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Comptroller General of the United States
Washington, I}C 2054~
.. -. .~ ~ ". . . ;.'. ... .... ~: . ,.. . .(.~. ,,

Decision
Matter Off O|.~mpus ,I~uilding Services, Inc. File: B-296741,14; B-296741.15

Date:
Grace Bateman, Ehq,, ;l~'d'Am~n~ta Weiner, Esq., Sey:farth Shaw LLP, .for the protester. '¯ Kenneth. B. Weekstein, Esq., and Pamela A. Reynolds, Esq., Epstein Becket & Green, PC, :[or Rowe Contracting Ser~.ces, Inc.., aa intervenor, Frank A, March, Esq,, Department of the Army, for the agency. Mary G, Curcio, Esq., and Jo.hn M, Melody, Esq., Office o'~ the General Counsel, GAO, participated in the preparation of the d~cisi~n: ~IGEST

d

DECISION ,

We deny the protest,

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TECHNICAL EVALUATION

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PRICE EVALUATION

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BEST VALUE DETERMINATION

The protest is denied.

Gary L. Kepplinger General Counsel

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Facsimile Transmission
Date: February 27, 2007
C O~PA.NY PHONE NO.

RECIPIENT Mary Go Curcio
Grace Bateman

GAO

202-512-4788

(202) 828-5359
REPLY FAX NO.: (202) 828-~;393 24134.016 , Number of Pages, Including Cover: .... r-] Hard copy will not follow 21

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SEYE__AR._ TH ..........
WriSt's dlr~ phone

SHAW,,,

815 Con'r'K~"Ut Avenue, N,W. Suite Wmhir~gk~n, D.C. 202-463-2~0 ~u~ 202-828,5393

PROTECTED MATERIAL.TO BE RELEASED ONLY IN ACCORDANCE WITH GAO PROTECTIVE ORDER (Corr~ted February 27, 2007) February 20, 2007

_VIA FACSIMILE 20:2-512-9749 AND U.S. MAIL
M~ry O. Culcio, Esq. Smaior Attorney Procm'emcnt Law Division Oov~'nrnent Accountability Office 41 G Street, N.W. W~hin~ton, D.C. 20548 B-29674.15; Olympus Building Services, Inc.'s S~,ond SupplernentM Protest and Cornmeo.ts on the Agency R~port on Olympus' First Su~lem...ental protest. Dear Ms. Curcio:
u Z z

o

The protester, Olympus Building Services,"Ol" -US''~ hereby files its Second Inc. ( ymp ),
Supplemental Protest and its Comments on the Agency Report on Olympus' First Supplemental Protest. SECOND S UpPLE~NT..AL.PROTEST

The bases for Olympus' Second Supplemental Protest are as follows: 1. D1A's "lh-adeoff Analysis is irrational because it is based upon a material error of fact

regarding the manpower the awardee Rowe Contracting Services, Inc. ("Rowe") and Olympus are proposing. The SSA mistakenly concluded that Rowe offm five more employees than Olympus,

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when, in fact, Olympus actually offer represented the best value. 2.

Mary G. Curcio, Esq. F~bruary 20, 2007 Page 2

15 more employees (Full-time Equivalents "FTE"s) than

Rowe over the contract term. The SSA relied on this mistake of fact in deciding that Rowe's

In the alternative, GAO cannot determine whether the SSA's best value decision is

reasonable in the absence of documents in the record that explain the SSA's comparative manpower analy~sis, or confirm whether the SSA performed any such analysis at all. Olympus' Second Supplemental Protest is timely, in that it is filed within 10 days of February 14,'2007, the date on which DIA first provided to Olympus a copy of Rowe's price proposal which contains the data that the SSA relied on when she made the manpower comparison referenced in the agency's price analysis and best value decision. It is also filed within 10 days of February ] 5, 2007, the date on which Olympus received an e-mail message from DIA disclosing that the ~tgeney does not have any evaluation documents to support the SSA's analysis of the manpower the respective firms offered. . I. The SSA's Tradeoff Analysis Is Fatally Flawed Because it Is Based Upon A Material
Error Of Fact Regarding The Offerors' Proposed Manpower.

