THIS OPINION WAS INITALLY ISSUED UNDER PROTECTIVE ORDER AND IS BEING RELEASED TO THE PUBLIC IN REDACTED FORM ON JANUARY 10, 1995 DENIED: December 15, 1994 GSBCA 13016-P, 13017-P THE TELECOMMUNICATIONS BANK, INC., and NORTHWEST COMMUNICATIONS SERVICES, INC., Protesters, v. DEPARTMENT OF VETERANS AFFAIRS, Respondent. Sam Zalman Gdanski of Suffern, NY, counsel for Protesters. Phillip Kauffman, Jane S. Converse, and Dennis Foley, Office of General Counsel, Department of Veterans Affairs, Washington, DC, counsel for Respondent. Before Board Judges NEILL, DeGRAFF, and GOODMAN. GOODMAN, Board Judge. Protesters, The Telecommunications Bank, Inc. (Telecom) and Northwest Communications Services, Inc. (Northwest), challenge the award of contracts by respondent, the Department of Veterans Affairs (VA). The protests were consolidated, as they concern common questions of law and fact. For the reasons set forth below, we deny the protests. Findings of Fact 1. These protests concern requests for proposals (RFPs) 101-17-94 and 101-18-94 (the solicitations) for the acquisition of replacement telephone systems at the VA Medical Centers in Denver, Colorado, and Richmond, Virginia. RFP 101- 17-94 was issued on May 2, 1994; RFP 101-18-94 was issued on May 16, 1994. Protest File, GSBCA 13016-P, 13017-P, Exhibit 1. The due date for receipt of initial proposals was set for both procurements as August 10, 1994. Id., GSBCA 13016-P, Exhibit 2, Amendment 4; Id., GSBCA 13017-P, Exhibit 2, Amendment 6. 2. Both solicitations provided that offerors must submit a life cycle price and a life cycle present value cost.[foot #] 1 Protest File, GSBCA 13016-P, 13017- P, Exhibit 1 at B-13. The life cycle present value cost was to be calculated by the offeror by multiplying the monthly values comprising its life cycle price by discount factors set forth in each solicitation at page B-14. Id. at B-14. 3. Section M of each solicitation provided as follows: SECTION M - EVALUATION FACTORS FOR AWARD M.1 EVALUATION OF OPTIONS FIP RESOURCES (FIRMR 201- 39.5202-4)(OCT 1990) (a) The Government will evaluate offers for award purposes by adding the total price for all options to the total price for the basic requirement. These prices will be adjusted by the applicable discount factors shown in Section B of the solicitation. Evaluation of options will not obligate the Government to exercise the options. Offers containing any charges for failure to exercise any option will be rejected. (b) Selection of an offer will be made on the basis of the most advantageous alternative to the Government provided that the contract prices ----------- FOOTNOTE BEGINS --------- [foot #] 1 Protesters and respondent have used various terminology to refer to life cycle price and life cycle present value cost. The life cycle price has been referred to by protesters as "above-the-line pricing" and by respondent as "total raw 10 year lifecycle cost," "10 year total cost," and "total 10 year lifecycle cost." The life cycle present value cost has been referred to by protester as "below-the-line pricing," by respondent as "ten year present value adjusted price," and by both as the "discounted price" or "discounted method." Table B-5 of the solicitations refers to these two values as "yearly total" and "adjusted total." ----------- FOOTNOTE ENDS ----------- reasonably represent the value of bona fide requirements for each fiscal year. This determination with respect to contract prices will be made after consideration of such factors as commercial or catalog prices for short term leases, offeror system startup expenses, multi-year price protection, assured system life availability of equipment, software, and vender [sic] support. If a determination is made that an offer does not meet these criteria, that offer cannot be accepted for award. M.2 EVALUATION OF PROPOSALS To be acceptable and eligible for evaluation, proposals must (1) be prepared in accordance with and comply with the instructions given in this solicitation document, and (2) meet all the mandatory requirements set forth in Section C of this solicitation. Proposals meeting the mandatory requirements and complying with the Standard Form of Contract will be evaluated and awarded to that responsible offeror with the lowest lifecycle price. To be considered acceptable under the solicitation, the offeror must offer: (a) Fixed prices for the initial contract period in which supplies/services are being procured; (b) Fixed prices or prices that can be finitely determined and remain in effect during the renewal period for each separate optional renewal period; and (c) Fixed prices or prices that can be finitely determined for all required optional quantities. This solicitation is intended to achieve the maximum quality of performance at the lowest realistic fiscal year cost. The Government intends to evaluate the realism of the Offeror's proposed price to ensure that the contract price reasonably represents the value of the bona fide fiscal year requirements. An offer which is unbalanced as to prices for the basic and/or optional periods may be rejected. An unbalanced offer is one which is based on prices