___________________________________________________________
 
                       DENIED:   October 9, 1992
      ___________________________________________________________
 
                             GSBCA 11963-P
 
                  MCI TELECOMMUNICATIONS CORPORATION,
 
                                           Protester,
 
                                   v.
 
                    GENERAL SERVICES ADMINISTRATION,
 
                                           Respondent,
 
                                  and
 
                       AT&T COMMUNICATIONS, INC.,
 
                                           Intervenor.
 
        Robert  H.  Koehler,  Mary  Beth  Bosco,  Judith   Bartnoff,
   Michael J. Schaengold,  Curtis V. Gomez,  and James L.  Lester of
   Patton, Boggs &  Blow, Washington, DC, and Robin  L. Redfield and
   Linda  P.  Armstrong   of  MCI  Telecommunications   Corporation,
   Washington, DC, counsel for Protester.
 
        George  N. Barclay,  Michael J.  Ettner,  Seth P.  Binstock,
   Pamela  Reiner,  and  Kurt Summers,  Office  of  General Counsel,
   General  Services  Administration,  Washington, DC,  counsel  for
   Respondent.
 
        C.  Stanley Dees, Thomas  C. Papson, Daniel  E. Johnson, and
   Paul E.  Pompeo of  McKenna & Cuneo,  Washington, DC;  Michael R.
   Greene,   Jonathan  S.   Hoak  and   G. Ridgley   Loux  of   AT&T
   Communications, Inc.,  Silver Spring, MD;  and David S.  Cohen of
   Cohen and White, Washington, DC, counsel for Intervenor.
 
   Before Board Judges HENDLEY, PARKER, and HYATT.
 
   PARKER, Board Judge.
 
        In   this   protest,  MCI   Telecommunications   Corporation
   challenges the General Services Administration's (GSA's) decision
   to procure "dedicated multipoint service" by modifying a GSA ten-
   year comprehensive FTS2000 contract.  AT&T  Communications, Inc.,
   the other party to the contract, has intervened in the protest in
   support of  GSA.   MCI,  which is  a prospective  offeror of  the
   multipoint service,  maintains that the contract  modification is
   improper because it is outside the scope of the FTS2000 contract.
   Thus, according to MCI, if GSA is to obtain the services, it must
   do so by conducting a competitive procurement.
 
 
        For the reasons  discussed below, we hold  that the contract
   modification  was  proper; GSA's  contracting  officer reasonably
   determined that the services in question were within the scope of
   the FTS2000 contract.  Accordingly, we deny the protest.
 
                            Findings of Fact
 
   Contract Provisions
 
        1.   In   December   1988,    GSA   awarded   two   ten-year
   telecommunications contracts known  as FTS2000.  The  "Network A"
   contract  was  awarded  to  AT&T  as  a  fixed-price,  indefinite
   quantity contract with  an estimated value of $1.3  billion and a
   maximum dollar limitation  of $15 billion.   Intervenor's Exhibit
   11.  U.S. Sprint Communications  Company was awarded the "Network
   B" contract, with a maximum dollar limitation of $10 billion.
 
        2.   The solicitation  described the  contract generally  as
   follows:
 
                  This  contract   is  for   telecommunications
             services  for the  FTS2000 program.   The  FTS2000
             program  will   replace  the   existing  intercity
             switched voice  Federal Telecommunications  System
             (FTS)   and   provide  additional   and   enhanced
             telecommunications  capabilities  to  the  Federal
             Government.  The FTS2000 program will be mandatory
             for all federal agency activities subject  to P.L.
             89-306, as implemented by  the Federal Information
             Resources Management Regulations (FIRMR).
 
   Protest File,  Exhibit 1 at  C-15.  The solicitation  also stated
   that:
 
             The FTS2000 procurement  is designed to  meet
             the following government objectives:
 
             a.   To   obtain  a   comprehensive  set   of
             telecommunication services.
 
             b.   To  obtain  telecommunications  services
             through   two   prime   service   contractors
             responsible  for providing  all services  and
             network management.
 
