BNUMBER:  B-266345
DATE:  February 8, 1996
TITLE:  Atherton Construction, Inc.

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Matter of:Atherton Construction, Inc.

File:     B-266345

Date:     February 8, 1996

Denver C. Snuffer, Esq., Nelson, Snuffer & Dahle, P.C., for the 
protester.
David H. Doro, Esq., Department of the Air Force, for the agency.
Jeanne W. Isrin, Esq., and John M. Melody, Esq., Office of the General 
Counsel, GAO, participated in the preparation of the decision.

DIGEST

1.  Where agency's methodology for determining which additive items to 
award, and which bid was low, was based on the solicitation scheme and 
did not allow for manipulation of funds to direct award to any 
particular bidder, protest challenging award is denied; moreover, 
since all base bids exceeded funding amount established prior to bid 
opening, making base bids the determining factor for award, protester 
which was not low on the base bid was not entitled to award.

2.  Solicitation provision stating that award would be made on an "all 
or none" basis cannot be reasonably interpreted as requiring that 
award be made for all line items where:  (1) the plain language of the 
provision says only that one award will be made based on however many 
items are awarded, and (2) protester's interpretation is directly in 
conflict with provision detailing the procedure to be followed to 
determine the number of additive items upon which award would be 
based.

DECISION

Atherton Construction, Inc. protests the award of a contract to Dale 
B. Stevens Construction, Inc. under invitation for bids (IFB) No. 
F42650-95-B-0034, issued by the Department of the Air Force for the 
repair/alteration of building 1266 at Hill Air Force Base, Utah.

We deny the protest.

The IFB was issued on August 8, 1995, and contemplated a firm, 
fixed-price contract.  The project consisted of minor construction, 
repair, and equipment components which were set out in the bid 
schedule in nine line items, three base and six additive.  Items 0001 
(base), and 0004 and 0005 (additive) detailed the minor construction 
work to be performed.  Item 0002 (base) detailed the repair work to be 
performed; there were no additive items for repair work.  Item 0003 
(base) and items 0006, 0007, 0008, and 0009 (additive) detailed the 
equipment-related work to be performed.

The IFB included a provision, subparagraph L-507, entitled "AWARD-ALL 
OR NONE BASIS," which provided:

     "Notwithstanding the clause at 52.215-16, "Contract Award", of 
     this solicitation, award shall be made to a single bidder/offeror 
     for all items being awarded.  Failure to bid on any item 
     including any option periods will be cause for rejecting your 
     bid/offer as non-responsive." 

On the same page, directly below the above provision, the IFB 
incorporated by reference Defense Federal Acquisition Regulation 
Supplement (DFARS)  sec.  252.236-7007, entitled "Additive or Deductive 
Items (DEC 1991)," which provides (in pertinent part):

     "(a) The low offeror and the items to be awarded shall be 
     determined as follows--

        (1) Prior to the opening of bids, the Government will 
        determine the amount of funds available for the project.

        (2) The low offeror shall be the Offeror that--

             (i) Is otherwise eligible for award; and

             (ii) Offers the lowest aggregate amount for the first or 
             base bid item, plus or minus (in the order stated in the 
             list of priorities in the bid schedule) those additive or 
             deductive items that provide the most features within the 
             funds determined available.

        (3) The Contracting Officer shall evaluate all bids on the        
        basis of the same additive or deductive items.

             (i) If adding another item from the bid schedule list of 
             priorities would make the award exceed the available 
             funds for all offerors, the Contracting Officer will skip 
             that item and go to the next item from the bid schedule 
             of priorities; and

             (ii) Add that next item if an award may be made that 
             includes that item and is within the available funds.

     "(b) The Contracting Officer will use the list of priorities in 
     the bid schedule only to determine the low offeror.  After 
     determining the                                   low offeror, an 
     award may be made on any combination of items if--

        (1) It is in the best interest of the Government;

        (2) Funds are available at the time of award; and

        (3) The low offeror's price for the combination to be awarded 
        is less than the price offered by any other responsive,  
        responsible offeror."

