TITLE:  Cooperativa Muratori Riuniti, B-294980; B-294980.2, January 21, 2005

BNUMBER:  B-294980; B-294980.2

DATE:  January 21, 2005

**********************************************************************

   Decision



   Matter of:   Cooperativa Muratori Riuniti



   File:            B-294980; B-294980.2



   Date:              January 21, 2005



   Reed L. von Maur, Esq., for the protester.



   Susan L. Schor, Esq., and Laurence Schor, Esq., McManus, Schor, Asmar &

Darden, for Impresa Pizzarotti & C. S.p.A., an intervenor.



   Damon Martin, Esq., and Shivaun White, Esq., Naval Facilities Engineering

Command, for the agency.



   Jennifer D. Westfall-McGrail, Esq., and Christine S. Melody, Esq., Office

of the General Counsel, GAO, participated in the preparation of the

decision.



   DIGEST



   1.  In evaluating proposals for construction work, agency has not provided

a reasonable basis for distinguishing between offerors' experience in

performing multiple projects at multiple sites under a single contract and

offerors' experience in performing multiple projects at multiple sites

under multiple contracts, particularly where solicitation called for

performance at two separate work sites.



   2.  Protest against evaluation of past performance is sustained where

record reveals that protester's past performance was re-rated by the

evaluators on a different scale and in response to different questions

than those posed to the references, and it is not clear that the new

ratings were reasonably based.



   3.  Evaluators reasonably rated protester's proposed construction schedule

as good, as opposed to excellent, where they determined that protester had

offered an accelerated schedule, but had failed to offer evidence that it

had thought through the implications of that schedule with regard to

matters such as staffing.



   DECISION



   Cooperativa Muratori Riuniti (CMR) protests the evaluation of its proposal

and the award of a contract to Impresa Pizzarotti & C. S.p.A. (Pizzarotti)

under request for proposals (RFP) No. N33191-04-R-4004, issued by the

Department of the Navy for construction of two facilities at Aviano Air

Force Base in Italy.  The protester takes issue with the agency's

evaluation of its technical proposal.



   We sustain the protest.



   BACKGROUND



   The RFP, which contemplated the award of a fixed-price contract, requested

prices for a base and six optional line items.  Contract line item No.

(CLIN) 0001 (the base item) and CLIN 0002 sought prices for the work

associated with "Phase II" of the effort, construction of a personnel

alert holding area.  CLINs 0003-0007 sought prices for the work associated

with "Phase I" of the effort, construction of a heavy drop rigging

facility.  The agency notes that the sites at which the two "phases" will

be performed are approximately a half-mile apart.  The solicitation

provided for exercise of CLIN 0002 within 180 days after contract award,

CLIN 0003 within



   365 days after contract award, and CLINs 0004-0007 within 90 days after

exercise of CLIN 0003.



   The RFP provided for award to the offeror whose proposal represented the

best value to the government.  Three equally weighted

factors--organizational experience, organizational past performance, and

schedule--were to be considered in the evaluation of technical proposals;

taken together, these factors were to be of approximately equal weight to

price in the evaluation.  Proposals were to be rated both overall and with

regard to each evaluation factor as excellent, good, satisfactory,

marginal, or poor. 



   Six offerors responded to the RFP.  The technical evaluation board (TEB)

assigned Pizzarotti's technical proposal ratings of excellent for past

performance and schedule and a rating of good for organizational

experience; overall, the TEB rated the proposal as excellent.  The TEB

rated CMR's proposal as good for past performance and schedule and as

satisfactory for organizational experience, resulting in an overall

technical rating of good.  The other proposals were rated lower.  CMR's

overall price, inclusive of all options, of [deleted] was [deleted], while

Pizzarotti's price of *20,716,210 was [deleted].  The source selection

board determined that the additional quality of Pizzarotti's proposal

outweighed the price difference between the two proposals and selected it

for award.  On September 23, 2004, the Navy notified Pizzarotti and CMR

that Pizzarotti had been awarded a contract for CLINs 0001 and 0002.  Upon

receipt of a written debriefing, CMR protested to our Office.