                  . . . .
 
             e.   To  adopt  an   architecture  that  will
             provide a smooth  transition to an Integrated
             Services Digital  Network (ISDN)  environment
             when it becomes economically attractive.
 
             f.   To encourage competition between the two
             FTS2000 services  contractors as  a means  of
             ensuring  continued  improvements  in FTS2000
             services and prices.[foot #] 1
 
   Id. at C-15-1 through C-16.
 
        3.   Section C of  the contract went on to  describe the six
   telecommunication services intended to be procured:
 
             C.1.3.1   Telecommunications Services.  T h e
             government intends  to procure  the following
             six  telecommunications  services:   switched
             voice   service,   switched   data   service,
             switched digital  integrated service,  packet
             switched service, video transmission service,
             and  dedicated  transmission service.    This
             solicitation  describes  these  services,  as
             well as specific  features of these  services
             that the government is likely to procure.  It
             is   the  government's   intent  that   these
             services conform as closely  as possible with
             those offered commercially.
 
   Protest File, Exhibit 1 at C-16.
 
        4.   Section C.2.1 described  the services in a  little more
   detail:
 
                  This      section       defines      the
             telecommunications services and features that
             comprise FTS2000.   Included in  this section
             are the specifications  of these services and
             their features,  as well  as descriptions  of
             the  interfaces  to   FTS2000  and  equipment
             associated with these interfaces.
 
 
                                                                    
                   ----------- FOOTNOTE BEGINS ---------
 
        [foot #] 1 Clause H-14  of  the  contract  requires  GSA  to
   conduct  a recompetition between  the two winning  vendors in the
   fourth and  seventh years of  the contract.  Thus,  although AT&T
   now holds the Network A contract (sixty percent of the total), it
   will  compete with  U.S. Sprint  in  those years  for the  lion's
   share.
 
                   ----------- FOOTNOTE ENDS -----------
 
 
 
                       C.2.1.1   Services.  The contractor
             shall provide the following services:
 
                       a.   Switched voice service for the
                            transmission of voice  or data
                            for   data   speeds   to   4.8
                            kilobits per second (kbps)
 
                       b.   Switched data service  for the
                            transmission  of  data   in  a
                            digital format at  56 kbps and
                            64 kbps
 
                       c.   Switched   digital  integrated
                            service   for    the   digital
                            transmission  of voice,  data,
                            image,     and     video    at
                            transmission  rates  of  up to
                            1.544   megabits  per   second
                            (Mbps)
 
                       c.   Packet  switched  service  for
                            the  transmission  of  data in
                            packet form
 
                       e.   Video transmission service for
                            the   transmission   of   both
                            compressed and wideband video
 
                       f.   Dedicated transmission service
                            for the point-to-point private
                            line transmission of voice and
                            data
 
   Protest File, Exhibit 1 at C-19.
 
        5.   This  protest   concerns  the   dedicated  transmission
   service portion of  the contract  which, again,  is described  in
   greater detail later on in the solicitation:
 
                  C.2.7     Dedicated Transmission Service
 
                       Dedicated    transmission   service
             includes analog, digital, and T1 transmission
             service, as described below.
 
                       Dedicated    transmission   service
             between two  FTS2000 service  delivery points
             [SDPs]  whether  on the  same or  between two
             FTS2000 networks, shall be  provided from SDP
             to  SDP by the  FTS2000 contractor  from whom
             the service is ordered.
 
                       The    connection    between    the
             locations  receiving  this service  shall  be
             continuously established unless an authorized
             request for disconnect is received.
 
                       C.2.7.1   Analog.   The  contractor
             shall provide  dedicated analog  transmission
             for (i) voice and analog data at rates up  to
             4.8 kbps, and  (ii) voice and analog  data at
             9.6 kbps between two FTS2000 service delivery
             points.
 
                  . . . .
 
                       C.2.7.2   Digital.  The  contractor
             shall  provide  dedicated,  synchronous, full
             duplex,  totally  digital,  service  delivery
             point-to-service    delivery    point    data
             transmission    service    between    FTS2000
             locations.   The data transfer rates shall be
             9.6  kbps  and 56  kbps/64  kbps  (when clear
             channel capability is available).
 
