Comptroller General

United States Government Accountability Office

Washington, DC 20548 

of the United States

DOCUMENT FOR PUBLIC RELEASE 

The decision issued on the date below was subject to a

GAO Protective Order. This redacted version has been

approved for public release. 

Decision 

Matter of: HydroGeoLogic, Inc. 

File: B-311263; B-311263.2 

Date: May 27, 2008 

Holly A. Roth, Esq., and Amandeep S. Sidhu, Esq., McDermott Will & Emery, LLP, for 

the protester. 

Thomas C. Papson, Esq., and Matthew T. Crosby, Esq., McKenna Long & Aldridge 

LLP, for Innovative Technology Solutions, Inc., the intervenor. 

Jonathan S. Baker, Esq., Environmental Protection Agency, for the agency. 

Kenneth Kilgour, Esq., and Christine S. Melody, Esq., Office of General Counsel, 

GAO, participated in the preparation of the decision. 

DIGEST 

1. In a procurement for architecture-engineer (A-E) services, protest challenging the 

agency’s decision not to select the protester as the highest-ranked firm with which to 

negotiate is denied where the record shows that the agency reasonably relied on key 

discriminators to select the highest-ranked firm. 

2. In a procurement for A-E services, protest that the agency conducted inadequate 

discussions by failing to properly advise the protester on weaknesses in its

submission is denied where the questions posed by the agency concerned the 

offeror’s concepts and methods, consistent with the Federal Acquisition Regulation 

(FAR) provisions applicable to A-E procurements; FAR provision regarding content

of discussions in negotiated procurements does not apply to A-E procurements. 

DECISION 

HydroGeoLogic, Inc. (HGL) protests the failure of the Environmental Protection 

Agency (EPA) to select it as the highest-ranked firm, with whom the EPA would then

negotiate an architect-engineer (A-E) contract for professional services to support

remedial planning and oversight activities in EPA’s Region 9. HGL alleges that the 

agency’s evaluation of its submission under certain factors was unreasonable; the 

agency failed to conduct adequate discussions and unreasonably evaluated the firm’s 

submission based on the discussions that it did hold; and the most highly-ranked 

firm was ineligible for award because information contained in its submission 

indicated that it is incapable of complying with the subcontracting limitation. 
We deny the protest.

BACKGROUND 

This procurement of A-E services is being conducted pursuant to the procedures set

forth in the Brooks Act, 40 U.S.C. §§ 1101, 1104 (2002), and its implementing 

regulations, Federal Acquisition Regulation (FAR) subpart 36.6. In accordance with

those regulations, on May 16, 2007, the EPA synopsized the requirement. The 

procurement envisioned the award of two “response action contracts” (RAC), one 

under full and open competition and one as a small business set-aside (RAC II); the 

subject of this protest is the RAC II contract, which is to be awarded under 

solicitation No. PR-R9-07-10112. To be considered for negotiations with the agency, 

firms were invited to submit a completed standard form (SF) 330 (A-E 

Qualifications) detailing their qualifications to provide various A-E services, 

including site management; remedial investigation feasibility studies; engineering 

services to design remedial actions; engineering evaluation and cost analysis for 

one-time critical removal actions; construction management for implementing 

remedial actions and one-time critical removal actions; enforcement support; and 

other technical assistance. 

Firms were advised that their qualifications would be evaluated under six factors, 

listed in descending order of importance, two of which had subfactors:

• Factor 1: Specialized Experience and Technical Competence 

• Sub-Factor 1: Fund-Lead Site Specific Work Areas

• Sub-Factor 2: Enforcement Support Site Specific Work Areas

• Sub-Factor 3: Other Technical Assistance Site Specific Work

 Areas 

• Factor 2: Past Performance 

• Factor 3: Knowledge of, and Experience with, Environmental 

Regulations 

• Factor 4: Professional Qualifications

• Sub-Factor 1: Management Personnel 

• Sub-Factor 2: Technical Personnel 

• Factor 5: Location in the General Geographical Area and Ability to

Maintain Appropriate Office and Staff Presence in Region IX 

• Factor 6: Capacity to Accomplish the Work in the Required Time 

Page 2 B-311263, B-311263.2 
Solicitation at 3-6. Thirty-two work areas--the tasks that would need to be 

accomplished to complete the statement of work--were listed under the three 

subfactors in factor 1. 