   DISCUSSION



   CMR takes issue with its proposal's rating under each of the evaluation

factors, contending that it should have received a rating of good rather

than satisfactory for organizational experience and ratings of excellent

rather than good for past performance and schedule.  The protester argues

that if its proposal had received the technical ratings that it deserved,

the agency would have determined that it represented the best value to the

government.



   In reviewing a protest challenging an agency's evaluation of a proposal,

we will not evaluate the proposal anew or substitute our judgment for that

of the agency; we will examine the record to determine whether the

agency's judgment was reasonable and in accord with the RFP evaluation

criteria and with applicable procurement statutes and regulations,

however.  Symtech Corp., B-289332, Feb. 19, 2002, 2002 CPD P 43



   at 4.  As explained below, we conclude that the agency's evaluation of

CMR's proposal under both the organizational experience and past

performance evaluation factors was unreasonable.  Because the errors in

the evaluation may have affected the outcome of the competition, and

therefore prejudiced CMR, we sustain the protest. 



   Experience



   The solicitation defined relevant organizational experience as new

construction or renovation where the project was completed within the past

5 years, similar in magnitude (expressed in terms of euro amount), similar

in construction features, and similar in other project features such as,

but not limited to, traffic management and security issues.  The RFP

instructed each offeror to submit a list of five relevant projects.



   The TEB assigned CMR's proposal a rating of satisfactory under the

organizational experience evaluation factor, noting that "on an experience

basis, [CMR] could only be considered minimally qualified to tackle the

project at hand," and that awarding to the firm "would constitute some

risk to the government."  Technical Evaluation Report at 6.  The rating

was based on the evaluators' assessment of each of the protester's prior

projects as only "somewhat relevant."



   The evaluators arrived at the relevance ratings under this factor by

assessing each project as relevant, somewhat relevant, or "non relevant"

with regard to completion date, construction features, project value, and

project complexity.  Ratings of relevant on a minimum of three of the

foregoing criteria were required for the project to be considered

relevant, and ratings of relevant on a minimum of two criteria, or ratings

of somewhat relevant on all four criteria, were required for the project

to be considered somewhat relevant.  All five of CMR's projects were rated

as relevant with regard to completion date and construction features, but

none was rated as relevant with regard to project value or project

complexity; because each of CMR's projects was rated as relevant under

only two criteria, each was rated as somewhat relevant overall.



   None of CMR's projects was rated as relevant with regard to project value

because none had a completed cost within the agency's estimated price

range for the work to be accomplished pursuant to this solicitation of 20

to 30 million euros.  Further, none of the projects was rated as relevant

with regard to project complexity because none was found to be

sufficiently similar, taking into account traffic management, security,

and number of job sites.  In particular, CMR's first project was rated as

only somewhat relevant with regard to project complexity because while it

involved airport and job site security, it involved only one job site and

no traffic management; CMR's second project was rated only somewhat

relevant with regard to the criterion because there were no traffic

management or security issues other than job site security, and while the

project involved two sites, they were adjacent to one another; the

protester's third project was rated as somewhat relevant because it

involved only one site and no traffic management; and both the fourth and

fifth projects were rated as "non relevant" because they involved a single

site, job site security only, and no traffic management issues.



   CMR argues that its projects demonstrated relevant experience and that it

should have received a rating of good, rather than merely satisfactory,

under the organizational experience factor.  Specifically, the protester

takes issue with the agency's rating of its projects as merely somewhat

relevant with regard to project value and project complexity.



   With regard to project value, the protester contends that the contract to

be performed here actually consists of two separate projects with a

combined value of 20 to 30 million euros that are to be performed (at

least in part) concurrently, and that it demonstrated experience in

handling multiple projects with a combined value of 20 to 30 million euros

concurrently.  In this regard, the protester's proposal referenced the

following projects:



   +------------------------------------------------------------------------+

|Project Title     |Amount at completion|Date of award|Date of completion|

|------------------+--------------------+-------------+------------------|

|Alghero Airport   |*16,380,000         |Jan 01       |Aug 03            |

|Terminal          |                    |             |                  |

|------------------+--------------------+-------------+------------------|

|Siena Recycling   |*13,161,600         |Dec 00       |Nov 02            |

|Center            |                    |             |                  |

|------------------+--------------------+-------------+------------------|

|Aviano Fitness    |*9,794,250          |Jul 00       |Feb 03            |

|Center            |                    |             |                  |

|------------------+--------------------+-------------+------------------|

|Shopping Center Le|*14,258,000         |Jul 02       |Aug 03            |

|Valli             |                    |             |                  |

|------------------+--------------------+-------------+------------------|

|Soccer Stadium    |*8,702,000          |Feb 01       |Sep 02            |

|Expansion         |                    |             |                  |

+------------------------------------------------------------------------+



   The proposal also included the following excerpt:



   Multiple job sites at the same military base is a situation with which CMR

is extremely familiar.  In calendar year 2002, for example, CMR had 5

separate U.S. NAVY managed projects under construction at 5 different

sites at Aviano Air Base alone:  Integrated Communications Complex; DoDDs

Kindergarten, Radar Approach Control Facility, Fitness Center, and the

Golf Course Clubhouse.  At that time, we had also recently completed work

on the very successful Main Gate Entry and Medical Clinic projects, also

for the U.S. Navy at Aviano.  In addition to this $25M in Navy work at

Aviano, during this same time period, we were responsible for the $8.4M

U.S. Air Force Saber and $1.8M Total Maintenance contracts at Aviano Air

Base.  Every project under these contracts was delivered with high quality

and respecting the required client delivery timelines.  We have a similar

experience at Vicenza and Livorno, where in 2003, we had $19M and $9M in

projects under construction.



   CMR Technical Proposal at 4.



   The agency argues in response that it was clear from the terms of the

solicitation that only projects with values of 20 to 30 million euros

would be considered relevant, and that, therefore, it was appropriate for

it to rate the protester's projects, which each had a value below that

range, as only somewhat relevant with regard to project value.  The agency

further argues that it was reasonable for the evaluators to distinguish

between experience in performing multiple projects under a single contract

with an overall value of 20 to 30 million euros and multiple projects

under multiple contracts with combined values of 20 to 30 million euros

because supervising and administering a 20 to 30 million euro contract is

a much bigger job than supervising and administering a smaller, e.g., 10

million euro, contract.  In this regard, the agency notes that there "is a

significant difference in responsibility for [the positions of Project

Manager, Project Superintendent, Assistant Project Manager, Quality

Control Manager, and Safety Specialist] for a project between



   *20-30 million compared to a *10 million."  Agency Response to

Supplemental Protest and GAO Questions, Dec. 21, 2004, at 5.



   Regarding the agency's first argument, the RFP did provide that for

experience to be considered relevant, a project needed to be "similar in

magnitude (euro amount)," which, we think, can only reasonably be

interpreted as meaning that the project needed to be similar in magnitude

to the project(s) here.  It is not clear, however, whether the

solicitation here comprised a single project (the overall work effort),

with a value of 20 to 30 million euros, or two projects (construction of a

personnel alert holding area and construction of a heavy drop rigging

facility), with a combined value of 20 to 30 million euros.  Either

interpretation is reasonable in our view, given that the RFP itself refers

to the work both as a project (in the specification table of contents) and

as projects (on the RFP cover page, SF 1442).[1]  Accordingly, we do not

think that the RFP can be said to have clearly placed offerors on notice

that only projects with values of 20 to 30 million euros would be

considered relevant; rather, we think that it may reasonably be

interpreted as providing for consideration of projects similar in value to

one of the phases as relevant.[2]



   Regarding the agency's argument that it was reasonable for the evaluators

to distinguish between experience in performing multiple projects under a

single contract with an overall value of 20 to 30 million euros and

multiple projects under multiple contracts with combined values of 20 to

30 million euros because supervising and administering a 20 to 30 million

euro contract is a much bigger job than supervising and administering a 10

million euro contract, the issue is not whether administering and

supervising a larger contract is more difficult than administering and

supervising a smaller one; the issue is whether administering and

supervising a larger contract is more difficult than administering two

smaller ones with an equivalent overall value concurrently.  The agency

has offered no persuasive argument as to why such is the case, whereas the

protester has offered two reasonable arguments as to why concurrent

administration of multiple contracts is in fact more difficult: (1) under

multiple contracts, the contractor is required to deal with multiple

government contract managers, each of whom may interpret and apply

government procedures differently, while under a single contract, the

contractor deals with only one government contract manager, and (2)