   Protest File, Exhibit 1 at C-57.
 
        6.   The solicitation explained that  "[s]ervice and feature
   requirements are provided in this solicitation to enable offerors
   to prepare price and technical proposals, and to provide a common
   framework for proposal evaluations."  Protest  File, Exhibit 1 at
   C-20.  Offerors,  however, were encouraged, in  section L.37.4.4,
   to
 
             offer  additional  features   and  items  not
             identified in the price schedules provided in
             the RFP  [request for  proposals], but  which
             the offeror  normally supplies  to its  other
             customers.
 
   Id.  at L-62.   The  same section  required that  such additional
   features and  items be,  among other things,  "items that  can be
   included under the general scope of this solicitation."
 
        7.   Finally,  the   solicitation  contained   the  standard
   "Changes" clause  (section  I.52), and  a "Service  Improvements"
   clause  (section  H.16),  which   provided  mechanisms  by  which
   additional items  could be  added to the  contract.   Clause H-16
   stated in pertinent part:
 
             H.16  Service Improvements
 
                  a.  After contract award, the Government
             may solicit, and the Contractor is encouraged
             to propose independently, improvements to the
             services, features, or  other requirements of
 
             the  contract.    These improvements  may  be
             proposed   to   save    money,   to   improve
             performance, or  for any other  purpose which
             presents   a   service   advantage   to   the
             Government.  As part of the proposed changes,
             the Contractor shall submit a price  proposal
             to  the Contracting  Officer for  evaluation.
             Those proposed service  improvements that are
             acceptable   to   the  government   will   be
             processed as modifications to the contract.
 
                  . . . .
 
                  e.   If a proposal submitted pursuant to
             this clause is accepted  and applied to  this
             contract, the equitable adjustment increasing
             or decreasing the contract  price shall be in
             accordance   with  the   procedures  of   the
             "Changes"  clause.   The  resulting  contract
             modification  will  state  that  it  is  made
             pursuant to this clause.
 
   Protest File, Exhibit 1 at H-24 through H-24-1.
 
   Expectations of the Offerors as to Scope
 
        8.   The FTS2000 project was first described publicly by GSA
   at  a  "pre-bidders' conference,"  on  February  13, 1985.    GSA
   announced  that  FTS2000  would provide  agencies  with "one-stop
   shopping,  includ[ing] every  provision  of intercity  services,"
   with "continuous upgrades."   Intervenor's Exhibit 18; Transcript
   at 606-08.  These concepts  were reinforced by GSA throughout the
   three   and  one-half  years   leading  up  to   contract  award.
   Transcript at 504-05, 577-78, 608-09, 666.
 
        9.   Prior to award,  AT&T, Sprint and Martin  Marietta, the
   three  prime contractor offerors for FTS2000, understood that the
   successful  vendors  would  provide  virtually  all  commercially
   available  intercity  telecommunications  services  to  the  user
   agencies,  and that the  losing vendor would  be essentially shut
   out of that business.  Transcript at 577-78, 581-82, 607-09, 637,
   666.
 
        10.  Protester MCI, which teamed with Martin  Marietta, also
   shared this  view.  Transcript at  630-32.  On  October 30, 1987,
   MCI's   FTS2000  Team  Leader  wrote  to  another  MCI  executive
   following a GSA announcement regarding FTS2000:
 
             [H]ere's what GSA said:
 
                  1.   Single  procurement  for  ten years
             with two winners (60-40 split).  Loser is out
             of  (at  least  the  civilian  side  of)  the
             government business.
 
                  . . . .
 
                  4.   Each winning  vendor will  have the
             exclusive     right      to     sell      ALL
             telecommunications services  to the  agencies
             on  its network (i.e. such agencies cannot go
             outside FTS2000 to procure any service).
 
   Intervenor's Exhibit 20.
 