significantly less than cost for some services and/or items, or for which prices are significantly overstated for other services and/or items. There must be a direct and reasonable relationship between the consideration paid by the Government and the value of goods or services received by the Government on a fiscal year basis. M.3 PRICE PROPOSALS Price proposals will be evaluated separately from technical proposals. Price proposals will be evaluated using price analysis techniques and will not be point scored. The offeror s proposal will be evaluated to determine the expected contract life cycle present value costs. This life cycle present value cost will be based upon all costs including special discounts, escalation and terms and conditions, as applied to the cost evaluation model. In addition, price analysis will include an evaluation of each proposal for completeness, realism, reasonableness risk, and cost related factors. Protest File, GSBCA 13016-P, 13017-P, Exhibit 1 at M-1 to M-2. 4. By letter dated August 30, 1994, discussions were scheduled with firms determined to be in the competitive range for RFP 101-18-94, including Telecom. Protest File, GSBCA 13016-P, Exhibit 5. By letter dated September 6, 1994, discussions were scheduled with firms determined to be in the competitive range for RFP 101-17-94, including Northwest. Id., GSBCA 13017-P, Exhibit 5. 5. By letters dated September 8, 1994, and September 9, 1994, the contracting officer informed offerors that discussions were closed for RFP 101-18-94 and RFP 101-17-94 and that best and final offers (BAFOs) were due on September 20, 1994. Protest File, GSBCA 13016-P, 13017-P, Exhibit 7. Protesters and the awardees submitted timely BAFOs. Id., Exhibits 9, 10. 6. By letter dated September 26, 1994, to the Small Business Administration (SBA), the contracting officer advised that with regard to RFP 101-17-94: Listing of top three (3) offerors, ranked in the order of their standing for award: Vendor Total Base Total 10 Year Cost Year Cost Award of this contract was based on the total 10 year lifecycle cost to the Government. It should also be noted that the figures above are submitted totals by each offeror. Ranking of each firm was based on the Government evaluated 10 year total. The Government's evaluated 10 year total is as follows: A total of (6) proposals were received in response to this solicitation. One (1) firm failed to submit a best and final proposal and therefore did not make it to the final evaluation process. Protest File, GSBCA 13017-P, Exhibit 11. 7. Northwest's proposed contract price under RFP 101-17- 94 was for the life cycle price, and its life cycle present value cost was Protest File, GSBCA 13017-P, Exhibit 9. The contracting officer testified that Northwest ranked in RFP 101-17-94, based on either life cycle price or life cycle present value cost. Transcript at 93. 8. On September 29, 1994, respondent awarded a contract to DataEquip, Inc., under RFP 101-17-94 in the amount of $3,181,432 for the life cycle price. Protest File, GSBCA 13017-P, Exhibits 10, 13. DataEquip, Inc.'s life cycle present value cost was Id., Exhibit 10 at Table B-5. 9. By letter dated September 26, 1994, to the SBA, the contracting officer advised that with regard to RFP 101-18-94: Listing of top three (3) offerors, ranked in the order of their standing for award: . . . . Award of this contract was based on the total 10 year lifecycle cost to the Government. A total of proposals were received in response to this solicitation. firms failed the validation process during best and final evaluations. This was primarily caused by errors and omissions on the part of these offerors. Protest File, GSBCA 13016-P, Exhibit 11. 10. Telecom's proposed contract price was for the life cycle cost, and its life cycle present value cost was Protest File, GSBCA 13016-P, Exhibit 9 (last unnumbered page). According to the contracting officer, Telecom ranked fourth in RFP 101-18-94, based on either life cycle price or life cycle present value cost. Transcript at 93. 11. On September 30, 1994, respondent awarded a contract to United Communications Systems, Inc., under RFP 101-18-94 in the amount of $5,357,072 for the life cycle price. Protest File, GSBCA 13016-P, Exhibits 10, 13. United Communications Systems, Inc.'s life cycle present value cost was $4,211,146. Id., Exhibit 10 at lcc-11. 12. On October 11, 1994, identical protests were filed by Northwest and Telecom, alleging that the VA has awarded and evaluated procurements by utilizing a "discounted price formula"[foot #] 2, and that, upon information and belief, protesters had submitted a price lower than the publicly disclosed award prices. The protests further alleged that each protester had submitted the lowest price, and failure to award to the respective protesters therefore violated the terms of the solicitation, the Competition in Contracting Act, and the Brooks Act. Protest File, GSBCA 13016-P, 13017-P, Exhibit 19. 13. A hearing on the merits was held on November 9, 1994. 