A,

The SSA Mistakenly Concluded That Rowe Offered Five More Employees Than Olympus Offered,

The SSA references and compares the manpower that Rowe and Olympus will provide in both the "Price/Cost Analysis" section of the Sou~rce Selection Decision ("SSD") and in the '~FradeoffAnalysis" section of the SSD. A.K, Tab 32, pp. 14 -16. In the "Price/Cost Analysis" seetiou, the -qSA determines that Olympus' price is reasonable and realistle, but then not~ that Olympus' price exceeds Kowe's price while offe five fewer employees than Rowe:

OLYMPUS: Offered price is considered reasonable and realistic. However, the offered price is the second lowest among four offers
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and would cost the Government over $557,000 more than Kowe's off~.

~ at p. 14 (~rnphasis added). Similarly, in the '~Tradeoff Analysis" aection of the SSD, the SSA compares the final four offerors and determines that Rowe's low price offer provides for next ] ow~t offeror, O]ympus: Of the four final offerors, Rowe proposes the lowest priced offer at a firm-fixed-price in the total amount of $ ! 9, 217,912 employees, more than the

Id., at p. 15 (~nphasis added). The SSA obviously thought the comparison bctwecaa the manpower Rowe and Olympus offered was a major discriminator between offers, because she repeated this comparison in the next paragraph in the "Tradeoff Analysis" section of the SSD:

]~d., a~ p. 15 (emphasis added), Finally, again highlighting the importance of the manpower issue in ho" decision, the SSA included the number of employees each bidder offered in a separate column in the "Summary Comparison" table at the conclusion of the '~l'radeoff Analysis" section in the SSD. This separate coltmm in the table again r~flects the SSA's conclusion that Rowe offered with Olympus' employees. employees, compared

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SEYF, ~AP,,.TH
B.

Mary O. Cu.rdo, Esq. February 20, 2007 Page 4

The SSA Mistgkenly Concluded That Rowe Offered More Employees Than Olympus By Using A "Number Of Employees" Standard Rather Than An "FTE" Measure,

The record does not contain any doctrmcnts revealing how the SSA determined that Rowe offered more employees than Olympus offcr~l. Rowe's incoherent and inoomplct¢ final 56 employees. S~e, AR, Tabs 20 and 22. de 51 employees.

proposal do~ not state that it will offer to pro~i

Simflm'ly, Olympus' t~hnical proposa! do~ not state that Olympus will pr

~ AR, Tabs 23 and 25.l The only documents in the record that clearly indicate the manpower Rowe and Olympus will provide are the offerors' price proposals. Specifically, both offerors" price proposals provide detailed information on the numbs, ofjanitors, supervisors, and managm-s offered, and their full-time (8 hours per day, 40 boars per w~ek, 2080 hours per year), or a part-time (20 hours per week, 1040 hours per year) statu~. AR, Tabs 40 and 41. It is not possible to compare the respective manpower proposals by comparing the "nmnber of ornploy¢~s" offered, as th~ SSA has done, beca hours per week are not equivalent five part-time -mployees each working 20

full-time employees each working 40 hours p~r week. To

compare the manpower proposals, it is necessary to express both proposals in terms of"Full-time Equivalent" ("FTE") employ¢~s. Thus, one full-time 40-hour-per wee.k employee wo~d equal 9he FTE, and two part-time 20-hour pro" week employees would also equal one FTE. The followi.ng table summarizes Rowe's and Olympus' manpower proposals in terms ofthe number of FTEs offered. The data in this table came directly flora Rowe's and Olympus' pri~ proposals. AR Tabs
40, 41.

I It is possible that the SSA may have actually got'ten the "51" from the "No Wkcrs.'" Column for the DIAC in Rowe's price proposal, de.spite attributing this number to Olympus, AR, Tab 40, p. 1.
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_AI~_TH

Mm'y G. Curcio, Esq. Februm'y 20, 2007 Page 5

Rowe's Proposed Total Manpower (Janitorial and Management) For The DIAC And The Expansion Building)2 Contract Period 7-Month Base Period Option 1 Total Annual Labor Hours Total FYEs (Total Annual Labor Hours~2080)

Option 2

Option 3
Option 4 TOTAL

Olympus' Proposed Manpower Proposal (Janitorial and Management) For The DIAC And The Expansion Building3 Contract Period 7-Month Ba~e Period Total Annual Labor Hours Total FTEs (Total Annual Labor Hours/2080)