Consistent with the above provision, on July 20, contracting officials 
received notice that $654,279 was available for the project, broken 
down as follows:  (1) $279,800 for the minor construction component 
(base item 0001 and additive items 0004 and 0005); (2) $124,506 for 
the repair component (base item 0002); and (3) $249,973 for the 
equipment component (base item 0003 and additive items 0006 through 
0009).

Six bids were received by the September 19 bid opening with results as 
follows:

                 Funds Available Atherton       Stevens

Item 0001                           $250,000     $188,000

Item 0004                            $20,000      $61,000

Item 0005                             $9,000      $27,000

Subtotal
(1, 4, 5)             $279,800      $279,000     $276,000

Item 0002             $124,506      $350,000     $412,000

Item 0003                           $252,225     $180,000

Item 0006                            $10,775       $8,000

Item 0007                            $20,000      $15,000

Item 0008                            $20,000      $31,000

Item 0009                            $10,000      $33,000Subtotal
(3, 6, 7, 8, 9)       $249,973      $313,000     $264,000

TOTAL                 $654,279      $942,000     $955,000

According to the agency, because each of the three project components 
had a separate funding limit, each component, its base item and any 
additives associated with it, was evaluated separately in the 
following manner:

(1)  Minor Construction Component (base item 0001, additive items 
0004, 0005) - Aggregate bids for the three items were calculated for 
all six bidders.  Atherton, Stevens, and one other bidder submitted 
aggregate bids that were within the $279,800 limit.  Stevens and the 
other bidder were tied for low bid at $276,000.

(2) Repair Component (base item 0002) - Since the funds available for 
base item 0002 were substantially lower than all the bids for that 
item, which ranged from $275,700 to $412,000, and item 0002 was a base 
item and was considered a "must award" item by the agency, the 
contracting officer requested and received for that item an additional 
commitment of $287,494, the amount necessary to bring all offers 
within the funds available.  (The additional funds brought the total 
amount of funds available to perform the project to $941,773.)

(3) Equipment Component (base item 0003, additive items 0006 through 
0009) - Contracting officials tabulated aggregate totals and found 
that all aggregate bids exceeded the funds available.  The agency thus 
applied DFARS  sec.  252.236-7007, and found that, within the $249,973 
funding limit, award could be made for items 0003 and 0006, 0007 and 
0008, but only to Stevens.  All other bidders, including Atherton, had 
aggregate bids for items 0003 and 0006 through 0008 which exceeded the 
funding limit.

Contracting officials also tabulated a running total of line item 
prices (rather than prices broken down by the three base items) for 
all three components according to two sequences:  (1) 0001 through 
0009 in numerical order, and (2) 0001, 0004, 0005, 0002, 0003, 0006, 
0007, 0008, and 0009, i.e., ordered by base bid grouping, each with 
its additives.  Both yielded the same result when evaluated against 
the revised total funding ($941,773), i.e., no award could be made for 
all line items, but Atherton and Stevens had running totals through 
item 0008 which were within the available funds.  Although the results 
of this method differed slightly from the other method in that 
Atherton's bid was within available funds for items 0001 through 0008, 
Stevens's bid was low for the eight items--$922,000, compared to 
$932,000 for Atherton.  Based on all these findings, contracting 
officials concluded that award should be made to Stevens as the low 
bidder.  On September 26, award was made to Stevens, based on items 
0001 through 0008, for $922,000.  Had award been based on all items, 
0001 through 0009, Atherton's total bid, $942,000, would have been 
lower than Stevens's bid of $955,000.