        11.  GSA  intended, and  the  offerors understood,  that the
   solicitation did not list every service which the winning vendors
   would  be expected  to provide  over  the life  of the  contract.
   Transcript at 494, 503-05, 537, 539-40, 579, 583-85, 609, 624-25,
   664,  667-68,  720-21.    The executive  summary  of  the  Martin
   Marietta/MCI proposal proclaimed:
 
             We have  organized these  partners .  . .  so
             that  long-term user needs . . . will dictate
             the  introduction  of  new  technologies  and
             service offerings.
 
   Protest File, Exhibit 2a at 2.
 
        12.  All  three offerors  proposed  additional features  and
   items  in   response  to  section  L.37.4.4.     See  Finding  6.
   Specifically,  all   three  offerors   expected  that   dedicated
   multipoint was  the type of  service that would  be added to  the
   FTS2000 contracts at some point.  Transcript at 589-90, 629, 679-
   80.  AT&T and Sprint offered multipoint capability  under section
   L.37.  Id.  at 592-93, 669-72;  Protest  File Supplement, Exhibit
   81;  Intervenor's Exhibit 3c.   Martin Marietta/MCI did not offer
   multipoint because it  did not have the capability  at that time.
   Transcript at 184.
 
        13.  GSA did not accept, reject  or even evaluate any of the
   additional features or items proposed by the offerors in response
   to section L.37.4.4.  GSA concluded that  it did not have time to
   evaluate the additional items, and informed the offerors  that it
   would  use the  responses to  L.37.4.4 only  as a  market survey.
   Transcript at 541-48,  675, 724-33.  GSA made no  decisions as to
   whether any of  the L.37.4.4 items were  within the scope of  the
   FTS2000 procurement, and did not intend to foreclose the addition
   of those items at a later date.  Id. at 544, 570-71, 675, 731-33.
 
   Modification No. PS100
 
        14.  In  June 1991, AT&T proposed to  add analog and digital
   dedicated   multipoint  transmission   service  to   the  FTS2000
   contract.  Protest File, Exhibit 11.  This was the same item that
   AT&T had proposed in response to section L.37.4.4 of the original
   solicitation.   Transcript  at 672.    GSA determined  that  "DTS
   [dedicated  transmission   service]  Multipoint   is  a   feature
   enhancement to  the DTS  service under  the  contract," and  was,
   therefore, within  the scope  of the  FTS2000 contract.   Protest
   File, Exhibit 13.   On July  6, 1992, AT&T  and GSA executed  the
   modification.  Id., Exhibit 15.
 
 
        15.  The pricing of  the dedicated multipoint uses, with one
   exception, the same  pricing elements, and the  same prices, used
   for the existing  FTS2000 dedicated analog and  digital point-to-
   point   services.[foot #] 2       There    is   one    additional
   charge -- a ten dollar  monthly "bridging" charge for each analog
   multipoint circuit.   There is  no additional charge  for digital
   multipoint.  Transcript at 380.
 
        16.  GSA  estimated the  incremental cost of  the multipoint
   capability over the  cost of the existing FTS2000  services to be
   approximately  $16.8  million  for  the  remaining  term  of  the
   contract.    Protest File,  Exhibit  15  at  5.   An  independent
   government  estimate estimated the  total cost of  all multipoint
   circuits which  may be added  to the contract over  its remaining
   term to  be $349  million; at trial,  however, that  estimate was
   shown to  contain several  faulty assumptions  and other  errors.
   Transcript  at 267-78.   The  current  value of  the contract  is
   between $5 billion and $8 billion.
 
   What is Multipoint and How Does it Relate to the Contract?
 
        17.  Telecommunications services  generally are  categorized
   as broadcast,  mobile, or fixed.   Transcript at  27; Protester's
   Exhibit  41.     Fixed  telecommunications   services  denote   a
   stationary  transmission medium  and are  further  categorized as
   "switched"  or "dedicated."   Dedicated transmission service (the
   type at issue in this protest), also called private line service,
   refers to the fact that the transmission capacity is reserved for
   the user and available at all  times to the user.  Transcript  at
   29.    In  other  words,  with  switched service  (i.e.,  regular
   telephone service), the connection is made when you make the call
   and  changes, depending  on whom  you call.   Dedicated circuits,
   however, are always connected to the same party at the other end.
 
