TITLE:  Hernandez Engineering, Inc.; ASR International Corporation, B-286336; B-286336.2; B-286336.3; B-286336.4, January 2, 2001
BNUMBER:  B-286336; B-286336.2; B-286336.3; B-286336.4
DATE:  January 2, 2001
**********************************************************************
Hernandez Engineering, Inc.; ASR International Corporation, B-286336;
B-286336.2; B-286336.3; B-286336.4, January 2, 2001

Decision

Matter of: Hernandez Engineering, Inc.; ASR International Corporation

File: B-286336; B-286336.2; B-286336.3; B-286336.4

Date: January 2, 2001

Richard J. Webber, Esq., and David A. Vogel, Esq., Arent Fox, for Hernandez
Engineering, Inc., and Anthony B. Barton, Esq., Forchelli, Curto, Schwartz,
Mineo, Carlino & Cohn, for ASR International Corporation, the protesters.

Alan M. Grayson, Esq., Ira E. Hoffman, Esq., and Mark R. Mann, Esq., Grayson
and Kubli, for SRS Information Services, an intervenor.

Bernard J. Roan, Esq., National Aeronautics & Space Administration, for the
agency.

Katherine I. Riback, Esq., and James Spangenberg, Esq., Office of the
General Counsel, GAO, participated in the preparation of the decision.

DIGEST

1. Protest that contracting agency improperly evaluated awardee's past
performance as "very good" is denied, even though the agency considered
references of the awardee's parent corporation in the past performance
evaluation, where the solicitation did not require any specific minimum of
reference questionnaire responses and the agency received a reference
questionnaire response regarding a comparable contract performed by the
awardee rating its performance as "very good" to "excellent."

2. Consistent with the solicitation's evaluation factors, agency reasonably
found significant strengths in awardee's proposal that justified a technical
rating that was significantly higher than that of protesters.

3. In calculating probable costs of protesters' proposals, agency reasonably
upwardly adjusted their costs where protesters proposed less staffing than
forecasted in the solicitation for some of the required services without
adequate explanations of the methodology used to develop the proposed lesser
levels of staffing and/or accounting for the enhanced levels of services
contemplated by the solicitation.

DECISION

Hernandez Engineering, Inc. and ASR International Corporation protest the
award of a contract to SRS Information Services, for mission assurance
services by the National Aeronautics & Space Administration (NASA) pursuant
to request for proposals (RFP) No. 5-02035-502. Both protesters challenge
NASA's evaluation of their and the awardee's proposals.

We deny the protests.

BACKGROUND

The Office of Systems Safety and Mission Assurance at Goddard Space Flight
Center conducts reviews before and after launches of flight projects and
provides independent technical support, including risk assessment and
guidance to all flight programs. The procurement at issue here is to support
NASA's mission by providing services in the mission assurance engineering,
system safety, reliability, continuous risk management, and information and
assurance technology areas. RFP attach. A, at 1. The solicitation, issued on
April 6, 2000, as a 100-percent small business set-aside, anticipated the
award of a cost-plus-award-fee (CPAF) contract for 5 years. The RFP stated
the agency's intention to award the contract without discussions.

The three evaluation factors listed in the RFP were, in descending order of
importance: mission suitability, past performance, and cost/price. The RFP
stated that the non-cost/price factors, when combined, were significantly
more important than the cost factor. The mission suitability factor was
point scored and adjectivally rated considering four subfactors: technical
approach and methodology (300 points), scenarios (300 points), management
approach (200 points), and quality approach (200 points). [1] RFP sect. M.3. The
past performance factor was adjectivally rated based largely on responses to
the "Experience and Past Performance Questionnaire" that each offeror was to
send to its references. RFP sect. L.16. For the cost/price factor, the agency
considered both proposed and probable costs, as calculated through cost
realism analyses, for the offerors' proposals for the total 5-year contract
effort as well as for the offerors' responses to the seven scenarios. RFP sect.
M.4.

The RFP further provided for the deduction of points from the mission
suitability score where there was a significant variance between an
offeror's proposed costs and probable costs. [2] As indicated, under the
RFP, cost realism adjustments could be made to the offeror's proposed CPAF
value for the total 5-year effort and to the total CPAF value associated
with the seven scenarios. The percentage cost realism adjustment for these
two items would then be added together and divided by two to obtain an
average cost realism adjustment. This average would be utilized to determine
if reductions in the mission suitability score were warranted. Percentage
differences in excess of plus or minus 6 percent between an offeror's
proposed and probable costs would lead to specified point reductions to the
offeror's mission suitability score. RFP sect. M.3.3.

