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2022 U.S. Comp. Gen. LEXIS 95

2022 U.S. Comp. Gen. LEXIS 95

Comptroller General of the United States

May 11, 2022

B-420626

Opinion

DECISION

MartinFederal Consulting, LLC, of Huntsville, Alabama, protests the award of a contract to Altus Engineering, LLC, by the Department of the Army, Army Materiel Command, pursuant to request for proposals (RFP) No. W31P4Q-22-R-0042, 1 for the performance of analytical and testing services supporting the Army's oil analysis program. 2 Martin, the incumbent contractor, complains that award to Altus was improper because Altus lacks the requisite experience and intends to subcontract more than 50 percent of the contract requirements. Martin also asserts that the agency failed to properly consider an alleged organizational conflict of interest.

We dismiss the protest.

BACKGROUND

In July 2021, the agency issued the solicitation as a total small business set-aside, 3 seeking proposals to operate and maintain laboratories in designated locations throughout the world. RFP at 2. The solicitation provided for award on the basis of a best-value tradeoff between the following evaluation factors: technical, 4 staffing plan, and price. 5 

Of relevance here, the solicitation provided that "The offeror shall have a minimum of 5 years work experience providing lubricant analysis services." RFP at 50. The solicitation also provided that offerors could form teaming arrangements; stated that "[t]he offeror shall clearly describe its own capabilities and those specialized services or capabilities that will be provided by any subcontractor"; and added that the offeror "must demonstrate clearly that it can self-perform, or perform through its teaming or subcontractor arrangements." Id. at 49, 51.

Proposals were received from multiple offerors, including Martin and Altus. 6 Thereafter, the agency evaluated Martin's and Altus's proposals as follows:

Martin

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2022 U.S. Comp. Gen. LEXIS 95 *

Matter of: MartinFederal Consulting, LLC

CORE TERMS

protest, solicitation, subcontractor, speculation, asserts, offeror, fail to state, valid basis, subcontract, training, percent, teaming, conflicting interest, contract requirement, organizational, lubricant, proposals