increasing the number of contracts increases the number of submittals

since use of the same material at multiple sites under multiple contracts

requires a separate submittal for approval of the material under each,

whereas use of the same material at multiple sites under a single contract

does not.  To the extent that the agency argues that it can assume that a

company with experience with a 20 million euro contract will staff

management positions under this contract with qualified individuals, but

that it cannot make the same assumption for companies that have performed

combined efforts of 20 million euros, see id., we do not think that the

agency can reasonably make assumptions about personnel qualifications

without instructing offerors to submit information pertaining thereto and

evaluating such information.



   In our view, the agency's evaluation of CMR's projects under the

"similarity in magnitude" (or project value) criterion was unreasonable

because it failed to take into consideration CMR's experience in

concurrently performing smaller projects with combined values in the range

of the estimated value of the contract here.  We think that it was

unreasonable for the evaluators not to consider concurrent performance

under multiple contracts at multiple sites as relevant experience with

regard to the effort to be performed here, given that concurrent

performance at multiple sites is precisely what the RFP here requires.



   We also think that the agency's determination that none of CMR's projects

demonstrated sufficient similarity with regard to project complexity to be

rated as relevant under that criterion was unreasonable.  In our view, it

was not reasonable for the agency to downgrade the relevance ratings of

CMR's projects on the basis that each project, on an individual basis,

failed to involve multiple sites, given that the projects, as a group,

demonstrated abundant experience with multiple sites.  It simply makes

little sense that if an offeror presented two projects, each involving

security issues and multiple sites, both would be determined relevant with

regard to project complexity, whereas if an offeror presented two

projects, each involving security issues, that were performed at different

sites at the same time, neither would be determined relevant with regard

to project complexity.[3]



   In our view, the record fails to demonstrate that the agency had a

reasonable basis for its determination that CMR could only be considered

minimally qualified with regard to experience and that awarding to the

firm would constitute some risk to the government, and thus that it should

be rated as merely satisfactory with regard to organizational experience. 



   Past performance



   The agency evaluated CMR's past performance on the basis of information

collected by the evaluation boards for other solicitations for which CMR

competed at approximately the same time as the solicitation here.  The

agency explains that contractors frequently cite the same projects in

their responses to multiple solicitations, and, thus, to save time and

reduce the intrusion on the references, where a reference check has

recently been made, the evaluators reuse the information rather than

repeating a call.



   While we see nothing objectionable in this basic approach, i.e., basing a

past performance evaluation on information compiled in connection with a

different recent solicitation, we do find the manner in which it was

implemented here objectionable.  In this connection and as explained more

fully below, the record reveals that the TEB here used the ratings

collected by the other TEBs to re-rate CMR in accordance with a different

rating scale and under different criteria than used by the original TEBs,

and there is no evidence that the new ratings were reasonably based. 

Moreover, the record reveals that Pizzarotti, which received a past

performance rating of excellent, was rated pursuant to a different, more

liberal rating scale than either of the scales used to rate CMR's past

performance, and it appears that use of the more liberal rating scale may

have contributed to Pizzarotti's superior rating.



   The agency has submitted statements from the individuals who completed the

reference checks for the other TEBs, all of whom indicate that they told

the references whom they contacted to rate CMR's performance on a scale of

excellent/good/satisfactory/marginal/poor.  The TEB rating sheets included

in the agency report for four of CMR's five projects do not employ such a

rating scale for the individual questions, however; they use the following

rating scale: exceeded the standard, met the standard, departure from

standard increased risk/impact to the client, departure from standard

caused significant risk/impact to the client, unacceptable departure from

standard.[4]  The statements further reveal that with regard to several of

the projects, the questions asked of the reference were not the same

questions as those on the rating sheets completed by the evaluators here. 