The agency received three proposals by the June 19 closing date. Each
offeror then made its oral presentation. The findings of the source
evaluation board (SEB) are summarized as follows:

            Raw           Post-Cost    Past          5-Year    5-Year
                          Realism
            Mission                    Perfor-mance  Proposed  Probable
            Suitability   Mission
                          Suitability                Cost      Cost
            Score/
                          Score/
            Adjectival
            Rating        Adjectival
                          Rating

 SRS        887/Very      887/ Very    Very Good     $44.7M    $45.0M
            Good          Good

 Hernandez  570/Good      470/Fair     Very Good     $44.8M    $45.7M

 ASR        544/Good      444/Fair     Very Good     $36.8M    $41.4M

Agency Report at 4.

SRS's proposed costs for the 5-year effort and for the scenarios were within
1 percent and 0.5 percent, respectively, of the NASA-computed probable costs
for the SRS-described technical approaches; as a result, SRS's mission
suitability score was not adjusted. Id., Tab 22, SEB Initial Findings
Report, at 29. Hernandez's proposed costs for the 5-year effort and for the
scenarios were within 2 percent and 19 percent, respectively, of the
NASA-computed probable costs, for an average cost realism adjustment of 11
percent; and ASR's proposed costs for the 5-year effort and for the
scenarios were within 13 percent and 12 percent respectively, of the
NASA-computed probable costs, for an average cost realism adjustment of
12.5 percent. Id. at 30-32, 35-38. Based on the RFP methodology, NASA
reduced the mission suitability scores of both Hernandez and ASR by
100 points. [3] Id. at 32, 37-38.

The Source Selection Official concurred with the SEB's findings, and stated
the following:

As compared with ASR, the magnitude of the difference in the Mission
Suitability scores between the two was significantly greater than the cost
disadvantage SRS sustained as compared with ASR. In order to confirm this
result, I considered whether the greater cost of the SRS proposal was
warranted by the technical benefits which the Government would realize from
SRS performance of the contract. The services to be provided support flight
projects at very critical times in assessing spacecraft, launch vehicle,
operational ground systems, and scientific instruments prior to, during, and
following launch. Failure to timely identify technical issues affecting the
successful operation of multi-million dollar instruments and spacecraft can
well result in their permanent reduced level of performance or even total
loss. The level of services which SRS has demonstrated it can provide
meaningfully reduces risk of such problems as compared to that demonstrated
by ASR, in light of the specific strengths and weaknesses previously
discussed. The amount of additional cost to be incurred is more than
reasonable to provide for reduced risk of instrument and spacecraft losses,
and thereby loss of millions of dollars of investment.

Id., Tab 25, Source Selection Memorandum at 7. The source selection official
thus determined to award the contract to SRS. [4]

EVALUATION OF SRS'S PROPOSAL

Both Hernandez and ASR protest that the technical evaluation of SRS's
proposal was improper. The evaluation of technical proposals is primarily
the responsibility of the contracting agency. Our Office will not make an
independent determination of the merits of technical proposals; rather, we
will examine the record to ensure that the agency's evaluation was
reasonable and consistent with the stated evaluation criteria. Litton Sys.,
Inc., B-237596.3, Aug. 8, 1990, 90-2 CPD para. 115 at 8. A protester's mere
disagreement with the agency's evaluation does not render the evaluation
unreasonable. SWR Inc., B-286044.2, B-286044.3, Nov. 1, 2000, 2000 CPD para. __
at 3. Based on our review, we find the agency's technical evaluation of
SRS'S proposal unobjectionable.

Both protesters contest the agency's past performance evaluation of SRS's
proposal. Hernandez notes that three of the four questionnaires from
customers regarding SRS's relevant experience and past performance in fact
related to the performance of SRS Technologies, which is the parent
corporation of SRS Information Services and is not proposed to perform the
RFP work. As a result, Hernandez contends that the agency's evaluation of
SRS's past performance was "arbitrary and irrational." Hernandez Comments
(Nov. 2, 2000) at 1-3.

