The U.S. Government Accountability Office has rejected a protest challenging a $77.6 million U.S. Air Force task order, concluding that the losing bidder failed to justify labor rates the agency found unrealistically low.
The protest was filed by Texas-based contractor T3i Inc., which submitted a proposal priced roughly $3.9 million below the winning bid from LMR Technical Group LLC. Despite the lower overall cost, the Air Force determined that T3i’s proposal contained wage figures for multiple positions that did not reflect realistic market conditions.
According to the GAO’s decision, Air Force evaluators identified 25 positions in T3i’s submission where unburdened hourly labor rates were significantly below expected benchmarks. The agency concluded that those figures posed performance risk for the aircrew training support program covered by the task order.
T3i argued that its pricing should have been evaluated alongside a narrative explaining its technical approach and staffing efficiencies. The GAO disagreed, noting that the solicitation did not require a detailed technical analysis as part of the price realism review.
Absent explicit solicitation language mandating a particular evaluation method, the GAO said agencies retain broad discretion when assessing whether proposed prices are realistic for successful performance.
The Air Force issued the task order request in May to support its comprehensive aircrew flying training readiness program. The contract requires staffing 129 full-time equivalent positions across 13 locations nationwide. Under the solicitation, the award was to go to the lowest-priced proposal deemed fair, balanced, and realistic.
While T3i also challenged the Air Force’s reliance on market salary data drawn from a comparable occupational category, the GAO found the agency’s approach reasonable. The decision noted that the selected comparison reflected similar education requirements, responsibilities, and compensation expectations, and that no closer equivalent category was available.
The ruling marks another example of the GAO deferring to agency judgment in price realism evaluations, particularly when a protester cannot demonstrate that the evaluation violated the terms of the solicitation.