Firms were advised that “[a]t least fifty (50) percent of the cost of contract 

performance incurred for personnel shall be expended for employees of the prime 

contractor.” Id. at 2. Firms were instructed that, after an initial evaluation by the 

agency’s architectural and engineering evaluation board (AEEB), a short list of firms

would be invited to participate in oral presentations, and that each firm’s subsequent 

evaluation would depend on both its written submission and oral presentation. 

Following that second AEEB evaluation, the AEEB would rank the firms, the source 

selection official (SSO) would make the final ranking, and the contracting officer 

would then begin negotiations with the highest-ranked firm. 

Eight firms, including HGL and Innovative Technical Solutions, Inc. (ITSI), submitted 

their qualifications for evaluation. In its initial evaluation, the AEEB reviewed each 

firm’s submission, chose the three highest-ranked firms, HGL, ITSI, and Offeror C, 

and invited those three firms to make oral presentations. The firms were advised to

limit their oral presentations to approximately 15 minutes, allowing an additional 70 

minutes to respond to questions from the board, which the offerors would receive 1 

hour prior to their presentations. Firms were advised that the oral presentation team

must include the program, contract, and financial managers and no more than seven 

other people. 

At the conclusion of its second review, which included a consideration of the oral 

presentations, the AEEB rated the three firms--in order of rank, ITSI, Offeror C, and 

HGL--as follows: 

Offeror Factor 1

Specialized

Experience 

Factor 2 

Past 

Performance

Factor 3 

Regulation

Knowledge

Factor 4 

Professional 

Qualifications 

Factor 5 

Location 

Factor 6 

Capacity 

ITSI Excellent Excellent Excellent Excellent Excellent Excellent

C Excellent Good Excellent Excellent Excellent Excellent

HGL Excellent Excellent Excellent Excellent Excellent Good

 

Each of these firms received an overall rating of “excellent.” After a review of the 

AEEB’s evaluation, the SSO ranked the firms as follows: ITSI; HGL; and Offeror C. 

While noting that ITSI and HGL were the “two strongest offerors,” the ranking

analysis stated that “HGL’s overall proposal was slightly weaker than ITSI’s 

proposal.” Agency Report (AR), Tab 12, Ranking Determination, at 20. The SSO 

based her decision principally on the ground that the protester’s submission was

unclear as to how HGL would adequately staff the contract, as reflected in its 

Page 3 B-311263, B-311263.2 
evaluation under factor 6 (Capacity), and noted concerns about the quality of the 

protester’s oral presentation. 

By letter dated February 5, 2008, the agency notified the protester that it was not the 

top ranked offeror. On February 6, the protester requested a debriefing, which was

held on February 14. This protest followed. 

DISCUSSION 

HGL challenges the AEEB’s decision on numerous grounds. In reviewing an 

agency’s selection of a contractor for A-E services, our function is not to make our 

own determination of the relative merits of the submissions, or to substitute our 

judgment for that of the procuring agency by conducting an independent 

examination. Foundation Eng’g Sci., Inc., B-292834.2, Dec. 12, 2003, 2003 CPD ¶ 229 

at 3. Rather, our review is limited to examining whether the agency’s selection was 

reasonable and consistent with the evaluation factors and applicable procurement 

statutes and regulations. Id. A protester’s mere disagreement with the agency’s 

evaluation does not make it unreasonable or improper. See CH2M Hill, Ltd., 

B-259511 et al., Apr. 6, 1995, 95-1 CPD ¶ 203 at 4. Here, we have considered all of 

HGL’s arguments and find that none has merit.

1

 Our decision addresses HGL’s most

significant arguments, beginning with the role of the ranking discriminators. 

Evaluation under Factor 6--Capacity 

As noted above, HGL and ITSI received the same rating (excellent) under the first 

five evaluation factors; under factor 6--Capacity, HGL received a rating of good, 

while ITSI received a rating of excellent. HGL’s rating reflects the agency’s 

uncertainty regarding whether the protester would be able to adequately staff the 

contract at its inception, which the agency characterized as the “decisive point” in

making the decision to rank ITSI over HGL. AR, Tab 12, Ranking Determination, at

28. As explained below, we see no basis to object to the agency’s evaluation. 

Under factor 6, the agency required offerors to demonstrate their “ability/capacity to 

staff the contract with experienced trained personnel at the appropriate levels and 

disciplines in an effective and timely manner. The offeror[s] will be evaluated on 

current and projected workload commitments.” Solicitation at 6. 

