Aar Government Services, Inc. v. United States

CourtUnited States Court of Federal Claims
DecidedFebruary 25, 2026
Docket25-1488
StatusPublished

This text of Aar Government Services, Inc. v. United States (Aar Government Services, Inc. v. United States) is published on Counsel Stack Legal Research, covering United States Court of Federal Claims primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Aar Government Services, Inc. v. United States, (uscfc 2026).

Opinion

In the United States Court of Federal Claims BID PROTEST

) AAR GOVERNMENT SERVICES, INC., ) ) Plaintiff, ) ) No. 25-1488C v. ) (Filed Under Seal: February 6, 2026 ) Reissued: February 25, 2026) ∗ UNITED STATES OF AMERICA, ) ) Defendant, ) ) and ) ) V2X AEROSPACE LLC, ) ) Defendant-Intervenor. ) )

Caitlin Therese Conroy, Steptoe LLP, Washington, DC, with whom were Paul R. Hurst, Anna M. Menzel, and Shannon Reid, Of Counsel, for Plaintiff.

Blake William Cowman, U.S. Department of Justice, Washington, DC, with whom were Corinne A. Niosi, Patricia M. McCarthy, and Brett A. Shumate, for Defendant. LeDara Y. Clark and Maj. Princess Gaye, United States Air Force, Joint Base Andrews, MD, Of Counsel.

Kayleigh Marie Scalzo, Covington & Burling LLP, Washington, DC, with whom were Jason A. Carey, J. Hunter Bennett, Andrew R. Guy, and Victoria A. Skiera, Of Counsel, for Defendant- Intervenor.

OPINION AND ORDER

KAPLAN, Judge.

In this post-award bid protest, Plaintiff AAR Government Services, Inc. (“AAR”) challenges the decision of the United States Air Force (the “Air Force,” or “Agency”) to award Defendant-Intervenor V2X Aerospace LLC (“Vertex”) a contract to provide Contractor Operated and Maintained Base Supply (“COMBS”) services under Request for Proposals (“RFP”) No. FA8106-23-R-1000 (the “Solicitation”). AAR contends that the Agency’s price reasonableness analysis, its evaluation of AAR’s past performance, its evaluation of Vertex’s past performance,

∗ This opinion was originally issued under seal, and the parties were given the opportunity to

request redactions. Each party requested redactions which the Court has adopted. and its best value determination were arbitrary and capricious. See generally Pl.’s Mot. for J. on the Admin. Rec, ECF No. 39 [hereinafter Pl.’s MJAR].

On January 30, 2026, the Court ruled on the parties’ cross-motions for judgment on the administrative record (“MJARs”), denying AAR’s motion and granting the motions of the government and Vertex. ECF No. 47. What follows is an explanation of that ruling.

BACKGROUND

I. The Solicitation

A. Overview

This protest arose out of the Air Force’s award of the COMBS IV contract to Vertex. The RFP sought proposals for the provision of COMBS services for a fleet of over seven hundred military aircraft across a dozen locations, including bases and depots in the southern United States. AR Tab 61 at 68076. Contractors would be required to “provide a full spectrum of transparent Supply Chain Management [] services to support safe, flyable aircraft to meet users’ daily flight schedule and depot requirements.” AR Tab 79 at 72090. These services, which the Air Force has deemed “mission essential,” included “managing supply and demand, sourcing parts, assembly, disposal, warehousing and inventory tracking, order entry and order management, distribution across all channels, and delivery to the customer.” Id.

The Solicitation anticipated the award of a single, firm-fixed price, indefinite delivery/indefinite quantity contract with a five-year base period, a four-year option period, and a six-month option to extend services. AR Tab 61 at 68076–77. An award would be made to the offeror that represented the best value to the government. AR Tab 71b at 71827. The RFP cautioned that the best value determination “may result in an award to a higher rated, higher priced Offeror, where the decision is consistent with the evaluation factors, and the Source Selection Authority (SSA) reasonably determines the technically acceptable proposal, and superior past performance of the higher priced offeror outweighs the price difference with lower priced offerors.” Id.

B. Evaluation Factors

Proposals would be evaluated under three factors: Factor 1: Technical; Factor 2: Past Performance; and Factor 3: Price. Id. at 71829. “Technical acceptability [would be] a prerequisite to the best value analysis and potential trade-off between Past Performance and Price. Id. Further, “for all technically acceptable proposals,” the Past Performance factor would be considered “significantly more important” than Price. Id.

1. Technical Evaluation

The evaluation of the Technical factor would be based on three subfactors: Program Management, Supply Chain Management, and Inventory Data Management and Reporting. The proposal would be rated either acceptable or unacceptable. Id. at 71829–31. “[T]echnical acceptability [was] a prerequisite to the best value analysis and potential trade-off between Past

2 Performance and Price.” AR Tab 36k at 975; see also AR Tab 82 at 74304–06 (proposal instructions for Technical factor).

2. Past Performance

The Past Performance evaluation was designed to assess “the degree of confidence the [Air Force had] in an offeror’s ability to supply products and services that meet users’ needs, including cost and schedule, based on a demonstrated record of performance.” AR Tab 71b at AR 71831. In conducting that evaluation, the Agency would consider the recency, relevancy, and quality of offerors’ past performance, relying on both information the offeror provided and data obtained from other sources. Id. at 71832–35; AR Tab 82 at 74306–09.

The RFP instructed offerors to submit up to three Past Performance Information Forms (“PPIFs”) for themselves and three PPIFs for each significant subcontractor. AR Tab 82 at 74308. 1 For each PPIF, offerors were to “provide a narrative explaining what aspects of the contract [were] deemed relevant to the proposed effort, and to what aspects of the proposed effort they relate.” Id. 2

Under the RFP, only recent past performance would be considered. “To be recent, the effort must have been performed during the past three (3) years.” AR Tab 71b at 71832. In addition, “[i]f any part of the performance [fell] within the [three-year] timeframe, the contract in its entirety [could] be evaluated for past performance.” Id.

The RFP specified that “[m]ore relevant performance [would] have a greater impact on the Performance Confidence Assessment than less relevant effort.” Id. at 71835. The Agency would determine relevancy by comparing the scope, magnitude, complexity, and price of offerors’ performance examples to the T-6 COMBS IV contract requirements. Id. at 71833. Scope encompassed factors such as the number of sites and subcontractors on a project. See id. Magnitude concerned the “[d]ollar value of parts managed,” “[s]ize of parts inventory managed,” “[s]ize of aircraft fleet(s),” and “[c]ontract value.” Id. at 71834. Complexity would be “based on, but not limited to, the similarities between a given Past Performance effort and the technical subfactors.” Id. Finally, relevancy concerning price would be assessed primarily based on the similarity of the contract type to the COMBS requirement. Id.

Each past performance example would be assigned an overall relevancy rating as follows:

1 The RFP defined a “significant subcontractor” as “a contractor who is proposed to perform over 5% of the total effort, or a contractor who is proposed to perform less than 5% of the total effort but is determined to be performing a critical function.” AR Tab 82 at 74308. 2 “The requested number of PPIFs for the prime and subcontractors are preferences and not requirements. Offerors may submit more than the preferred number if the Offeror believes the extra contracts are needed to fully describe their relevancy.” AR Tab 82 at 74308.

3 addition of escalation to account for inflation/economic uncertainty and risk factors, as applicable.” Id.

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