Bhate Environmental Associates, Inc. (B-422557.2; B-422557.3)

You should not care.

Category: Technical evaluation, OCI, best value tradeoff

Date: 3 January 2025

URL: https://www.gao.gov/products/b-422557.2%2Cb-422557.3

Bhate Environmental Associates protested the Interior’s award of a task order to Trinity Analysis and Development Corp. under a GSA Schedule RFQ for environmental services at three Air Force installations in Florida. Bhate alleged that the agency unreasonably evaluated technical and past performance factors, failed to address an alleged conflict of interest, and conducted a flawed best-value tradeoff.

GAO found the agency reasonably evaluated Bhate’s proposal under the technical approach, work control, and quality control subfactors, noting that the weaknesses assigned to Bhate were well-documented. Similarly, GAO upheld the agency’s past performance evaluation of Trinity’s proposal, rejecting claims of disparate treatment and improper credit for teaming partners. Regarding the conflict of interest allegation, GAO determined the agency reasonably investigated and found no impropriety in the compliance chief’s relationship with Trinity’s project manager. Lastly, GAO found no error in the best-value tradeoff decision, emphasizing that Trinity’s higher technical ratings justified the price premium.

GAO denied the protest, concluding that Bhate failed to show any errors in the agency’s evaluation or decision-making process.

Digest

1. Protest challenging the agency’s evaluation of quotations is denied where the evaluation was reasonable and in accordance with the terms of the solicitation.
2. Protest alleging that the agency failed to adequately address a purported conflict of interest is denied where the agency meaningfully considered the allegation and reasonably concluded that no conflict of interest existed.
3. Protest that the agency failed to conduct a proper best-value tradeoff analysis is denied where protester fails to demonstrate that the tradeoff was unreasonable.