GAO Bid Protests
News stories on federal bid protest decisions issued by the GAO General Counsel.
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GAO Denies Protest by L3Harris Technologies of Florida
WASHINGTON, May 15 -- The Government Accountability Office has issued a decision on May 13, 2022, denying a bid protest dated May 3, 2022, filed by L3Harris Technologies Inc. of Palm Bay, Florida.
According to the GAO, L3Harris Technologies Inc. "protests the award of a contract to Peraton Inc., of Herndon, Virginia, under request for proposals (RFP) No. FA7022-21-R-0001, issued by the Department of the Air Force for software development and engineering services support. L3Harris argues that the agency failed to adequately consider whether Peraton has an organizational conflict of interest that
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WASHINGTON, May 15 -- The Government Accountability Office has issued a decision on May 13, 2022, denying a bid protest dated May 3, 2022, filed by L3Harris Technologies Inc. of Palm Bay, Florida.
According to the GAO, L3Harris Technologies Inc. "protests the award of a contract to Peraton Inc., of Herndon, Virginia, under request for proposals (RFP) No. FA7022-21-R-0001, issued by the Department of the Air Force for software development and engineering services support. L3Harris argues that the agency failed to adequately consider whether Peraton has an organizational conflict of interest thatwould preclude award to it. We deny the protest."
The bid protest decision (B-420490) was issued on May 3, 2022 (https://www.gao.gov/products/b-420490).
In its findings, the GAO said: "Protest that the agency failed to properly consider an impaired objectivity organizational conflict of interest (OCI) is denied where the record shows that the contracting officer gave meaningful consideration to whether the awardee had an OCI and there is no clear evidence in the record that the agency's conclusion was unreasonable."
The participants in the case included: Andrew E. Shipley, Philip E. Beshara and Douglas W. Gates, Wilmer Cutler Pickering Hale and Dorr LLP, for the protester. Kevin P. Connelly and Kelly E. Buroker, Vedder Price PC, for Peraton Inc., the intervenor. Lieutenant Colonel Matthew W. Ramage-White, Kevin P. Stiens and Erika Whelan Retta, , Department of the Air Force, for the agency. Heather Weiner and Jennifer D. Westfall-McGrail, Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Denies Protest by LOGMET of Texas
WASHINGTON, May 10 -- The Government Accountability Office has issued a decision on May 9, 2022, denying a bid protest dated May 6, 2022, filed by LOGMET LLC of Round Rock, Texas.
According to the GAO, LOGMET LLC "challenges the terms of the solicitation under request for proposals (RFP) No. FA4897-22-R-0001, issued by the Department of the Air Force for flight operations training and F-15 aircraft maintenance to support the Republic of Singapore Air Force (RSAF) at Mountain Home Air Force Base, Idaho. The protester argues that the agency improperly bundled two requirements and that several solicitation
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WASHINGTON, May 10 -- The Government Accountability Office has issued a decision on May 9, 2022, denying a bid protest dated May 6, 2022, filed by LOGMET LLC of Round Rock, Texas.
According to the GAO, LOGMET LLC "challenges the terms of the solicitation under request for proposals (RFP) No. FA4897-22-R-0001, issued by the Department of the Air Force for flight operations training and F-15 aircraft maintenance to support the Republic of Singapore Air Force (RSAF) at Mountain Home Air Force Base, Idaho. The protester argues that the agency improperly bundled two requirements and that several solicitationprovisions are unduly restrictive of competition. We deny the protest."
The bid protest decision (B-420507) was issued on May 6, 2022-05-10 (https://www.gao.gov/products/b-420507).
In its findings, the GAO said: "1. Protest alleging agency improperly bundled requirements in violation of the Small Business Act is denied where the record shows that the requirements do not meet the definitional prerequisites of the bundling restrictions of the Act, i.e., the requirements were not previously performed under two separate, smaller contracts. 2. Protest challenging terms of the solicitation as unduly restrictive of competition is denied where the solicitation's requirements are reasonably necessary to meet the agency's needs."
The participants in the case included: Wayne Rankin, LOGMET LLC, for the protester. Erika Whelan Retta, Isabelle P. Cutting, Department of the Air Force, for the agency. Emily R. O'Hara and Peter H. Tran, Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Denies Protest by DCR Services & Construction of Michigan
WASHINGTON, May 7 -- The Government Accountability Office has issued a decision on May 6, 2022, denying in part and dismissing in part a bid protest dated April 28, 2022, filed by DCR Services & Construction Inc. of Detroit, Michigan.