For example, according to the statement of the chairperson of the TEB for

solicitation No. N33191-04-R-4003, who conducted several of the past

performance checks that were used as a basis for the evaluation of CMR's

past performance under the instant RFP, he asked the references whom he

contacted the following questions:



   *  Did the contractor achieve high level of coordination

between subcontractors, suppliers, and JV partners, of applicable, of the

project?



   *  Was the contractor successful at managing

schedule/delivery dates?



   *  Was the contractor successful at managing costs and

maintaining the project budget?



   *  Did the contractor complete on the schedule dates required

by the contract?



   *  Was the contractor responsive and cooperative during

performance, and committed to customer satisfaction?



   *  Did the contractor comply with safety requirements of this

contract?



   *  Did the contractor demonstrate proficiency with

computerized CPM schedules?



   The forms completed by the TEB here for the same projects instead included

the following questions:



   *  Did the contractor's performance conform to the terms and

conditions of the contract, including schedule and budget, and

administrative aspects of performance?



   *  Was the Contractor capable, efficient, and effective?



   *  Did the contractor's performance conform to its safety

plan?



   *  Did the contractor's performance conform to its quality

control plan?



   *  Was the contractor responsive and cooperative during

performance?



   *  Was the contractor committed to customer satisfaction?



   It is apparent from the foregoing that the TEB here re-rated CMR's

performance under the various projects using different questions and a

different rating scale than those used by the evaluators who conducted the

reference checks.  Given the difference between the rating scales used and

the questions asked, there is no way that we can be certain that the

ratings on the forms completed by the TEB here accurately reflect the

opinions expressed by the individuals contacted.  For example, there is no

evidence that any of the references contacted expressed an opinion as to

whether CMR's performance conformed to its quality control plan, yet the

TEB rated CMR's performance as having met the standard (but not exceeded

it) with regard to all four projects.  Further, there is no evidence that

it was reasonable for the TEB to translate the references' original

ratings (of excellent/good/satisfactory/etc.) into virtually across-the

board ratings of "met the standard."[5]  In this regard, the agency has

furnished us with neither the original rating sheets, nor with an

explanation as to how it translated the scores.  For example, it has not

been explained (and it is unclear to us) whether ratings of "met the

standard" reflect original ratings of satisfactory (as would seem

appropriate) or original ratings of good (pursuant to the reasoning that

"met the standard" was the second highest rating under the original scale,

whereas "good" was the second highest under the scale used by the

TEB).[6]  Without such information, we have no basis upon which to

conclude that the agency's evaluation of the protester's past performance

was reasonable.



   Further, as noted above, the record reveals that Pizzarotti's past

performance was initially rated using a different, more liberal rating

scale than either of those described above.  According to the statement of

the individual who conducted Pizzarotti's reference checks pursuant to an

earlier solicitation, he explained to the references whom he contacted

that they were to rate Pizzarotti's performance in accordance with the

following scale:  met or exceeded the standard, close to the standard,

departure from the standard with increased risk, departure from the

standard with significant risk, unacceptable departure from the standard. 

This scale differs from those used to rate CMR's past performance in that

it collapses the top two (in the case of the exceeded the standard/met the

standard/etc. scale) or possibly three ratings (in the case of the

excellent/good/satisfactory/marginal/poor scale) into the single top

category of met or exceeded the standard.  It would obviously have been

easier for Pizzarotti to attain top ratings under this scale than for CMR

to attain top ratings using either of the others.  In our view, the use of

these different rating scales calls into question the even-handedness of

the evaluation of CMR and Pizzarotti's past performance.



   Schedule



   The solicitation provided that offerors' proposed schedules would be

evaluated to determine the extent to which the offeror proposed to

complete the work within the time frames specified in the RFP.  Offerors

were instructed to specify the duration of construction and to submit one

schedule for both phases, including no more than 100 major project

events.  The solicitation also provided that the offeror's proposed

schedule would be "enhanced" by addressing the following elements

separately for each building: identified critical path, overall contract

construction schedule, account for holiday periods (U.S. and Italian),

critical equipment delivery dates, and critical submittal submission dates

for the submittals required by the solicitation.  The RFP further provided

that "additional consideration" would be given for the following:  (1) the

extent to which the management approach is sufficiently detailed to assess

validity, demonstrates flexibility and resourcefulness, and offers a high

probability of success, and (2) early time completion of the contract.