14. At the hearing, Mr. Ray Zitzloff, the Senior Vice President of Telcom Systems Services, Inc. (Telcom), testified on behalf of protesters. Telcom is a supplier for both protesters. Transcript at 30. Mr. Zitzloff assisted in the preparation of the cost proposals of each protester. Id. at 12. Mr. Zitzloff is not an employee, officer, or owner of the protesters, nor did he sign or submit the initial proposals or the BAFOs. Id. at 29-30. ----------- FOOTNOTE BEGINS --------- [foot #] 2 This is a reference to life cycle present value cost. ----------- FOOTNOTE ENDS ----------- 15. Mr. Zitzloff testified that he determined what he believed to be the basis for award for each RFP by examining and interpreting Section M, Evaluation Factors for Award, specifically, paragraphs M.1 and M.3. He concluded that the basis of award would be on "present value below the line cost [life cycle present value cost]." Transcript at 12-15. Mr. Zitzloff did not consider paragraph M.2 in determining what he believed would be respondent's basis for award. Id. at 34-36. 16. Mr. Zitzloff testified concerning a document (Protesters' Exhibit 1) which contained a calculation allegedly representing the maximum price that Telecom would have offered had it interpreted the RFP to state that award would be based on the lifecycle price, rather than life cycle present value cost. Transcript at 23-27. No similar calculation was provided concerning Northwest's BAFO in response to RFP 101-17-94. Id. at 28-29. Mr. Zitzloff testified that the lifecycle price, as revised, which was lower than the original lifecycle price in the BAFO, would result in the same dollar return to the offeror. Id. at 23, 55. Mr. Zitzloff testified that Telecom was not prevented from submitting the revised BAFO price, no matter what it believed was the basis of award. Id. at 55. 17. The contracting officer testified regarding respondent's interpretation of Section M and the basis for award for the solicitations that are the subject of the instant protests. Transcript at 69-74. The contracting officer testified that the basis of award is contained in paragraph M.2 of both RFPs. She identified the specific sentence which states the basis of award as that which reads "[p]roposals meeting the mandatory requirements and complying with the Standard Form of Contract will be evaluated and award[ed] to that responsible offeror with the lowest lifecycle price." She also noted that paragraph M.2 provides that the solicitations are intended to achieve the maximum quality of performance at the lowest realistic fiscal year cost. Accordingly, the contracting officer testified that the solicitation required the Government to make award based upon life cycle price, not life cycle present value cost. Id. at 70. 18. The contracting officer testified that the solicitation states that the Government will evaluate life cycle present value cost in paragraphs M.1 and M.3, but nowhere in these paragraphs does it state that award will be based on life cycle present value cost. Transcript at 71. She testified further that life cycle present value cost is used by the Government to help determine likely costs to the Government and the cost of money over the life of the contract. Id. at 72. 19. The contracting officer recognized that the RFP did require offerors to furnish a life cycle present value cost derived from discount factors provided by the Government. Transcript at 73. She testified that the present value price is simply the unadjusted price multiplied by the factors provided by the Government; it is based upon the unadjusted price and is not a separate pricing methodology. Also, it was her understanding that the Government is required to request present value pricing based upon OMB Circular A-94 and the General Services Administration standard solicitation format. However, the contracting officer further stated that she believed that the Federal Information Resources Management Regulations (FIRMR) provides that the Government is only bound to utilize present value pricing in its award decision when different alternative procurement methods, such as lease, lease with option to purchase, lease to purchase, as well as purchase, are being considered. Id. at 72. 20. The contracting officer testified that the prices provided by Northwest in Table B-5 of its proposal, Systems Life Pricing Summary By Year, do not add up to the totals represented therein, when added vertically in the total column. That is, the ten-year total for equipment and software, plus the ten-year total for adds, moves, and changes, does not equal This is true even if one also adds in the ten-year total cost for training, at which was not extended into the total column. Also, on the initial page of its BAFO, in Note H, Northwest states that BMM, basic monthly maintenance, and installation for adds, moves, and changes are broken out in separate columns in Table B-3, and these costs have not been extended into Table B-4, summary by month, and Table B-5, summary by year. The contracting officer testified that Northwest's BAFO was therefore ambiguous, since the Government does not have a clear and definitive total price for all items requested. Transcript at 93-95. 