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If someone has experience performing a complex task, we generally assume they have experience performing the components of that task. For instance, if someone can play Rachmaninoff’s Piano Concerto No. 2, we would assume that person can read music. But as this protest illustrates, an offeror cannot expect an agency to make that kind of assumption when evaluating proposals. If a solicitation seeks experience doing ten different tasks, you best mention all of them and not assume the agency will infer experience performing smaller tasks from your experience performing a larger, more complex task.

DCR Services & Construction, Inc., GAO -B-0420179.2, B-420179.3

Background

The Department of Interior issued an RFQ seeking contaminated cleanup servies. The RFQ anticipated establishment of multiple blanket purchase agreements (BPA). The agency received multiple quotations, including one from DCR Services & Construction. The agency did not establish a BPA with DCR, finding that it had a low-ranked, high-priced quotation. DCR protested.

Legal Analysis

DCR objected to a weakness it received under the experience for a lack of detail in demonstrating experience with cost tracking and cost recovery. DCR argued that it demonstrated experience with cost recovery and thus had necessarily demonstrated experience with cost tracking. GAO rejected the argument, reasoning that while DCR may have thought that cost tracking was implicit in cost recovery, it is a vendor’s responsibility to submit a well-written quotation that clearly demonstrates compliance with solicitation requirements.

DCR also complained about a weakness assessed to its technical approach with respect to CERCLA-related tasks. The agency found that DCR had not demonstrated sufficient CERCLA capabilities. DCR contended it had demonstrated experience with one the most complex components of CERCLA that necessarily included other CERCLA components. But GAO found to see how DCR’s quotation demonstrated experience beyond one CERCLA requirement. The quotation had not explained the company’s experience in 16 other CERCLA components.

DCR is represented by Lewis P/ Rhodes and Orest J. Jowyk of McMahon, Welch, and Learned, PLCC.  The agency is represented by Willaim B. Blake of the Department of the Interior. GAO attorneys Michael P. Grogan and Edward Golstein participated in the preparation of the decision.