While it is true that three of SRS's four references were in fact for SRS
Technologies, one of the questionnaires that the agency received from an SRS
reference related to the performance of SRS Information Services on a
contract at Patrick Air Force Base to provide safety engineering, mission
assurance, and occupational safety and health support services. Agency
Report, Tab 15, SRS Past Performance Questionnaires. The majority of the
responses on this questionnaire pertaining to the performance of SRS
Information Services were "excellent" and the remaining responses were "very
good." Id. The contracting officer noted that SRS Information Services had
"provided very comparable space-based mission assurance services to Patrick
Air Force Base," and that "the respondent is pleased with the services
provided." Supplemental Contracting Officer's Statement at 1-2. The
contracting officer stated that, even assuming the SEB excluded the three
questionnaires related to SRS Technologies, the rating for SRS's past
performance would remain unaffected because SRS Information Services had
relevant and highly rated past performance. Id. While the protester states
that we should reject the contracting officer's conclusion because it was
only offered in response to the protest and the agency in fact considered
SRS Technologies' references in the evaluation, we note that the RFP did not
require any specific minimum number of questionnaire responses. RFP sect. L.16.
Accordingly, we find reasonable the contracting officer's conclusion that
the highly relevant and favorable reference for SRS Information Services
supports a rating of very good.

Hernandez next argues that the agency's evaluation of the SRS proposal for
the technical approach subfactor was irrational because it was based upon
the alleged better credentials of the SRS management and staff personnel,
even though SRS's proposal, like Hernandez's, showed that it intended to
employ incumbent staff personnel. Hernandez Supplemental Protest (Oct. 30,
2000) at 4-5. The agency replies that the SEB was concerned with the minimum
education requirements and experience that offerors were proposing to use
for labor categories providing services to meet the contract's statement of
work requirements. [5] Supplemental Contracting Officer's Statement at 7.
While the SEB recognized that an offeror did "not need certified or degreed
people to meet all of the statement of work requirements," it did regard as
a strength in SRS's proposal the fact that SRS will require professionally
certified people to manage the contract and quality engineers to have
bachelor degrees. [6] Id. The agency found that this "demonstrate[d] the
offeror's effective understanding of the level of expertise required to
provide the services necessary for effective contract performance." Agency
Report, Tab 22, SEB Initial Findings Report, at 22. While it is true that
both SRS and Hernandez offered incumbent personnel who were certified and
had bachelor degrees, we find the agency's determination that SRS's proposal
warranted a strength for requiring its personnel to meet such minimum
requirements to be reasonable and consistent with the stated evaluation
criteria, particularly given that the other offerors did not make the same
offer.

The protesters assert that it was irrational for the agency to conclude that
SRS's proposal to obtain ISO 9001-2000 compliance and obtain third-party
evaluation and certification of this compliance was a strength in SRS's
quality approach. The protester contends that this should not form a basis
for differentiating among the proposals because the RFP required only ISO
9000 compliance. The SEB found that SRS's third-party accreditation of its
quality system provided the government with more confidence in the offeror's
ability to successfully perform the work. Agency Report, Tab 22, SEB Initial
Findings Report, at 11. Based on our review, we find the agency's conclusion
reasonably based and not inconsistent with the RFP's evaluation scheme. The
quality approach subfactor specifically stated that the offeror's compliance
with ISO standards to ensure they are integrated into the quality management
system would be evaluated, and the agency acted reasonably in assigning a
strength based on SRS's enhanced offer under this qualitatively evaluated
factor.

Hernandez also claims that the agency, in making its source selection,
unreasonably noted as a strength SRS's proposed use of the [DELETED]
database, which allows government customers access to information relative
to the services provided, but did not assign Herndandez a similar strength
for its assertedly functionally equivalent database, which Hernandez asserts
evidences unequal treatment. [7] SRS's proposal of the [DELETED] database
was viewed as a significant strength because it allowed government customers
to access [DELETED] all current information regarding action items, status,
cost, and schedule on the services provided by the contractor. Agency
Report, Tab 22, SEB Initial Findings Report, at 10. While Hernandez claims
that its proposal offered the same basic functionality as the [DELETED]
database, the agency responds, and Hernandez concedes, that SRS's proposed
[DELETED], which poses the risk that [DELETED]. Supplemental Contracting
Officer's Statement at 8. Based on our review, we find the agency's
evaluation in this area to be reasonable and not unequal treatment.

Hernandez also challenges the significant strength noted in SRS's proposal
(under the management approach subfactor) for its proposed use of [DELETED]
training for all personnel, including [DELETED], while not crediting
Hernandez's proposal for its proposed training. The agency viewed SRS's
proposed [DELETED] as a significant strength because it [DELETED]. Agency
Report, Tab 22, SEB Initial Findings Report at 10. Given that Hernandez's
proposal does not offer the [DELETED] proposed by SRS, we cannot find this
evaluation of SRS to be unreasonable.