21. The contracting officer testified that the prices provided by Telecom in Table B-5 of its proposal, systems life pricing summary by year, do not add up to the totals represented therein, when added vertically in the total column. That is, the ten-year total for equipment and software, plus the ten-year total for adds, moves, and changes, does not equal This is true even if one also adds in the ten-year total cost for training, at which was not extended into the total column. Also, on the initial page of its BAFO, in Note H, protester states that BMM, basic monthly maintenance, and installation for adds, moves, and changes are broken out in separate columns in Table B-3, and these costs have not been extended into Table B-4, summary by month, and Table B-5, summary by year. The contracting officer testified that Telecom's BAFO was therefore ambiguous since the Government does not have a clear and definitive total price for all items requested. Transcript at 93-95. 22. With regard to the alleged math errors in Table B-5 of both BAFOs, the contracting officer is correct that certain numbers do not total correctly. This appears to be an identical math error made on both spreadsheets which is easily resolvable by a cursory examination. The amount for training, which appears in year one, has not been extended across the row to the total column, which reads "0." The total amount for B- 3, adds, moves, changes, does not equal the sum of the yearly totals in the same row for years one through ten. When the amount for training in year one is entered in the total column, and the amount for adds, moves, changes is corrected in the total column, the resulting sum is the life cycle price (designated as total of the monthly totals row of the spreadsheet) as actually stated in the BAFO. Protest File, GSBCA 13016-P, GSBCA 13017-P, Exhibit 9 at Table B-5. 23. The contracting officer testified concerning her involvement in fourteen other telephone procurements at the VA since 1992. Transcript at 73-74. Documentation was offered from various solicitations. Respondent's Exhibits 1-11. In every instance, she stated that the contract was awarded based upon life cycle price. Id. at 91-92. Also, in these procurements, the Government required a ten-year life cycle present value cost based on the discount factors provided by the VA in the RFP. Id. at 71-73. Except for one instance, a solicitation for which award was made concurrently with the instant solicitations, Section M did not contain language identical to the instant solicitations. In three instances, Telcom, or a firm affiliated with Telcom, received award. Id. at 78-82. 24. Mr. Zitzloff also testified regarding three other telephone procurements that were awarded to Telcom at the VA Medical Centers located at Indianapolis, Indiana, American Lake, Washington, and Livermore, California. Transcript at 125-27; Protesters' Exhibits 2-4. Mr. Zitzloff claimed that award of these solicitations was based on present value discounted prices. Portions of the solicitations containing Section M were not provided to the Board. 25. After the hearing, protesters were granted leave to file award letters, pricing sheets, and portions of two-step sealed bid solicitations for telephone system procurements at seven additional VA medical centers from 1990 and 1991. Protesters' Exhibit 5. These documents are not complete solicitations, nor was the language comprising Section M provided for any of these solicitations. Respondent was also granted leave to file additional documentation with regard to these procurements, and did so. Respondent's Hearing Exhibits 12-14. Discussion The Original Protest Complaint The original protest complaints alleged that 1) based upon information and belief, the VA, which has procured comparable systems at numerous facilities throughout the United States, has awarded and evaluated procurements by utilizing "discounted prices" (i.e., a life cycle present value cost), and 2) protesters' prices are lower than the publicly disclosed award prices and each should, therefore, receive award since they have offered the lowest price. Complaints at 1-2. Additional Allegations of Protesters Protesters' allegations have changed focus during these protests. In response to protesters' allegations in the protest complaints that the VA used life cycle present value cost in awarding other contracts, respondent submitted considerable documentation attempting to prove that "[p]rotesters knew or should have known VA's interpretation, based on past experience with Ms. Martinez, who has been the contracting officer on all telephone systems procurements originating from VACO [Veterans Affairs Central Office]." Respondent's Posthearing Brief at 13; Findings 23, 25. In rebuttal, protesters submitted documentation from many solicitations to which they had responded previously. Findings 24, 25. By reference to these other solicitations, protesters attempted to demonstrate that other offices of the VA had previously awarded contracts based upon life cycle present value cost rather than life cycle price. However, except for one solicitation for which award was made concurrently with the protested awards, none of the