According to the GAO, DCR Services & Construction Inc. "protests the non-selection of its quotation for the establishment of a blanket purchase agreement (BPA) under request for quotations (RFQ) No. 1489735, issued by the Department of the Interior, National Park Service (NPS), for contaminated site cleanup services. The protester challenges the agency's evaluation
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WASHINGTON, May 7 -- The Government Accountability Office has issued a decision on May 6, 2022, denying in part and dismissing in part a bid protest dated April 28, 2022, filed by DCR Services & Construction Inc. of Detroit, Michigan.
According to the GAO, DCR Services & Construction Inc. "protests the non-selection of its quotation for the establishment of a blanket purchase agreement (BPA) under request for quotations (RFQ) No. 1489735, issued by the Department of the Interior, National Park Service (NPS), for contaminated site cleanup services. The protester challenges the agency's evaluationof quotations and resulting selection decision. We deny the protest in part and dismiss in part."
The bid protest decision (B-420179.2, B-420179.3) was issued on April 28, 2022 (https://www.gao.gov/products/b-420179.2%2Cb-420179.3).
In its findings, the GAO said: "1. Protest challenging the evaluation of the protester's technical quotation is denied where the evaluation was reasonable and consistent with the terms of the solicitation. 2. Protest challenging agency's evaluation of one awardee's quotation is dismissed where the protester would not be in line to receive a blanket purchase agreement if its allegations were sustained."
The participants in the case included: Lewis P. Rhodes and Orest J. Jowyk, McMahon, Welch and Learned, PLLC, for the protester. William B. Blake, Department of the Interior, for the agency. Michael P. Grogan and Edward Goldstein Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Denies Protest by Academy Leadership of Florida
WASHINGTON, May 7 -- The Government Accountability Office has issued a decision on May 6, 2022, denying a bid protest dated April 13, 2022, filed by Academy Leadership LLC of Juno Beach, Florida.
According to the GAO, Academy Leadership LLC "protests the award of a contract to Gettysburg Addresses, Inc. d/b/a The Lincoln Leadership Institute (Lincoln), under request for proposals (RFP) No. 70CMSD21R00000001, issued by the Department of Homeland Security, United States Immigration and Customs Enforcement (ICE), for leadership-focused training. The protester challenges the agency's best-value tradeoff
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WASHINGTON, May 7 -- The Government Accountability Office has issued a decision on May 6, 2022, denying a bid protest dated April 13, 2022, filed by Academy Leadership LLC of Juno Beach, Florida.
According to the GAO, Academy Leadership LLC "protests the award of a contract to Gettysburg Addresses, Inc. d/b/a The Lincoln Leadership Institute (Lincoln), under request for proposals (RFP) No. 70CMSD21R00000001, issued by the Department of Homeland Security, United States Immigration and Customs Enforcement (ICE), for leadership-focused training. The protester challenges the agency's best-value tradeoffdecision, as well as various aspects of the agency's technical evaluation; asserts that its proposal should have received a higher confidence rating under the past performance factor; and contends that the agency unreasonably evaluated both the protester's and awardee's sample training presentations. We deny the protest."
The bid protest decision (B-419705.3,B-419705.4) was issued on April 13, 2022 (https://www.gao.gov/products/b-419705.3%2Cb-419705.4).
In its findings, the GAO said: "1. Protest challenging the agency's technical evaluation is denied where the awardee's proposal compared favorably to the protester's because the two proposals were different, not because they were evaluated disparately; and where the agency reasonably found that although the protester resolved the weaknesses identified in its proposal, the awardee's proposal was still superior. 2. Protest challenging the agency's past performance evaluation is denied where the agency's evaluation was reasonable and consistent with the solicitation's evaluation criteria and where the agency properly considered past performance in the best-value tradeoff decision. 3. Protest that the agency unreasonably considered the substance of answers given during sample training presentations is denied where the agency evaluated proposals in accordance with the terms of the solicitation. 4. Protest challenging the agency's best-value tradeoff analysis is denied where the record reflects that the agency's source selection rationale was consistent with the stated evaluation criteria."
The participants in the case included: Joseph R. Berger, Thomas O. Mason and Francis E. Purcell, Jr. Thompson Hine LLP, for the protester. Alan Grayson for Gettysburg Addresses Inc., the intervenor. Javier A. Farfan, Department of Homeland Security, for the agency. Hannah G. Barnes and Christina Sklarew Office of the General Counsel, GAO, participated in the preparation of the decision.