Option
Option 2 Option 3

Option 4
TOTAL

2 Rowe's price proposal has separate pages for the DIAC and the Expansion Building for each contract period. The Total Annual Labor Hour column includes both janitorial and managemm~t employees. The first number in the parenthesis is for the DIAC, and the second is for the Expansion Building. ~ Olympus' price proposal presents data on janitorial and management personnel on separate pages for each contract period. The first number in parenthesis m the Total Annual Labor Hours eolurrm is for janitorial personnel, including the group leader, and the second number is for management, including security escorts. All Olympus data are for both the DIAC and the Expansion Building.
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Thus, when a proper analysis of Row¢'s and Olympus' manpower proposals is p~fformed based upon FTEs, inst~d of proposing five fewer vmploye~ than Rowe, as the SSA mistakenly conclnded~ Olympus a0tually off~ TEs) than

Rowe offm'ed over the term of the contra~t; Thmefore, any best value tradgoffdecision in favor of Rowe that is predigated upon the SSA's " ~al. ysis is irrational on its faR. C. The SSA Admits Using The Manpower Each Offeror Proposed As A Discriminator In The Best Value Decision, " ~nalysis, instead of the correct

In the Legal Memorandum supporting the Agency Rea~ort on Olympus' First S~plemental Protest, DIA argues that the SSA "properly considered the number of employees off, rots proposed when making the so~rce selection decision." AR, Tab 38, pp. Protester c0rreetly observ~ that the Contraetin~ Officer considered the number of ~-mployees each offeror prop0_se¢l._ when making her some selection decision~ however, this consideration w~
¯

Id., at pp. 5-6 (emphasis added). !n addition, in the Contracting Officer's Statement, the SSA confirms that she considered the number ofernployees offered in the best value tradeoffanalysis: The number of employee~ offered is a factor in best value trade off .analysis and a factor in the cost realism analysis in accordance with the solicitation. AR, Tab 39, p. 2, (emph~is added).~ These statements are consistent with DIA's statcments regarding this i~s'-ae in the Legal Memorandum and in the ContraCting Officex's statement

' In the SSD, the SSA asserts that, in accordanoe with FAR 15.404-1 (b)92)(i), she did not need to perform a cost realism analysis, because there was adequate price competition. Howaver, in the Contracting Officer's Statement in the Agency Report on Olympus" First Supplemental Protest, the SSA states that she took account of the number of employees offered in the cost realism analysis.
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Mary G. Cureio, Esq. Febra~a-y 20, 2007 Page 7 supporting the Agency Report on Olympus' initial protest. See, AR, Tab 1, p. 9; AR, Tab 2, p 8.
Therefore, DIA cannot deny that the SSA relied upon her mistaken conclusion regarding the

number of employees that Rowe offered compared to the n~maber that Olympus offered when she selected Rowe for award.
D. The Best Value Decision Is Invalid, Because The SSA Mistakenly Credited Rowe With Offering More Manpower Than Olympus When The Opposite Is
TIRe.

GAO cannot uphold a source selection decision that is premised upon a material mistak~ of fact. American Development __Co_~., B-251,876, B-251876,4, 93-2 CPD P 49 (protest sustained where cost/technical tradeoffwas based on incomplete and inaocurate information). Hero, both the SSA and her attorney-adviser have repeatedly confirmed that the SSA considered Rowe's offer to represent the best value because Rowe's offer was slightly lower in price than Olympus' and Rowe offered more manpower. If the SSA had properly determined that Olympus than Rowe offered over the contract term, she would have realized that this'increased manpower more than offset the less between Olympus' price and Rowe's price.

Gemmo !mpiant~_Sp_A, B-290,427, 2002 CPD ¶146 (agency's source selection decision was .um'easonable where tradeoff decision contained material defects that prejudiced protester).

However, there at~ no documents in the record to indicate that the SSA actually performed a cost realism analysis of offers.
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Mary.G. Curcio, E~. Pcbruary 20, 2007 Page 8

In The Alternative, GAO Cannot Determine Whether DIA'~ Best Value Decision Wa~ Reasonable In The Absence Of Any Documents In The Record To Show How The SSA Evaluated Rowe's Manpower Proposal. A. There Are No Documents In The Record Showing How The SSA Performed The Manpower Analysis That GAO Can Review To Determine Whether The SSA's TradeoffWas Reasonable,