other solicitations offered by either party contains the same language which is found in Section M of the instant solicitations. Finding 23. Protesters' representative testified that his understanding that award would be made under this procurement based on life cycle present value cost was premised on the language of the solicitations in the instant procurements. Finding 15. Protesters therefore argue that "the case may be decided on this issue alone, i.e., that [Section] M3 [of the instant solicitations] which was a newly revised paragraph, led to the ambiguity and past procurement practice would be irrelevant to sustain a protest on this issue." Protesters' Posthearing Brief at 28. These protests arise from a dispute as to the interpretation of specific language appearing in the instant solicitations, and the record does not establish that identical language appears in the solicitation for any similar procurements in the past. We agree with protesters that the evidence as to past procurements is irrelevant to the resolution of the instant protest. Each procurement action is a separate transaction, and the action taken under one is not relevant to the propriety of the action taken under another procurement for purposes of a bid protest. S & G Industries, Inc., B-255263, 94-1 CPD 81 (Feb. 1, 1994); Westbrook Industries, B-248854, 92-2 CPD 213 (Sept. 28, 1992); PFC, Inc., B-243195, 91-2 CPD 24 (July 5, 1991); Warrensville File & Knife, Inc., B-241805, 91-1 CPD 236 (Mar. 1, 1991). Rather, the issue is whether the evaluation is consistent with the evaluation criteria in the solicitation. The solicitations for the procurements which are the subject of these consolidated protests contain identical language in Section M, which is entitled "Evaluation Factors for Award." The solicitations require that offerors submit information in their proposals to establish a life cycle price and a life cycle present value cost. The life cycle present value cost was to be determined by multiplying the monthly totals which comprise the life cycle price by specified discount factors set forth the solicitation. Finding 2. These protests arise as the result of protesters' understanding that respondent would base award of the contracts on the life cycle present value cost, and their allegation that the language of Section M was ambiguous regarding the basis for award. VA's Defenses to the Protest The VA maintains that 1) protesters are not interested parties, since they submitted ambiguous BAFOs, 2) in the alternative, if protesters are found to be interested parties, the VA has made award to the appropriate vendors based on the lowest life cycle price in accordance with the clear language of the solicitations.[foot #] 3 Protesters are Interested Parties Respondent presented testimony during the hearing that both protesters' BAFOs were submitted with qualifications and ----------- FOOTNOTE BEGINS --------- [foot #] 3 Respondent alleges additional alternative defenses in the event the solicitations are determined to be ambiguous, including the defense of untimeliness of the protests. As we do not find the solicitations ambiguous, we do not address these alternative defenses. ----------- FOOTNOTE ENDS ----------- mathematical errors, not evident in their initial proposals, and the BAFOs were therefore ambiguous. Findings 20, 21. In its posthearing brief, respondent argues that "[i]f a best and final proposal is so fundamentally and materially deficient that the agency cannot realistically and therefore reasonably ascertain the intended prices, the proposal should be excluded . . . . The Citizens and Southern National Bank, GSBCA 9721- P, 89-1 BCA 21,354, at 107,650, 1988 BPD 291, at 8." Respondent's Posthearing Brief at 10. Board Rule 1(b)(6)[foot #] 4 defines "interested party" as an actual or prospective bidder or offeror whose direct economic interest would be affected by the award of the contract or failure to award the contract. Respondent contends that since protesters' BAFOs were unacceptable, they are not eligible for award, and therefore, protesters' direct economic interests are not affected and they are not interested parties. The contracting officer's testimony as to the alleged ambiguity of protesters' BAFOs and alleged inability to ascertain the intended prices is inconsistent with her other testimony and her course of conduct which indicates that respondent was able to and did evaluate and rank protesters' price proposals. The contracting officer testified that, with regard to RFP 101-18-94, Telecom's proposal ranked based upon either life cycle price or life cycle present value cost. Finding 10. Her letter to the SBA several days before award states that there were a total of proposals in response to the RFP, and firms failed the validation process during BAFO evaluation, primarily caused by errors and omissions on the part of these offerors. Finding 9. As the contracting officer testified that Telecom was ranked out of Finding 10, Telecom apparently was not one of the offerors which failed the validation process. In a similar vein, the contracting officer testified that, with regard to RFP 