   The TEB assigned CMR's proposal a rating of good for schedule.  The

evaluators noted that CMR had proposed to complete both phases

significantly early, Phase II [deleted] days early and Phase I [deleted]

days early, according to the evaluators.  The TEB went on to explain the

basis for its rating as follows:



   Based on having a fully compliant schedule, with advance completion

dates[,] the schedule was rated Good overall.  The board could not rate

the schedule excellent because significant justification of these early

completion dates was not provided.  The firm provides a narrative that

demonstrates it understands all of the project constraints and phasing,

including stating that it will use [deleted].  In addition the firm states

that it intends to [deleted].  Based on its detailed, correctly

constrained, early completion schedule the firm was rated Good overall for

Factor 3.



   Technical Evaluation Report at 6-7.



   The protester takes issue with the evaluators' determination that its

schedule could not be rated as excellent because "significant

justification" of its proposed early completion dates was not provided. 

CMR argues that the evaluators imposed a requirement for significant

justification based on their misunderstanding as to the degree to which

its proposed schedule was accelerated.  In the alternative, the protester

argues that its proposal did offer significant justification.



   With regard to the first point, the protester argues that the agency's

requirement for significant justification of its early completion dates

was based on the agency's misperception that its proposed completion dates

were in fact significantly early.  The protester argues that it did not

propose to complete the contract work over [deleted] early, as the

evaluators determined; rather, according to the protester, it proposed to

complete the work [deleted] early.  The difference is attributable to the

fact that the agency interpreted the solicitation as providing for a

36-month performance period for each phase of the work, with exercise of

the Phase I options to occur 8 months after contract award, while the

protester interpreted the RFP as providing for a single period of

performance of 36 months for accomplishment of both phases.[7]



   While the protester has argued that the agency incorrectly calculated the

number of days early that it proposed to complete the work effort in its

entirety (i.e., both Phases I and II), it has not argued that the agency's

calculation that it proposed to complete Phase II of the work [deleted]

early was incorrect.  We see no reasonable basis to conclude that the

agency would have required lesser justification for a schedule that

proposed completion of Phase II [deleted] early and completion of Phase I

[deleted] early than a schedule that proposed completion of Phase II

[deleted] early and completion of Phase I [deleted] early, since it is the

completion date for the Phase II work, which remains the same in the two

scenarios, that is the most accelerated.  Accordingly, we are not

persuaded by the protester's argument that the agency's miscalculation of

the extent to which its schedule was accelerated resulted in the agency's

requiring a higher degree of justification for the schedule.



   As noted, the protester also argues that its proposal did offer

significant justification for its accelerated schedule.  CMR asserts that

it offered significant detail in support of its proposed schedule,

including:



   *  Reciting [deleted] events, rather than merely the required

100, in its CPM schedule.



   *  Itemizing the [deleted] to the job site for each project.



   *  Itemizing [deleted].



   *  Detailing how it intended to use the [deleted].



   The protester is essentially disagreeing with the agency's judgment as to

what constitutes significant justification.  The mere fact that a

protester disagrees with an agency judgment does not demonstrate that the

agency judgment was unreasonable, however.  American States Utilities

Servs., Inc., B-291307.3, June 30, 2004, 2004 CPD P 150 at 7.  The

evaluators desired additional evidence that the protester had thought

through the implications of its accelerated schedule with regard to

matters such as staffing,[8] and the protester did not furnish this sort

of additional evidence.  We do not think that the evaluators'

determination that the protester's proposed schedule could not be rated as

excellent due to this shortcoming was unreasonable.  Accordingly, we deny

this ground of CMR's protest.