Atherton argues that bids were improperly evaluated because the amount 
of funds available for award was not determined prior to bid opening, 
as required by DFARS  sec.  252.236-7007, but was increased after bid 
opening to $941,773, and that bids were evaluated against that 
figure.[1]  

The award was proper.  The agency's approach to determining the low 
bid for the proper combination of items appears to have been properly 
based on methodologies under which the agency could not manipulate the 
funds available to ensure award to a particular firm.  In this regard, 
the funds available amount was established before bid opening, and the 
only increase in available funding (for item 0002) was based on the 
amount necessary to bring all offerors (as opposed to a certain 
offeror) within the funding limit.  This hardly can be said to have 
favored Stevens over Atherton.  Aside from this funding increase, the 
agency evaluated the bids based strictly on the order of the items 
(i.e., item 0001 and its additives first, item 0002 second, and item 
0003 and its additive, in order, last), and the revised total funds 
available. 

In any case, where, as here, the IFB contains the "Additive or 
Deductive Items" clause, and the funds available prior to bid opening 
are insufficient to cover even the lowest base bid, award should be 
made only to the bidder offering the lowest price on the least amount 
of work, in this case, the base bid, if additional, sufficient funds 
subsequently become available.  See Connie Hall Co., B-223440.2, Nov. 
18, 1986, 86-2 CPD  para.  576; Utley-James, Inc., B-198406, June 16, 1980, 
80-1 CPD  para.  417; Gartrell Constr., Inc., U.S. Floors, Inc., B-237032; 
B-237032.2, Jan. 11, 1990, 90-1 CPD  para.  46.  After additional funds are 
obtained, award may include additive items, so long as no other 
responsible bidder has submitted a lower bid on the same combination 
of items.  Connie Hall Co., supra; Utley-James, Inc., supra.  

Since all base bids were higher than the original amount of funds 
available, $654,279, only the base bids should have been considered in 
the award decision.  Since Stevens submitted a lower base bid 
($780,000) than Atherton ($852,225), and the total funds available 
after additional funds were obtained ($941,773) were sufficient to 
cover Stevens's lowest bid for items 0001 through 0008, Atherton is 
incorrect that it was entitled to the award instead of Stevens.  
Although Atherton argues generally that its bid represented the best 
value to the government because for only $10,000 more (the difference 
actually is $20,000) the government could have had performance of all 
items, this misses the point.  Since all base bids exceeded the funds 
available and Atherton's bid on the base items was not low, award to 
Atherton would have been improper.[2]

Atherton also argues that clause L-507 required award of all items, 
and that it thus was in line for award based on its low bid for all 
nine line items.  This argument is without merit.  The plain language 
of the clause states only that "award shall be made to a single 
bidder/offeror for all items being awarded"; it does not state that 
all items will be awarded.  Indeed, such an interpretation is directly 
contrary to the inclusion of additive items in the IFB; by definition, 
and as described in the DFARS  sec.  252.234-7007 provision incorporated in 
the IFB, the additive items were only to be awarded based on the funds 
available.  See Utley-James, Inc., supra.

Atherton maintains that contracting officials have manipulated the 
evaluation process to avoid making award to Atherton.  As discussed, 
however, Stevens was the correct awardee based on a funding limitation 
that was clearly established prior to bid opening, so there were no 
means by which officials could have manipulated the award.  
Contracting officials have denied Atherton's contention, and the 
protester has offered no evidence that contracting officials acted in 
bad faith.  Prejudicial motives will not be attributed to contracting 
officials on the basis of unsupported allegations, inference, or 
supposition.  Stabro Labs., Inc., B-256921, Aug. 8, 1994, 94-2 CPD  para.  
66. 

The protest is denied.

Comptroller General
of the United States

1. The basic purpose of the "Additive or Deductive Items" clause 
requirement that bids be evaluated based on the funds available at bid 
opening is to ensure that after bids are exposed the contracting 
agency cannot manipulate the amount of funds available to select 
enough additives to ensure award to a particular firm.  H.L. Martz 
Constr. Corp., B-213320, Dec. 27, 1983, 84-1 CPD  para.  29.  

2. Actually, Stevens's bid on the base items was $5 higher than 
another bid.         (The bidder has neither protested nor intervened 
in Atherton's protest.)  However, the analysis here is valid for 
purposes of addressing Atherton's claim of entitlement to the award.