        18.  Existing dedicated  service under the  FTS2000 contract
   is  "point-to-point,"  which  means that  the  dedicated  circuit
   connects only  two points.   The  multipoint capability added  by
   Modification  No. PS100 uses existing FTS2000 elements to connect
   three or more locations together  on a single dedicated  circuit.
                                                                    
                   ----------- FOOTNOTE BEGINS ---------
 
        [foot #] 2 As  explained in  the  following section  of this
   opinion,  because a  multipoint circuit  connects  more than  two
   points,  a method  for  determining  the  shortest  (least  cost)
   network  transport charge is necessary.  The formula or algorithm
   used for  this purpose is  the same one  used for the  compressed
   video transmission  portion of  the FTS2000  contract, which  has
   included multipoint capability from the beginning.  Protest File,
   Exhibit 1 at C-53, C-56; Transcript at 300-05, 380-82.
 
                   ----------- FOOTNOTE ENDS -----------
 
 
   Indeed, a multipoint circuit is essentially built from "point-to-
   point"  links  bridged  together to  form  a  multipoint circuit.
   Transcript at 127, 404.  The analog links are bridged together by
   a  Digital Multipoint Bridge,  and the digital  links are bridged
   together by a  Multipoint Junction Unit.   Id. at  333.  Both  of
   these devices  are small  circuit packs which  have been  part of
   AT&T's network from the beginning, although they  are not "turned
   on" for FTS2000's current point-to-point service.  Id. at 333-35.
 
 
        19.  Multipoint   service   does   not   involve   any   new
   transmission  rates.     Transcript   at  329.     The   testing,
   maintenance,  digital clocking,  performance objectives,  service
   intervals and service interfaces for a multipoint circuit are the
   same as those for a point-to-point circuit.   Id. at 357-61.  The
   delivery  schedule is  the  same.   Id.    From the  contractor's
   perspective, the only difference between a multipoint circuit and
   a  point-to-point circuit  is that the  former uses  the existing
   bridging capability to connect more than two locations, while the
   latter  connects only  two  points without  use  of the  bridging
   capability.  Id. at 118-20, 403-04.
 
        20.   Each  "bridge"  on  a  multipoint  circuit  is  easily
   programmed to  permit  one  of the  three  user  applications  of
   multipoint:    broadcast,  broadcast  polling,  or  conferencing.
   Transcript  at  345-47.    A  user  could accomplish  these  same
   applications  with a  number of  point-to-point circuits  already
   available under FTS2000.  Id. at 153-54, 408-09.
 
        21.  Although an  agency customer  could, as  a cost  saving
   measure,  replace  a  number of  point-to-point  circuits  with a
   smaller  number of  multipoint circuits,  the  Government has  no
   plans  to do so at  this time.   Instead, GSA intends  to bring a
   number  of existing  multipoint circuits,  which were  separately
   competed  outside  of   FTS2000,  under  the   FTS2000  umbrella.
   Transcript at 352.  GSA made a business decision to aggregate the
   multipoint services with other FTS2000 services to take advantage
   of  volume discounts  and to  simplify  maintenance, billing  and
   related items.   Id.  at  264, 374-75,  386-87, 783.   Any  long-
   distance  carrier is capable of providing the multipoint circuits
   to the Government in essentially  the same manner as AT&T intends
   to provide  them.  The  carrier would  simply pick up  the signal
   from  the local  carrier; the  long  distance multipoint  service
   would still  be transparent  to the user  and the  AT&T point-to-
   point  circuits would  not be  deleted or  disrupted in  any way.
   Transcript  at 132,  138, 315, 362-63.   GSA has  not studied the
   comparative  costs  of  competing  the  multipoint  circuits  and
   placing them under the FTS2000 contract.
 