 1

 The protester raised several issues in its comments on the supplemental agency 

report, including, for example, a challenge to the agency’s assessment of a notable 

weakness under factor 5. Comments on Supplement AR, Apr. 18, 2008, at 11-12. 

Those grounds, raised more than 10 days after receipt by the protester of the initial 

agency report, and based on information contained therein, are untimely. Bid 

Protest Regulations, 4 C.F.R. § 21.2(a)(2) (2008). 

Page 4 B-311263, B-311263.2 
The protester’s submission stated as follows: 

Assuming an estimated maximum resource requirement of 55 

full-time equivalents (FTEs), the over [DELETED] staff from 

within Region 9 Team offices represents [DELETED] times the 

amount of the estimated maximum requirement. Currently, the 

Team has [DELETED] FTE’s in excess capacity to perform all 

expected services and accommodate peak workloads in excess of 

[DELETED] FTEs at any one time. . . . Based on current 

contracted workload, our key personnel and technical staff will 

have approximately 50% availability in six months and up to 80% 

availability within 12 months.

Protester’s SF 330 at 41 (emphasis added). 

In its pre-oral presentation evaluation, the AEEB assigned a notable weakness to the 

protester’s submission under factor 6, stating that the “Offeror did not clearly 

explain [how] it would adapt to increasing capacity of this contract. The Offeror 

stated that they would be operating at 50% capacity in 6 months and 80% capacity in 

12 months.” AR, Tab 6, AEEB Report, at 6. 

As noted above, offerors were provided at the oral presentations with a list of

questions to which they should respond. The last of HGL’s questions stated: “The 

proposal includes an estimate that key staff will have 50% availability in 6 months 

and 80% availability at the end of the year. Please describe the personnel and 

companies included in this estimate.” Id. at 4.2

 In its post-oral presentation analysis, 

the AEEB stated that “during the oral presentation, HGL was asked to explain a 

statement in the written document regarding capacity (that HGL would be able to 

provide service at 50% at 6 months, 80% in 12) and did not satisfactorily explain how 

this would work to the AEEB.” AR, Tab 11, AEEB Final Report, at 3. 

The protester argues that the agency unreasonably took one sentence in its

submission out of context, when the submission, read as a whole, repeatedly 

asserted that HGL would be prepared to fulfill the contract requirements at the 

inception of contract performance. We disagree. 

An offeror has the responsibility to submit a well-written proposal, with adequately 

detailed information, which clearly demonstrates compliance with the solicitation 

 2

 Other related questions included: “6. If you are awarded RAC II, what assurance 

can you give us that the personnel in the proposal will be working on the contract?”; 

and “14. You have proposed to expand the San Francisco office. . . . What lag-time 

do you anticipate before this office will be fully staffed and operating to meet EPA’s

needs?” Id.

Page 5 B-311263, B-311263.2 
requirements and allows a meaningful review by the procuring agency, CACI Techs., 

Inc., B-296946, Oct. 27, 2005, 2005 CPD ¶ 198 at 5, and that contains all the 

information that was requested or necessary to demonstrate its capabilities in 

response to the solicitation. HealthStar VA, PLLC, B-299737, June 22, 2007, 2007 

CPD ¶ 114 at 2. A protester’s mere disagreement with the evaluation, as noted 

above, provides no basis to question the reasonableness of the evaluators’ 

judgments. See CH2M Hill, Ltd., supra. 

In our view, based on the reference in HGL’s submission to “50% availability in six 

months and up to 80% availability within 12 months” of its “key personnel and 

technical staff,” it was not unreasonable for the agency to seek confirmation from 

HGL regarding the availability of the personnel proposed for the contract. To that

end, four of the 15 oral presentation questions presented to HGL by the agency 

concerned staffing, including the last question, quoted above, which was specifically 

directed at obtaining clarification of the statement in the protester’s SF 330 

regarding staffing availability.3

 The record shows, however, that the protester failed 

to persuade the agency that it would have the key individuals with which it intended 

to staff the contract ready at the inception of performance, and that it was prepared 

to deal with the staffing contingencies that might arise. Because HGL did not 

provide the confirmation the agency was seeking,4

 it was reasonable for the agency 

to characterize this area as a notable weakness and ultimately rely on it as the 

primary discriminator between the two strong submissions from HGL and ITSI. 