The Agency Report in this procurement contains the entire record that supports th~ agency's contract award to Rowe. There m-e no documents in this record that shed even a ray of light on the data the SSA considered or the process she used to reach the mistaken conclusion that Rowe offered five more employees than Olympus, mad therefore that Rowe represented the best value. The references to the SSA's conclusion in this regard that appear in the SSD and in the Legal Memorandum and Contracting Officer's Statements in the Agency Reports on Olympus' initial and First Supplemental Protests do not provide any reference to an evaluation do~ma~at or to any type of analysis, or even to raw data in the offerors' proposals, that the SSA considered. The SSA's mistaken " conclusion appears to have dropped ~om the sky. Without " it attributes to Rowe, GAO

understanding how the SSA developed

cannot detm'rnine whether the SSA's best value lxadeoffde~ision is reasonable. B. GAO Has Consiste.nfly Held That Where The Decision Record Is Incomplete~ GAO Cannot Determine Whether A Procurement Decision Is Reasonable,

It is well-established that if there is not an adequate record ofth~ evaluation and the source selection decision in a procurement, GAO cannot determine the reasonableness of the agency's evaluation. In Biosph~es_lneor~orated, B-278508.4, .5, .6, 98-2 CPD ¶ 96. In Bio~herics, OAO sustained the protest of a disappointed offeror where the agency's Source Selection Decision memorandum failed to contain a discussion of the results 0fthe SSA's evaluation of revised proposals at:ter discussions. Accordingly, GAO determined that, ~s a consequence of the absence of
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final proposal was technioally superior to the protester's:

Ma~ G. Cureio, Esq. February 20, 2007 Page 9

an adequate record, it could not discea-n the basis for the agency's conclusion that the awardee's

In sum, the evaluation and source selection record furnished to our Office---numerical scores and a blanket determination of acceptability, no.post-discussion narratives, and the source selection memorandum whi~h contains no explanation of how the revised proposal affected the initial evaluation---is insufficient for our Office ~o determine the reasonableness of the agene_y.~S evaluation of proposals and the reas0nab.l..eness of the agenoy's selection decision. Id., at p,4 (emphasis added). See also, T¢!tara Inc,, B-280,922, 98-2 CPD ¶ 124 (protest sustained whore the source selection rnernorand~n contains only conclusory information that does not support the best value decision); ~ti'-Lite Optiqal, B-281,693, 99-I CPD ¶ 61 ~rotest sustained where the record does not provide any documentation or explanation which supports the price/technical tradeof0; Green Valley Transportation, Inc., 13-285,283, 2000 CPD ¶ 133 (protest sustained where record is devoid of qualitative analysis of offerors' past performance); J&J Maintenance, .Inc., EI-284708.3, 2000 CPD ¶ 106 (protest sustained where record does not establish the reasonableness of the evaluation or the cost/technical tradeoffunderlying the source seleelion decision); ~.C.ortland Memorial Hospital, B-286,890, 2001 CPD ¶ 48 (protest sustained where there is inadequate support in the record for the scoring that the contracting officer relied on in making the contract award); Marshall-Putnam Soil and Water Conservation District, B-289,949, .2, 2002 CPD ¶ 90 (.protest sustained where record does not contain contemporaneous documentation supporting or explaining the agency's evaluation); Midland Supt~Iy, Inc, B-298,720, .2, 2007 CPD ~[ 2 (protest sustained where record lacks any documentation reflecting a meaningful comparative analysis of proposals).

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Mary G. Cuttle, Esq. February 20, 2007 Page I 0

Consistent with this prec~:lent, GAO must sustain Olympus' protest because thee is not adequate documentation in the record to support the SSA's det~nination that Rowe offc~xt than Olympus offered, and th~efore that Rowe rcpresent~xi'tho be~t value.

COMMENTS ON THE AGENCY REPORT ON OLYMPUS' FIRST SUPPLEMENTAL PROTEST This procurement for janitorial services at the DIA facility at Boiling AFB, Virginia began in the Spring of 2005, and has involved four successive contract awards and three agency corrective actions, Despite this tortured history, the only record before GAO in this case are the documents that pertain to the agency's decision to make a contract award worth approximatel~ $20 million to Rowe. This record was compiled by three technical evaluators and the Contracting Offieer/SSA, who perfoma~! the past performance evaloation and the pfic~ evaluation and made the source selection decision. As set forth in Olympus' First Supplemental Protest, this record contains multiple, material errors, in addition to the SSA's material error regarding the manpower evaluation, discussed above. Specifically, the record does not support the award to Rowe because: 1. 2. DIA ignored Rowe's failure to submit a complete, coherent and responsive offer; The SSA's past performance ratings of Olympus and Rowe were irrational and based

upon errors of fact; 3. The SSA's evaluation of price proposals was irrational because she did not consider

presented performance risk; and 4. The overall evaluation record in this case is insufficient to enable GAO to det~mine

whether the best value decision was reasonable.
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I.