        22.  The Board heard expert testimony to the effect that the
   addition  of multipoint  is a  new  FTS2000 service,  as well  as
   testimony  that multipoint  is a  feature or  enhancement of  the
   existing dedicated  transmission service.   This  "battle of  the
   experts" has  succeeded in  convincing us only  that there  is no
   general agreement in  the telecommunications industry as  to what
   constitutes  a   "service,"  as   opposed  to   a  "feature"   or
   "enhancement" to a service.   It seems that  a telecommunications
   service, like beauty itself, is in  the eye of the beholder.   We
   do  point  out,  however,  that  when  MCI  first  announced  the
   availability  of its  digital multipoint  "service"  in 1990,  it
   described the service as "an enhancement to MCI's existing point-
   to-point" dedicated service.   Protest  File Supplement,  Exhibit
   70.  MCI's  government tariff likewise  presents multipoint as  a
   subcategory of one of MCI's "point-to-point"  dedicated services.
   Transcript at  213-14.  AT&T  and Sprint tariff  their multipoint
   capabilities the same way.  Id. at 249, 252.
 
 
                               Discussion
 
        MCI maintains that GSA unlawfully added dedicated multipoint
   service to the  FTS2000 contract because dedicated  multipoint is
   "a separate  and independent telecommunications service"  that is
   beyond  the  scope of  the  contract.    As discussed  below,  we
   disagree.
 
   Analytical Framework Under the Changes Clause
 
        The  standard Changes clause  incorporated in AT&T's FTS2000
   contract authorizes  the contracting officer to  order additional
   work "within the  general scope of [the] contract."   In protests
   challenging  a   contract  modification,  this  Board,   and  the
   Comptroller  General,  have   monitored  the  integrity   of  the
   competitive procurement process by assessing the nature and scope
   of the  original competition.   The  Comptroller General's  often
   quoted Memorex test  -- whether a modification  "so substantially
   changes the purpose or nature of a contract that the contract for
   which the  competition was held  and the contract which  is to be
   performed are essentially  different" -- is a means  to that end.
   Memorex,    61    Comp.     Gen.    42    (1981),     81-2    CPD
     334.[foot #] 3
 
        In  Wiltel, Inc. v.  General Services  Administration, GSBCA
   11857-P, 1992 BPD   201 (Aug.  4, 1992), appeal docketed, No. 92-
   1474 (Fed. Cir.  Aug. 18, 1992), a recent case in which the Board
   found a telecommunications service called "T-3" to be outside the
   scope of this same contract,  we cited four basic factors (again,
   originally  identified by the  Comptroller General) that  we will
   consider when  evaluating whether  the proposed modification  was
   within the scope of the contract.  All the parties to the instant
   case  agree  that  the  four  factors are  relevant  to  a  scope
   determination here.  The factors are: the degree of change in the
   (1) pricing of the service; (2)  the schedule for delivery of the
                                                                    
                   ----------- FOOTNOTE BEGINS ---------
 
        [foot #] 3 Although rulings by  the Comptroller General  are
   not  binding   on   this  Board,   they  nonetheless   constitute
   "persuasive authority."  Laser Digital, Inc., GSBCA 10810-P, 91-1
                            ___________________
   BCA   23,499, 1990 BPD   373.
 
                   ----------- FOOTNOTE ENDS -----------
 
 
   service; (3)  the type  of service the  contractor would  need to
   perform;  and  (4)  whether,  during  the competition,  potential
   offerors reasonably  would have expected  the changed work  to be
   within the scope of the contract, including its "Changes clause."
   Wiltel, slip op. at 14.  We apply those same factors here.
 
   Change in the Pricing of the Service
 
 
        As explained  in our  findings of  fact, existing  dedicated
   service  under the  FTS2000 contract  is "point-to-point,"  which
   means that the  dedicated circuit  connects only  two points,  or
   users.  The multipoint capability added by Modification No. PS100
   uses existing FTS2000 elements to connect three or more locations
   on  a  single   dedicated  circuit.    This  is  accomplished  by
   "bridging"  several point-to-point  circuits together  to  form a
   multipoint circuit.  Finding 18.
 
        The pricing of the proposed dedicated multipoint  capability
   uses, with one exception, the same pricing elements, and the same
   prices,  used for  the  existing  FTS2000  dedicated  analog  and
   digital  point-to-point services.    Finding 15.    There is  one
   additional  charge  --  a  relatively  insignificant  ten  dollar
   monthly "bridging"  charge  for each  analog multipoint  circuit.
   There is no additional charge for digital multipoint.  Id.
 