Oral Presentations 

While the primary discriminator in the ranking determination was the personnel 

staffing issue discussed above, the record shows that the agency also considered the 

fact that HGL’s oral presentation was considered weaker than the other two offerors’ 

presentations. AR, Tab 12, Ranking Determination, at 30. The specific weaknesses 

 3

 See, in particular, questions four (“Considering that you have other RAC contracts 

with other EPA Regions, what is your approach for managing the RAC II contract

without becoming over extended? What is your staffing plan if you become over 

extended?”) and six (“If you are awarded RAC II, what assurance can you give us 

that the personnel in the proposal will be working on the contract?”). AR, Tab 7, 

HGL Interview Questions at 1. 

4

 The protester states that it reached the last question with only 2 minutes remaining 

in the time allotted to respond to questions during its oral presentation, and unlike 

with other questions, the agency did not ask follow-up questions or for additional 

clarifications. The ground rules of the oral presentation were clear, and the fact that

HGL apparently had only a short time left in which to respond to the question at

issue provides no basis to question the agency’s evaluation of its submission in this 

area. 

Page 6 B-311263, B-311263.2 
are memorialized in a contemporaneous written summary of the evaluation of the 

oral presentations, where the AEEB noted, for example, that HGL did not present

“an in-depth understanding of the Superfund that was [commensurate] with the 

written proposal.” AR, Tab 11, AEEB Final Report, at 3. While HGL vigorously 

disputes the agency’s evaluation, the agency’s contemporaneous evaluation record 

contains a detailed summary of why the agency considered HGL’s oral presentation, 

though sound, inferior to ITSI’s, and we see nothing unreasonable in the evaluation. 

On a related point, the protester argues that the oral presentations did not satisfy the 

requirement for meaningful discussions in the FAR. The Brooks Act and its

implementing regulations in FAR subpart 36.6 provide that agencies “shall conduct 

discussions with at least 3 firms to consider anticipated concepts and compare 

alternative methods for furnishing the services.” 40 U.S.C. § 1103(c) (2002); FAR 

§ 36.602-3(c). The protester asserts that the agency’s meetings with the offerors did 

not constitute adequate discussions under the Brooks Act because the agency’s 

“failure to discuss any potential weaknesses. . . negates any meaningfulness of any 

discussions.” Comments, Mar. 31, 2008, at 22. We disagree. 

The questions that the agency posed to HGL more than adequately probed “concepts 

and the relative utility of alternative methods of furnishing the required services,” as

provided in FAR § 36.602-3(c). Specifically, questions 7 through 13 asked for 

examples of innovative approaches, methods for implementing certain processes,

and examples of projects where certain processes were successfully used. Each of 

those seven questions, nearly half of the 15 questions asked, dealt with the relative 

merits of various methods of delivering services. In our view, this is precisely the 

kind of discussion that is contemplated under FAR § 36.602-3(c). See URS

Consultants, B-275068.2, Jan. 21, 1997, 97-1 CPD ¶ 100 at 5-6 n.4. Moreover, FAR 

§ 36.602-3(c) includes no requirement that, during discussions, an agency identify 

any weaknesses in an offeror’s proposal; in fact, FAR § 36.601-3(b) states that FAR 

part 15--which includes the requirement to discuss proposal deficiencies and 

significant weaknesses with offerors whose proposals are included in the 

competitive range--is inapplicable to A-E procurements under FAR subpart 36.6. Id. 

In any event, the record clearly shows that the protester was advised of the agency’s 

concerns with its proposed staffing during discussions. 

Evaluation under Factor 1: Fund-Lead Projects 

The protester challenges the agency’s evaluation of its submission under factor 1, the 

most important factor, which identified as a significant weakness the fact that HGL 

“provided some ‘Fund-lead’ example projects which were not ‘Fund-lead’, but rather 

DOD/PRP lead.

5

 This did not demonstrate a clear or complete understanding of what

 

(continued...) 

5

 As the agency uses the terms, Fund-lead projects are those projects funded by the 

EPA. The term “Fund” is a shorthand reference to “Superfund.” The term

Page 7 B-311263, B-311263.2 
a Fund-lead project is including the associated level of work. This may result in 

more agency oversight.” AR, Tab 12, Ranking Determination, at 17. The protester 

asserts that the agency’s assessment of a notable weakness on this basis was 

unreasonable, and that the protester’s submission instead should have been rated 

“outstanding,” the highest rating available. 