EVALUATION OF HERNANDEZ'S PROPOSAL

Hernandez claims that NASA improperly increased its probable cost due to the
agency's erroneous conclusion that Hernandez's direct labor hours for
"reliability services" were understated and did not match the "historical"
data in the RFP. The protester contends that the historical figures in the
RFP were overstated, and were not an accurate reflection of the predecessor
contract. Clause L.13 of the RFP, "Historical Data," included a table that
identified the full-time equivalents (FTE) per year for various services
"based on past historical data." This table estimated 10 FTEs for
reliability services. Hernandez proposed using [DELETED] FTEs for
reliability services. Id., Tab 13, Hernandez Cost/Price Proposal, sect. 5.0,
exh. 4, at 22. For cost evaluation purposes, the SEB increased Hernandez's
reliability services FTEs from [DELETED] to 10. The agency contends that the
10 FTE figure included in the table for reliability services was a correct
estimate of these services, but the manner in which the table was identified
was "imprecise," Supplemental Contracting Officer's Statement at 4, and that
the FTEs should have been identified as "anticipated based on historical
experience and projected workload." Contracting Officer's Statement at 24.
The contracting officer notes that the Anticipated Service Forecast Letter
(RFP encl. 2, at 2-3) showed a significant increase in anticipated services
within the safety and reliability work areas from the incumbent contract due
to the fact that NASA has recently been focusing more on the system safety
and reliability of its missions; according to NASA, this equates to an
increase in the number of required services over historical figures and the
estimate in the table in the RFP reflected this additional work. Contracting
Officer's Statement at 25. Hernandez has not shown the agency's FTE estimate
for these services was erroneous or that Hernandez's proposed staffing and
technical approach accounted for the increased reliability services called
for by the RFP. [8] Thus, we find that the agency's upward adjustment of
Hernandez's probable cost for understating the required staffing for
reliability services was reasonable.

Hernandez also argues that the agency improperly reduced its mission
suitability score from 570 points to 470 points because of the cost realism
adjustments to Hernandez's scenario costs. The protester argues that this
cost realism adjustment "treats the Scenarios' cost estimates as if they are
part of the estimated costs of actually performing the contract," when in
fact "the scenarios are only hypotheticals, and those estimated costs are
not added to, or otherwise part of, the overall estimated costs of
performing the contract." Hernandez Supplemental Comments (Nov. 27, 2000) at
5. Hernandez also claims that this evaluation constitutes improper
double-counting in the mission suitability evaluation for alleged
deficiencies already accounted for in the cost evaluation. Hernandez's
arguments here constitute an untimely challenge to the evaluation scheme set
out in the RFP. As noted, the RFP clearly announced that scenario costs
would be part of the cost evaluation and described the adjustments that
would be made to the mission suitability score where proposed costs varied
more than 6 percent from probable costs. RFP sect. M.3.3.

Hernandez next contends that the agency's evaluation of its proposal under
the technical approach, management approach and quality approach subfactors
was "arbitrary," in that the evaluation documentation contained little more
than the adjectival ratings for these subfactors. The SEB judged that
Hernandez's proposal warranted a "good" rating under each of these
subfactors and no particular strengths or weaknesses in Hernandez's
technical proposal were recorded for these subfactors, except for one
"other" (that is, not significant) strength for the technical approach
factor (which strength was thoroughly described). [9]

We find that the documentation of the SEB's evaluation was sufficient. The
SEB was not required to document how it rated or disposed of every component
of Hernandez's technical proposal. Under Federal Acquisition Regulation sect.
15.305(a), NASA was obligated to document "the relative strengths,
deficiencies, significant weaknesses, and risks supporting proposal
evaluation." While NASA was required to document its evaluation in
sufficient detail to permit a meaningful review of its evaluation, KMS
Fusion, Inc., B-242529, May 8, 1991, 91-1 CPD para. 447 at 7, we think that it
did so here. In this regard, Hernandez has not identified any examples of
strengths or weaknesses in its proposal which were not documented but
reasonably would be considered significant discriminators between the
proposals. [10] Thus, the record does not show that the evaluation of
Hernandez's proposal under these subfactors was arbitrary or unreasonable.