Rowe Did Not Submit A Complete, Coherent And Responsive ]~inal Proposal. A. Neither The Agency Nor The Awardee Can Produce Rowe's Final Technical Proposal.

In its Supplemental Protest, Olympus noted the agency's identification of three weaknesses in Rowe's Technical Proposal during discussions. One of these weaknesses was the lack of a "security awareness plan?' AR, Tab 21, p: 1. The document Rowe submitted in its final revised propo.sal e~atitled "Security Awareness Plan" consisted of thr¢~ sentences on a quarter-page, followed by an indeterminate number of pages of generic material on terrorism and security printed from the Department of Defense website. In the Legal Memorandum supporting the Agency Report on Olympus' First Supplemental Protest, DIA quotes the Technical Evaluation Board's ("TEB") conclusion that Rowe offered a security plan, however, the TEB does not cite to any pages in Rowe's final revised proposal that comain this alleged security awareness plan. AR, Tab 26, p, 6. Moreover, agenoy counsel has not been able to identify Kowe's Se.urity Awareness Plan, or to agr~ with Rowe on the number of pages the "plan" includes. See, February 9, 2007 e-mail from LTC Frank March to GAO and the parties regarding missing pages from Row~'s final proposal: Despite the minor issue regarding the document in the AR that constitut~ Rowe's proposal, it is obvious that whatever the TEB ~valuated satisfied them to the extent that they rated Rowe as Excellent. AR, Tab 38, p. 3 (~nphasis added). The agency's extremely cavalier attitude towards whether agency evaluators had a complete copy of Rowe's final techniea] proposal when they evaluated it, and whether "whatever the TEB evaluated" actually contained a Security Awareness Plan, makes a mockery of the agency's competitive procurement process. If the TEB thought tlmt Rowe's lack of

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a Security Awareness Plan was sufficiently important for them to identify this lack as a "weakness" in Rowe's proposal, the TEB and the SSA should make some effort to determine whether Rowe, in

fact, Rowe submitted a complete Security Awar~ess Plan in its final revised proposal, and to
reference it in the ttx:hnioal ~aluation and SSD. DIA has done n~ither. B. The TEB Did Not "Figure Out" How To Assemble Rowe's Final Proposal, And Consequently Gave Rowe A "Strength" For An Element Not In Rowe's Final Proposal,

Agency counsel interprets Olympus' ~laim that Rowe's final proposM w~ incomplete rind incoherent as suggesting that Olympus believes "the TEB and Contracting Officer were not smart enough to figure out how to insert the replacement pages imo Rowe's original proposal." Tab 3 8, p, 2, A close inspection of the TEB's evaluation report suggests that this was, in fact, the case. Based upon its understanding oft he proper insertion of the urmumbered, partially blank pages of Rowe's final proposal into its inititd proposa!, the TEB concl~lded that Rowe's technical proposal should be given a "strength" for its strong p,rsonnel/staf~mg plan: STRENGTHS Strong persormeVstaffing plan and a retention plan with compensation bonuses. Already has exceeded the 20% cleo~red pgrsonnel requirement AR, Tab 26, p. 15 (emphasis added). However, unnumbered page 17 of Row¢'s final technical proposal contains a list of only . Moreover, unlike in Rowe's initial names appe~cd

proposal, the replacement page has a blank space in the place where the

in Rowe's original proposal, suggesting that, at the time of Rowe's final proposal, the originallynamed workers may no }onger have been available.

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Therefore, the TEB identified as a "strength" an asp~t of Rowe's technical proposal that .was not in the final version because it apparently did not "figure out how to insert the replacement pages into Rowe's original proposal." Accordingly, the TEB improperly gave Rowe a "strength" for an element in its proposal that, like the Emperor's Clothes in the ol~sio children's tale, simply w~ not there. C,
The SSA Did Not Make An Independent Determination That Rowe~s Final Technical Proposal Was Complete,