The protester agues that, besides the funding source distinction between Fund-lead 

and non-Fund-lead projects, which the protester argues is inconsequential, the 

various types of projects are functionally equivalent because they are governed by 

the same statutes and “[a]ny work that the DoD would undertake pursuant to

Superfund using its appropriated funds would be the equivalent of an EPA Fund-lead

action.” Comments, Mar. 31, 2008, at 5. Therefore, the protester argues, the agency’s 

concern that the protester’s lack of “understanding about the regulatory context

under which RAC actions occur, which could lead to more agency oversight during 

contract performance,” Additional Agency Comments, May 1, 2008, at 3, is 

unreasonable. 

Even assuming the regulatory framework is the same for Fund-lead and non-Fundlead projects, as the protester argues, it does not necessarily follow that the methods

by which different agencies oversee such projects are the same, and we cannot find

unreasonable the agency’s assertion that the protester’s apparent failure to 

appreciate this distinction might require additional agency supervision during 

contract performance.6

 In our view, the agency reasonably assessed the protester’s 

submission a notable weakness when it concluded in its evaluation that the protester 

may have misunderstood that distinction and may have failed to appreciate the 

administrative ramifications of which agency had contracted for the remediation 

services. 

Further, even assuming the agency unreasonably assessed the protester’s submission 

a notable weakness under factor 1, we see no resulting prejudice to the protester. 

Our Office will not sustain a protest absent a showing of competitive prejudice, that 

is, unless the protester demonstrates that, but for the agency’s actions, it would have 

a substantial chance of being the highest-ranked firm. McDonald-Bradley, B-270126, 

Feb. 8, 1996, 96-1 CPD ¶ 54 at 3; see also Statistica, Inc. v. Christopher, 102 F.3d 1577, 

1681 (Fed. Cir. 1996). Here and throughout its arguments, HGL incorrectly assumes 

 

(...continued) 

“DOD/PRP” refers to the Department of Defense (DOD) or a “potential responsible 

party” (PRP). 

6

 The protester argues for the first time in its May 1 comments that the agency 

disparately treated offerors in its evaluation under factor 1. This protest ground is

based on information contained in the agency report that was produced more than 

10 days prior to those comments, and it is therefore untimely. See 4 C.F.R. 

§ 21.2(a)(2). 

Page 8 B-311263, B-311263.2 
that the absence of a notable weakness would necessarily lead to a higher rating 

under a particular SF 330 factor (which would in turn lead to the highest SF 330 

ranking). There is nothing in the adjectival rating system’s definitions that directly 

or indirectly correlates the number of, or lack of, weaknesses to ratings, except for 

the rating of “poor.”7

 We thus see no reason to conclude that the removal of a 

notable weakness from its evaluation under factor 1 (where the protester was rated 

“excellent”) would necessarily improve its rating under that factor to “outstanding.”8

 

The agency’s evaluation clearly spells out the reasons that each of the submissions, 

including the protester’s, received the rating that it did under factor 1, and we see no 

basis to question the agency’s assertion that the criterion most influencing the 

factor 1 ratings was the quality of the relevant experience of each offeror. 

Adequacy of the Evaluation Documentation 

The protester asserts that the agency failed to sufficiently document its evaluation, 

because the agency did not comment on the strength of each SF 330 at the level of 

the 32 work areas in factor 1, nor did the evaluators engage in a point-by-point 

comparison of the SF 330s, tallying up each of the instances where the offerors’ 

SF 330s claimed to show experience relevant to the 32 work areas. 

It is clear from the final evaluation conducted by the agency, which included an 

assessment of each submission under each evaluation factor, including the 

subfactors under factors 1 and 4, that the SSO was aware of the strengths and 

weaknesses of each offeror’s SF 330. A selection official’s judgment must be 

documented in sufficient detail to show it is not arbitrary, but a failure to discuss the 

SF 330s in the detail that the protester argues is necessary does not affect the validity 

of the decision where, as here, the record shows that the agency’s ranking was 

reasonable. See Carmon Constr., Inc., B-292387.3, Sept. 5, 2003, 2003 CPD ¶ 158 at 4. 