101-17-94, Northwest's proposal ranked based upon either life cycle price or life cycle present value cost. Finding 7. Her letter to the SBA several days before award states that there were a total of proposals in response to the RFP, and one firm failed to submit a BAFO. Finding 6. There was no mention of any BAFO failing the validation process during BAFO evaluation as the result of errors and omissions. Northwest's life cycle price was mentioned in that letter as the amount stated in its BAFO. Further, the contracting officer's letter stated that the ranking was based upon the Government's "evaluated 10 ----------- FOOTNOTE BEGINS --------- [foot #] 4 58 Fed. Reg. 69,246, 69,251 (Dec. 30, 1993) (to be codified at 48 CFR 6101.1(b)(6). ----------- FOOTNOTE ENDS ----------- year total [life cycle price]" which was stated for Northwest as Id. The evaluated price differs from the price in the BAFO. An evaluation was performed, with no mention of ambiguity, error, or inconsistency as suggested by the contracting officer at the hearing. Thus, it appears that protesters' BAFOs were not so ambiguous or inconsistent as to preclude evaluation. Rather, they were evaluated and ranked. The BAFOs were evaluated without mentioning that protesters' prices for basic monthly maintenance and installation for adds, moves, and changes had not been extended into Table B-5 for both BAFOs, or math errors in Table B-5 of both BAFOs, as suggested by the contracting officer. We have reviewed the alleged math errors in Tables B-5 of both BAFOs, and find that they are easily resolvable by a cursory examination of the BAFOs. Finding 22. Accordingly, we cannot find that protesters are ineligible for award based upon alleged ambiguities in protesters' BAFOs which did not affect respondent's evaluation process. We therefore deny respondent's request to dismiss the protest for lack of interested party status of the protesters. Protesters' Position as to the Alleged Ambiguity of Section M of the Solicitation Protesters admit that Section M of the solicitation is not ambiguous on its face, but contend that the ambiguity was only apparent when they became aware of respondent's interpretation of Section M after contract awards. Protesters' Posthearing Brief at 18. Protesters complain that respondent's awarding the contract based upon life cycle price rather than life cycle present value cost is contrary to protesters' reasonable interpretation of the solicitation. Respondent contends the awards were made in accordance with the requirements of Section M. Protesters' argument is completely without merit. To characterize this dispute as one arising from an ambiguity, one must refuse, as did protesters, to consider the very language at issue -- the clear and unambiguous statement in Section M.2 of both solicitations, which stated that proposals would be "evaluated and awarded to that responsible offeror with the lowest lifecycle price." Finding 2. By their own admission, protesters either overlooked or ignored this key provision of the solicitations, relying only upon Sections M.1 and M.3. Finding 15. Additionally, the clear statement of the basis of award in Section M.2 does not conflict with any other language in the solicitations, including the language of Sections M.1 and M.2. According to respondent, the solicitations clearly provide for award on the basis of life cycle price and not life cycle present value cost. Respondent relies upon all paragraphs in Section M, including the language in paragraph M.2 which states that "proposals meeting mandatory requirements and complying with the Standard Form of Contract will be evaluated and awarded to that responsible offeror with the lowest lifecycle price." Finding 17. In interpreting a solicitation, we read the document as a whole so as to give meaning to all of its provisions. Raytech Engineering, Inc. v. Department of the Navy, GSBCA 12240-P, 93-3 BCA 25,928, 1993 BPD 80. Respondent's interpretation is reasonable and is in accordance with the plain meaning of the language in paragraph M.2, which clearly states that award would be based upon "lifecycle price." In interpreting the solicitation in this manner, respondent considered all portions of Section M, while protesters did not. On the other hand, protesters have failed to consider the solicitation as a whole and do not ascribe any meaning to paragraph M.2, which clearly states the basis of award. Respondent's reading of Section M is obviously the correct one, and would prevail in accordance with well established Board precedent, even if there were an ambiguity only apparent after submission of offers. Federal Systems Group, Inc., GSBCA 9874-P, 89-2 BCA 21,665, 1989 BPD 77; Rocky Mountain Trading Co.--Systems Division, GSBCA 9737-P, 89-1 BCA 21,456, 1988 BPD 307; Perception Technology, GSBCA 9883-P, 89-2 BCA 21,667, 1989 BPD 85; International Business Machines Corp., GSBCA 9703-P, 89-1 BCA 21,389, 1988 BPD 288. Decision The protests are DENIED. ________________________ ALLAN H. GOODMAN Board Judge We concur: ________________________ ________________________ EDWIN B. NEILL MARTHA H. DeGRAFF Board Judge Board Judge