        The above does  not necessarily mean that  adding multipoint
   capability to  the FTS2000  contract will  be  inexpensive.   The
   multipoint circuits  intended to  be purchased  will not  replace
   existing point-to-point circuits, although they could be used for
   that purpose.   Finding 21.  The new multipoint  circuits will be
   additional  circuits, albeit  priced  on  substantially the  same
   basis as  the existing  point-to-point service.   The pricing  is
   virtually identical  because the multipoint  circuits essentially
   are several point-to-point circuits bridged together.
 
        The cost of these new  circuits is estimated to be somewhere
   between  $16.8 million  and  $349  million,  depending  on  which
   estimate  one  chooses to  believe.   There  seems  little doubt,
   however, that the latter estimate is substantially inflated.  See
   Finding  16.   The current  value of  the contract is  between $5
   billion and $8 billion.  Id.
 
        Taken  as a  whole,  we view  the  degree of  change in  the
   pricing as supporting  GSA's in-scope determination.   Unlike the
   situation  in  Wiltel,  the prices,  with  the  exception  of the
   bridging charge, were obtained competitively through the original
   FTS2000  procurement; the  tables are  already  in the  contract.
   Although the Government  will be purchasing  additional circuits,
   we view  the change in pricing to be  of an incremental nature --
   certainly more so than was the case in Wiltel.  Finally, although
   significant,  the dollar  value  added  by  the  modification  is
   modest, considering  the size of  the FTS2000 contract.   See MCI
   Telecommunications Corp., GSBCA 10450-P, 90-2 BCA   22,735,  1990
   BPD   55.  "Pricing" goes in the "in-scope" column.
   Change in the Schedule for Delivery of the Service
 
 
        The delivery schedule for the multipoint service -- that is,
   the  amount of  time in  which the  contractor must  initiate the
   service after an order  is placed -- is the same  as the schedule
   for the  existing point-to-point service;  it was already  in the
   contract.  Finding 19.  On the other hand, as each new circuit is
   ordered,  whether it be  point-to-point or multipoint,  one could
   say that  a new  delivery "schedule" is  established.   Again, on
   balance,  we  think that  the  change  in the  delivery  schedule
   analysis supports the in-scope determination.  Because FTS2000 is
   an indefinite  quantity, indefinite  delivery contract  (i.e, the
   contract  contains no  fixed date  for  delivery of  a particular
   circuit until it is ordered), we think that GSA was reasonable in
   looking at the  change in delivery schedule as  a negligible one.
   AT&T  is  obligated  to provide  ordered  multipoint  services in
   exactly the same  timeframe as it is obligated  to provide point-
   to-point services.
 
   Change in the Type of Service Which the Contractor Will Perform
 
        We view this factor as being key in the in-scope versus out-
   of-scope analysis.  Once again, although there are two valid ways
   of looking  at the  multipoint capability, we  hold that  GSA was
   reasonable in determining that multipoint is, in  essence, a form
   of the existing FTS2000 dedicated transmission service.
 
        The FTS2000 contract,  like the telecommunications industry,
   uses the  term "service"  rather loosely.   See Finding 22.   The
   contract, in  section C.1.3.1,  lists six  "services":   switched
   voice, switched  data, switched  digital, packet  switched, video
   transmission, and dedicated transmission.  Finding 3.  All of the
   parties   agree  that  multipoint   is  one  type   of  dedicated
   transmission service.
 
        MCI relies  primarily on sections  C.2.1 and C.2.7  to argue
   that multipoint is a "separate and independent telecommunications
   service," outside the  scope of  the FTS2000  contract.   Section
   C.2.1 provides that  "the contractor shall provide  the following
   services: . . .   [d]edicated transmission service for the point-
   to-point  private line transmission of  voice and data."  Finding
   4.  Section  C.2.7 states that "[d]edicated  transmission service
   includes  analog,   digital,  and  T1  transmission  service,  as
   described  below."   The  section  then  goes  on to  state  that
   "[d]edicated  transmission service  between  two FTS2000  service
   delivery points . . . shall be provided  from SDP to SDP . . . ."
   Finding 5.  MCI reads these sections as defining the scope of the
   dedicated  transmission  service  and,  thus,  the  contract,  as
   "point-to-point."
 