   CONCLUSION AND RECOMMENDATION



   Because we find that the agency lacked a reasonable basis for its rating

of the protester's proposal under the organizational experience and past

performance evaluation factors, we sustain the protest.  We recommend that

the agency reevaluate CMR's proposal with regard to both factors.  With

regard to the past performance factor, we recommend that both CMR and

Pizzarotti's references be contacted to ensure that they are asked to rate

performance on the same basis.  If, as a result of the reevaluation, CMR's

proposal is determined to represent the best value to the government, we

recommend that the agency terminate the contract awarded to Pizzarotti and

make award to CMR.  We also recommend that the agency reimburse the

protester for its costs of filing and pursuing the protest.  Bid Protest

Regulations, 4 C.F.R. S 21.8(d)(1) (2004).  In accordance with section

21.8(f) of our Regulations, CMR's claim for such costs, detailing the time

expended and the costs incurred, must be submitted directly to the agency

within 60 days after receipt of the decision.



   The protest is sustained.



   Anthony H. Gamboa



   General Counsel



   ------------------------



   [1] We also note that the introductory section of the agency report

describes the work effort as consisting of two projects.  See Agency

Report at 2 ("The total estimated cost range for the two projects was

between twenty million (. . .) and thirty million

(. . .) euros.")



   [2] Each of the phases represented roughly half of the overall value of

the work effort according to the government estimate.



   [3] Regarding CMR's alternative argument that the TEB improperly limited

the factors that it considered in determining whether a project was

similar in complexity to whether the project involved multiple sites,

whether it involved security issues, and whether it involved traffic

management issues, and that it should also have considered similarity in

project features such as safety program management, quality control

program management, CPM [Critical Path Method] management, and

coordination with the customer, we think that it was within the agency's

discretion to determine which project features it would consider in

assessing similarity with regard to project complexity.



   [4] The fifth project was rated on a scale of

excellent/good/satisfactory/marginal/poor on a form that included eight

questions.  (The questions were similar, but not identical, to either of

the lists of questions set out below.)  The reference rated CMR's

performance as satisfactory in response to four questions, as good in

response to three, and as excellent in response to the final question,

which pertained to contractor commitment to customer satisfaction.  The

reference rated CMR's overall performance on the contract as good, and

commented that he "considered CMR ROICC Aviano's #1 Contractor for

projects with dollar value of <=$10M."  Agency Report, Tab 5(B), at 8.



   [5] CMR was rated as having "met the standard" in 21 of 24 instances.  (In

one of the remaining three, it was rated as having exceeded the standard,

and it was not rated in the remaining two.)



   [6] There is some evidence in the record that ratings of good were

translated into ratings of "met the standard."  In this regard, the

protester has submitted a statement from the individual whom the agency

contacted regarding CMR's performance on the Siena Recycling Center

project, who reports that he rated CMR as good or excellent in response to

all questions posed him.  The rating sheet completed by the TEB here rates

CMR as having "exceeded the standard" with regard to only one question and

as having merely "met the standard" with regard to the remaining five,

however.



   [7] The RFP was ambiguous with regard to the time period for completion of

the entire work effort.  In section 00202 (Evaluation Factors for Award),

the solicitation instructed offerers that they should:



   Provide the total number of calendar days for the construction duration. 

The maximum duration for construction is not to exceed

36 months.  . . .  Provide one schedule for both phases, including no more

than 100 major project events.  The schedules shall be based on exercise

of all Phase I options eight months after contract award and include

government review times.



   We think that this passage clearly conveys the intent that both phases of

construction are to be completed within 36 months.  A contrary intent is

conveyed in the clause entitled Commencement, Prosecution and Completion

of Work, incorporated into the solicitation on page 00710-19, however. 

This clause provides in relevant part as follows:



   The Contractor shall be required to . . .

               1.  CLIN 0001 Basic Work Personnel Alert Holding Area Phase

II:  complete the entire work, inclusive of CLIN 0002, not later than 1095

calendar days after contract award; and

               2.  CLIN 0003 Heavy Drop Rigging Facility Phase I:  complete

the entire work, inclusive of CLINs 0004, 0005, 0006, and 0007, not later

than 1095 calendar days after CLIN 0003 option exercise date.



   [8] The agency explains that "[t]he issue for the board was that CMR did

not provide the manpower or any other information explaining how it was

projecting to accomplish the tasks in its schedule, which the TEB would

have been able to use to ascertain if it was reasonable for CMR to

accomplish the tasks in the schedule."  Agency Response to Supplemental

Protest and GAO Questions, Dec. 21, 2004, at 8.