EVALUATION OF ASR'S PROPOSAL

ASR points out that its subcontractor, [DELETED], is the incumbent
contractor and its performance has been rated excellent. ASR argues that it
is "incorrect and inconsistent" for NASA to evaluate [DELETED] current
performance as excellent, and then evaluate ASR's proposal, which includes
[DELETED] as a subcontractor, as weak. ASR's Initial Protest at 1-2. In
particular, ASR argues that [DELETED] experience should speak for itself,
with the agency evaluating ASR's responses to the seven scenarios based on
[DELETED] "reasonableness of knowledge and experience in accomplishing
similar efforts"; instead, the agency, in ASR's view, improperly relied on
evaluators' "subjective" judgments in rating ASR's responses. Id. at 2.

The contracting officer responds that the emphasis of this contract is in
the areas of mission assurance, system safety, and reliability, yet the work
for which [DELETED] has been proposed is for continuous risk management and
information and assurance technology services, which account for only 15
percent of ASR's total hours. The contracting officer goes on to state that:

ASR is relying on the fact that the incumbent is a subcontractor in their
proposal and their performance under the current contract should be
recognized and accounted for in evaluating ASR's proposal but has not
proposed to utilize [DELETED] expertise and knowledge gained as the
incumbent contractor to provide services under the most important statement
of work service areas and, instead, is relying on incumbent capture to
ensure high-quality services are provided. . . . Regardless, the SEB
evaluated the proposal in accordance with the RFP. [DELETED] high-quality
work as the incumbent was noted in a past performance questionnaire subject
to the current contract and was taken into account in ASR's past performance
rating.

Contracting Officer's Statement at 34.

The record shows that NASA reasonably evaluated ASR's technical proposal,
including the scenario responses, based on what appeared within the four
corners of ASR's technical proposal and accounted for [DELETED] past
performance in the past performance evaluation. ASR has not provided us any
reason to find that the agency's evaluation here was unreasonable. [11]

ASR also disputes the significant weakness that the agency found in its
proposal for its failure to explain its methodology for fulfilling the
requirements identified in the Anticipated Semi-Annual Forecast Letter (RFP
encl. 2). ASR claims that the methodology was in fact described in its
proposal. ASR Initial Protest at 3; ASR's Comments at 2. The RFP
specifically requested that offerors explain their technical approach and
methodology to be utilized to meet the requirements in the Forecast Letter,
including "any assumptions as a means to demonstrate the proposed approach
and understanding of the requirements." RFP sect. L.14.1. The agency concluded
that ASR's proposal failed to address the methodology that was used to
develop the FTEs that ASR proposed based on the estimates and information
contained in the Forecast Letter. Supplemental Contracting Officer's
Statement at 9. Based on our review of ASR's proposal, we find that the
agency reasonably concluded that ASR failed to adequately state its
methodology as to how the Forecast Letter was used to develop its proposed
staffing.

ASR, like Hernandez, argues that the agency improperly added additional FTEs
for reliability services and continuous risk management services in the cost
evaluation, which also resulted in a decrease in ASR's mission suitability
score. ASR had proposed [DELETED] FTEs per year for reliability services and
[DELETED] FTEs per year for continuous risk management services. Agency
Report, Tab 14, ASR Proposal, Cost/Price Volume, at 8-9. However, because,
as noted above, ASR failed to explain its methodology for meeting the
forecast requirements while proposing FTEs below the "historical" levels,
the agency raised ASR's proposed FTEs to the "historical" levels. In its
protest, ASR stated that it is able to account for its lower proposed FTEs
"with an increase in small business efficiency, initiatives and innovations
by reducing the current number of field personnel by utilizing part time
personnel resulting in cost savings to NASA." ASR Initial Protest at 3. In
response, the contracting officer notes that "none of these cost-reducing
measures were cited in the Estimating Methodology of ASR's Cost/Price
Proposal." Legal Memorandum at 29. Our review confirms the agency's position
and we therefore find that the agency reasonably increased the FTEs and the
probable cost of ASR's proposal in these areas, and thus properly lowered
ASR's mission suitability score in accordance with the RFP evaluation
scheme.

ASR challenges other aspects of the cost realism evaluation that resulted in
a significant upward adjustment to ASR's costs. As noted by the agency, ASR
applied the same labor rate for incumbent employees that it applied to its
own employees. This was an incorrect labor rate for the incumbent employees.
NASA moved the costs for these employees into the correct labor category and
raised ASR's probable costs accordingly. Supplemental Contracting Officer's
Statement at 13. ASR now admits that it did use the incorrect labor rate for
the incumbent employees, but contends that the methodology that NASA
utilized in making the cost realism calculations is flawed. ASR Comments at
2. In response, the agency further explained its methodology, Supplemental
Contracting Officer's Statement at 11, upon which ASR was given the
opportunity, but failed, to comment. We have reviewed the record in this
regard, and find the increase in ASR's probable costs as a result of the
change of the labor rates for the incumbent personnel was reasonable.