In our view, the evaluators were not required to tally and compare, in the evaluation

summaries, the number of work areas in each SF 330 for which experience was 

provided, or to perform various other comparisons that the protester alleges were 

not made. Indeed, the evaluation of proposals and the assignment of adjectival 

ratings generally should not be based upon a simple count of strengths and 

weaknesses, but upon a qualitative assessment of the proposals consistent with the 

evaluation scheme. Sherrick Aerospace, B-310359.2, Jan. 10, 2008, 2008 CPD ¶ 17 

at 6. On the record here, as discussed above, we conclude that the agency made and 

documented just such a qualitative assessment. 

 7

 The solicitation defines a “poor” submission as one which addresses the factor, “but

contains deficiencies and/or weaknesses.” AR, Tab 5, Evaluation Factors, at 5. 

8

 In the evaluation of HGL’s submission under factor 2, for example, the agency cited 

no notable weaknesses in the protester’s submission but nevertheless rated the 

submission “excellent” rather than “outstanding.” 

Page 9 B-311263, B-311263.2 
The protester makes several allegations that, under certain factors, its SF 330 was 

better than ITSI’s, and that the agency thus should have rated its submission higher 

under those factors and ranked its submission first. As an initial matter, we note that

evaluations are conducted by comparing proposals to the evaluation factors, not to 

each other; two proposals that are of different quality under a particular factor might 

still reasonably receive the same rating for that factor. Moreover, the particular 

rating under each factor is not conclusive of which proposal an agency will rank

most highly. It is well-established that ratings are mere guides for intelligent 

decision-making in the procurement process. Id. Where an agency reasonably 

considers the underlying bases for the ratings, including advantages and 

disadvantages associated with the specific content of competing proposals, in a 

manner that is fair and equitable and consistent with the terms of the solicitation, the 

protester’s disagreement over the actual adjectival ratings, as in this case, does not 

affect the reasonableness of the judgments made in the source selection decision. 

Subcontracting Limitation 

In its original protest, HGL argued that ITSI cannot comply (i.e., does not have the 

“experience, qualifications, capability and availability” necessary to comply) with the 

small business subcontracting limitation requirements in the solicitation. We 

dismissed this issue on the ground that it presents a question of responsibility for 

review by the Small Business Administration, not our Office. See TYBRIN Corp., 

B-298364.6, B-298364.7, Mar. 13, 2007, 2007 CPD ¶ 51 at 6-7. 

The protester subsequently renewed this protest ground, arguing that the 

information contained in ITSI’s SF330 shows that the firm “cannot comply with a 

material condition of the Solicitation which is that work performed by [ITSI’s]

personnel alone must constitute at least 50% of the cost of contract performance.” 

Comments on Supplemental AR, Apr. 18, 2008, at 1. The issue of compliance with a 

subcontracting limitation concerns the acceptability of an offeror’s proposal, rather 

than the offeror’s responsibility, only where the proposal, on its face, should lead the 

agency to conclude that the offeror has not agreed to comply with the 

subcontracting limitation. See TYBRIN Corp., supra. Based on our review, we see 

Page 10 B-311263, B-311263.2 
no basis to conclude that ITSI’s SF 330, on its face, should have led to such a 

conclusion. 9 

The protest is denied. 

Gary L. Kepplinger 

General Counsel 

 9

 To arrive at its position that, on its face, ITSI’s submission fails to comply with the 

subcontracting requirement, the protester assumed that subfactors one, two, and 

three under factor 1 each comprise one third of the personnel cost required by the 

statement of work, and that each of the subfactors is evenly divided into various 

elements. After identifying those elements under the three subfactors where it says 

that ITSI’s resumes indicated that the firm will have its own employees performing 

the statement of work, the protester took a weighted average of ITSI’s employee 

performance under the three subfactors and calculated that the firm’s employees will

perform no more than [DELETED] percent of the value of the statement of work. 

Comments on Supplemental AR, Exh. 1. Calculations of whether an offeror will 

comply with the subcontracting limitation must consider the cost of performance by 

the prime and subcontractor employees, and cannot, as the protester has done here, 

rely simply on a numerical comparison of staffing levels. See Symtech Corp., 

B-285358, Aug. 21, 2000, 2000 CPD ¶ 143 at 12. 

Page 11 B-311263, B-311263.2