at 17-19.

15. ITT's slightly superior rating under the significantly less important
past performance factor would obviously be offset by Sprint's superiority
under the significantly more important technical management factor and
significantly lower price.