ALLEGED PROCUREMENT INTEGRITY VIOLATION

Finally, Hernandez argues that a possible procurement integrity violation
involving disclosure of source selection information and possible bias by
some SEB members in violation of the Office of Federal Procurement Policy
Act, 41 U.S.C. sect. 423 (Supp. IV 1998) may have occurred, which Hernandez
contends our Office should investigate since NASA has not adequately done
so. That Act provides that no person shall file a protest alleging a
violation of the Act, unless the alleged violation was first reported to the
agency responsible for the procurement. 41 U.S.C. sect. 423(g); see 4 C.F.R. sect.
21.5(d). Hernandez brought the potential violations to NASA's attention.
NASA reports that it reviewed the contentions, but found that the alleged
violations likely did not occur and in any case there was no effect on the
integrity of the evaluation process. NASA also reports that it has referred
the matter to its Inspector General for investigation, which is still
ongoing. Because our consideration of this issue pending the completion of
NASA's investigation would be premature, this allegation is dismissed. See
Veda, Inc.--Recon., B-278516.3; B-278516.4, July 8, 1998, 98-2 CPD para. 12 at 5
n.1.

The protests are denied.

Anthony H. Gamboa

Acting General Counsel

Notes

1. The responses to all mission suitability subfactors were to be presented
in the form of oral presentations, with the exception of responses regarding
relevant experience and educational levels of proposed labor categories and
the professional employees compensation plan. RFP sect. L.8. There were seven
specific scenarios representing typical services required to satisfy the
mission requirements to which offerors were to submit responses. RFP sect.
L.14.1.B.

2. This provision was based on the assumption that a significant lack of
cost realism may reflect a flawed understanding of, or an inability to meet,
the government's requirements and thus could adversely affect an offeror's
mission suitability rating. Agency Legal Memorandum at 2-3.

3. The RFP stated that a difference of 11 to 15 percent between the proposed
and probable costs required that 100 points be subtracted from the mission
suitability score. RFP sect. M.3.3.

4. NASA has stayed the award of the contract to SRS pending the resolution
of these protests. Agency Report at 6.

5. The RFP, under the technical approach subfactor, stated that the agency
would evaluate "the relevant experience and educational levels of the
proposed labor categories to provide services within each service area of
the SOW." RFP sect. M.3.1.

6. The contracting officer notes that the fact that the SEB recognized as a
strength in SRS'S proposal the use of minimum education requirements did not
mean that the SEB noted a corresponding weakness in Hernandez's proposal.
Supplemental Contracting Officer's Statement at 7.

7. The agency's evaluation of this database was considered under the
management approach subfactor, which stated that the agency would evaluate,
among other things, an offeror's "approach on software and hardware." RFP sect.
M.3.1.C.

8. In fact, Hernandez now states that it was aware that the figures labeled
"historical" FTEs were incorrect, but that it decided not to pursue the
matter in order to preserve its "competitive advantage." Hernandez Comments
(Nov. 27, 2000) at 9. To the extent that Hernandez claims that the figures
on the table were improperly labeled, this would constitute an untimely
challenge to the terms of the RFP. 4 C.F.R. sect. 21.2(a)(1) (2000).

9. A "good" adjectival rating was defined as:

A proposal having no deficiency and which shows a reasonably sound response.
There may be strengths or weaknesses, or both. As a whole, weaknesses not
off-set by strengths do not significantly detract from the offeror's
response.

Agency Report, Tab 23, SEB Presentation Charts to Source Selection Official,
at 10.

10. For example, as discussed above, in contrast to SRS's proposal,
Hernandez's proposal was properly not credited with strengths or weaknesses
for its proposed database and training. Thus, the agency was not required to
specifically discuss these features of Hernandez's proposal in the
evaluation documentation.

11. ASR argues that the valuation of a contract that it performed at
[DELETED] was incorrectly listed by the questionnaire respondent at $530,000
instead of $5.8 million, so the ASR's past performance rating was
understated. ASR's Comments at 3. We note that an apparent disagreement or
misunderstanding between ASR and the respondent caused this problem, not
NASA's misevaluation. In any case, NASA asserts that even had it considered
the valuation of the [DELETED] contract at the higher value, it is unlikely
that the SEB would have raised its past performance rating from "very good"
to "excellent," inasmuch as ASR had no contracts that were "truly aerospace
related." Supplemental Legal Memorandum at 31.