Chugach Logistics and Facility Services JV, LLC (B-423690; B-423690.2)

You should not care.

Category: Technical evaluation, past performance, cost or price evaluation

Date: 20 November 2025

URL: https://www.gao.gov/products/b-423690,b-423690.2

Chugach Logistics and Facility Services JV, LLC (CLFS), an 8(a) mentor-protégé joint venture small business, protests the award of a contract to CCS King George 2 LLC under RFP No. N62473-24-R-3210, issued by the Navy's Naval Facilities Engineering Systems Command for base operations support at Naval Base Coronado, California. The RFP contemplated a fixed-price IDIQ contract awarded on a best value tradeoff basis. CLFS, rated outstanding on technical approach with substantial confidence in past performance, was priced at $107.2 million—30 percent above CCS KG's $82.4 million. CLFS challenged the corporate experience evaluation, the past performance evaluation, the agency's failure to conduct a price risk analysis under DFARS provision 252.204-7024, and the source selection decision.

Corporate experience—JV partner references: CLFS argued CCS KG's corporate experience references were performed by other joint ventures involving King George LLC, not by CCS KG or its members directly. GAO found the RFP permitted reliance on the prime contractor experience of JV members and that King George LLC self-performed the vast majority of the referenced work. GAO also rejected CLFS's disparate treatment argument, finding CLFS relied on a sister subsidiary—a defined corporate affiliate under the RFP—while CCS KG relied on its mentor partner's direct JV experience.

Past performance—wrong CPARS submitted: CLFS submitted the wrong CPARS report for one of its three references. The agency declined to evaluate that reference. GAO found the RFP placed the burden on offerors to submit correct CPARS and that the agency was not obligated to independently research the correct report.

Past performance—negative information on awardee: CLFS argued the agency should have considered a prior King George LLC contract at Naval Base Coronado that ended prematurely. GAO found the contract did not meet the RFP's relevancy thresholds—annual value was approximately $6.6 million against a $10 million minimum and covered only custodial work, not multidiscipline base operations support.

Price risk under DFARS 252.204-7024: The agency conceded it did not access SPRS risk assessments. GAO found no competitive prejudice because SPRS returned no records for the relevant product and service code. GAO also held that incorporation of DFARS 252.204-7024 does not by itself create a price realism obligation under FAR Part 15, distinguishing MicroTechnologies, LLC, B-423197.2, and SMS Data Products Group, B-423197.

Result: Denied. GAO deferred to the agency's evaluation across every ground. The DFARS 252.204-7024 holding is a useful data point in the developing line of cases on the interaction between SPRS price risk assessments and traditional price realism analysis.

Digest

1. Protests challenging the agency's evaluation of corporate experience and past performance are denied where the protester has not demonstrated that the agency's evaluation was unreasonable or inconsistent with the solicitation's terms.
2. Protests challenging the agency's price evaluation are denied where the protester cannot demonstrate unfair competitive prejudice resulting from analysis of price risk under Defense Federal Acquisition Regulation Supplement provision 252.204-7024, and the agency was not obligated to perform a price realism analysis as set forth in Federal Acquisition Regulation part 15 because the solicitation did not provide for such an analysis.