        We think  MCI reads the  contract too narrowly.   Certainly,
   multipoint capability is not required under the current contract;
   if it were, there  would be no need for a  contract modification.
   The  "general scope"  of  a contract,  however, is  a horse  of a
   somewhat different  color.  Reading  the contract as a  whole, we
   believe that multipoint capability, whether or  not one wishes to
   call  it a  "service," is  an enhancement  or improvement  to the
   dedicated    transmission    service    called   for    in    the
   contract.[foot #] 4      A  multipoint   circuit   uses  existing
   FTS2000 elements to connect three or more locations together on a
   single dedicated circuit.  It is essentially built from point-to-
   point links bridged together.   Finding 18.  Multipoint does not,
   as Wiltel's T-3 did, involve new transmission rates.  Finding 19.
   From  the contractor's perspective, the only difference between a
   multipoint  circuit  and  a point-to-point  circuit  is  that the
   former uses the existing bridging capability to connect more than
   two  locations, while the latter connects only two points without
   use of the bridging capability.  Id.
 
 
        GSA has established  that the change in the  type of service
   that the contractor will need  to perform is minimal.  Multipoint
   service, by everyone's definition,  is an improvement to (1)  the
   dedicated  transmission service called  for in the  contract, and
   (2) the analog and digital dedicated transmission services called
   for  in  the  contract.    Finally,  consistent  with  MCI's  own
   Government  tariff and its own descriptions of multipoint, it can
   reasonably  be viewed as  an improvement to  "dedicated point-to-
   point transmission service."  See Finding 22.
 
   Expectations of the Offerors
 
        The record in this case establishes beyond doubt that all of
   the  offerors for  the  FTS2000  contract,  and  the  Government,
   believed  that the successful vendors would provide virtually all
   commercially available  intercity telecommunications  services to
   the   user  agencies,  and  that   the  losing  vendor  would  be
   essentially  shut out  of that  business for  a ten-year  period.
   Finding  9.  The offerors structured their proposals accordingly.
   Findings 11-12.  MCI, which elected to team  with Martin Marietta
   for the competition,  shared that view.  Finding 10.  We need not
   decide for  purposes of this  protest whether all of  those grand
   expectations were  reasonable.  Significantly, though,  all three
   offerors have conceded that dedicated multipoint was the  type of
   service  that would  be  added  to the  contract  at some  point.
   Finding 12.  For reasons  discussed previously, we hold that this
   belief clearly was reasonable.
 
   Conclusion
 
        Throughout  these proceedings, MCI  has asked this  Board to
   weigh the many benefits of competition  against GSA's decision to
   add multipoint  services to the  existing FTS2000 contract.   But
                                                                    
                   ----------- FOOTNOTE BEGINS ---------
 
        [foot #] 4   In  Wiltel, we held that  the "services already
                         ______
   bargained for" in the FTS2000 contract were "analog, digital, and
   T-1 in the  Dedicated Transmission Services'  group."  Wiltel  at
   ___                                                    ______
   17.
 
                   ----------- FOOTNOTE ENDS -----------
 
 
   our role is not to  "second guess" the business decisions  of the
   Government;  this Board  is charged  with  determining whether  a
   challenged agency action  violated a statute, regulation,  or the
   conditions of any delegation of procurement authority.  40 U.S.C.
     759(f)  (1988).  After reviewing  the relevant factors, we hold
   that dedicated multipoint service was reasonably determined to be
   within the general scope of  the FTS2000 contract.   Accordingly,
   GSA's decision to modify the contract was permissible.
 
 
                                Decision
 
        The protest is DENIED.
 
                                      ______________________
                                      ROBERT W. PARKER
                                      Board Judge
   We concur:
   _______________________
   JAMES W. HENDLEY
   Board Judge
   ________________________
   CATHERINE B. HYATT
   Board Judge