Federal Acquisition Regulation (FAR) 15,308 provides that ths SSA "may use reports and
maalyses prepared by others" in making a contract award, however '~he source selection decision shall represent the SSA's independent judgment." In this case, th~ SSA did not follow this mandat~ and use hm- independent judgment to even determine whether Rows had submitted a complete final proposal, lnstrad of reviewing Rowe's final proposal herself, she relied on the TEB to tell h~ that Rowe's final proposal was complete: Rowe submitted their final proposal in accordance Gith the discussion letter dated 08 Nov 2005..The final t~roposal was r.eviewed _by the Technical Evaluators who found that the progos_a~ add_rgssed all issues. Therefore, ~s the Source Selection.A. uthofity,_[, determine that Row~'s final proposal w~ comdete, coherrn.t and res~pnsive. AR, Tab 39, p. 1 (emphasis added). The SSA oannot d~ttz-mine that Rowe's final proposal was "eompIete, coherent and responsive" based upon the Technical Evaluators conclusion to that effect. The SSA has to make her own independent judgment that Rowe's proposal was "complete, coherent and responsive." The SSA's failure to use her own independent judgment to determine that Rowe's final proposal was complete, coherent and responsive, should cause GAO to sustain Olympus' protest on this ground alone. See University Research Co. LLC., B-294,358, B-294358.2-.5, 2004 CPD ¶ 217 ("FAR 15.308 requires documentation of som'ce selection decisions, and recognizes that
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decision reflects the selection officials' independent judgment.").

Mary G, Curcio, Esq. February 20, 200~ Page 14

while the selection official may rely or~ reports and analyses prepared by oth~'s, the ultimate

In sum, the SSA cannot establish that Rowe's final proposal was complete, coher~t and r~sponsive, because she relied on the TEB for this information, and the TEB apparently did not "figure out" how to prop~ly insert the tmnumb~ed pages of Rowe's final proposal into its initial proposal;as evidenced by its giving Rowe a "strength" for an element that was not included in Rowe's final proposal, IL The Agency's Past Performance Evaluation Of Olympus Was Irrational, Unreasonable And Prejudicial. A. The SSA Mistakenly Concluded That A Government Agency Had Issued A Cure Notice To Olympus.

Olympus has consistently stated that the agency unfairly evaluated its past performance record, by downgrading its overall past p~"ormance rating from the "Excellent" the agency had giv~'a Olympus in its 2005 pa~t p~forman~e ," which Olympus received in the

agency's 2006 evaluation Of this same Olympus past performance rccord. In 2006, the SSA, who performed the past pcTformance evaluation, unreasonably focused on the issuance of , t.o the exclusion of all other available information, in,luting an "Excellent" rating from the customer In response, the ag~ncy has contended that is a sufficiently

serious event to justify Olympus' lower past performance rating. It th~refor~ came as a consid~-able shock to read in paragraph 4 of the Contra~ting Officer's Statemunt issued in respons~ to Olympus' First Suppl~cntal Protest, that at this late date, the Contracting Officer/SSA mistakenly believes that to

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Olympus. The SSA's statement indicates that she considers this allegedly on Olympus' past performance record because "'

Mary G. Cur~io, Esq. February 20, 2007 Page 15

." AR, Tab 39, pg. 2 (emphasis added). This statement suggests that the SSA who evaluated off~rors past performance, was wholly ~mfamiliar with Olympus' past performance record when she performed the post performance evaluation. If she had read andund~r~tood Olympus' past perfolmance questionnaires, she would have known that a did not last "a long time," Olympus promptly developed a plan for resolving the underlying issue, and had the problem completely re.solved within 30 days ce, $¢0, AP,, Tab 29,

The Contracting Officer's most recent Statement only supports Olympus' contention that the agency failed to r~asonably and accmatdy consider all of Olympus' past performance information during the 2006 evaluation leading up to the award to Rowe. In light of the closeness of this competition, and the numerous other defects in the agency's evaluation of proposals that Olympus has identified, the SSA's obvious misunderstanding of Olympus' the facts contained in Olympus' past performane, record materially affected the award decision. B. The SSA~s Past Performance Rating Of Olympus Was Based Upon Her Mistaken Conclusion Did Not Give Proper Weight To Olympus' Exclusively ~Excellent" and "Outstanding" Past Performance Ratings.

In its First SupplementM Protest, Olympus argued that the SSA ignored the exclusively "Excellent" and "Outstanding" ratings Olympus received in the past performance questionnaire responses, while ignoring the several "Fair" and "'Good" ratings that Rowe received from one of its past performance references. Most important, the SSA ignored the fact that Olympus received
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