East Coast Flight Services, Inc. (HTC711-25-R-C004)

B-423977 Jan 07, 2026 Jump To VIEW DECISION DOWNLOADS RELATED PAGES GAO CONTACTS Highlights East Coast Flight Services, Inc. (ECFS), a small business of Easton, Maryland, protests the award of a contract to CSI Aviation, Inc., a small business of Killeen, Texas, under request for proposals (RFP) No. HTC711-25-R-C004, issued by the Department of the Air Force, for fixed-wing services. The protester contends that the agency unreasonably evaluated proposals, resulting in a flawed source selection decision. We dismiss the protest because, as filed with our Office, it does not establish a valid basis for challenging the agency's action. View Decision Decision Matter Of: East Coast Flight Services, Inc. File: B-423977 Date: January 7, 2026 Edward C. Ambler for the protester.  Jennifer S. Zucker, Esq., and Christopher O'Brien, Esq., Greenberg Traurig, LLP, for CSI Aviation, Inc., the intervenor.  Colonel Justin A. Silverman, and Kelsi Pilcher, Esq., Department of the Air Force; and Todd P. Federici, Esq. and Adam J. Koudelka, Esq., United States Transportation Command, for the agency.  Jacob M. Talcott, Esq., and Heather Weiner, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.  DIGEST 1. Protest challenging the award of a contract solely on basis that the awardee's proposal was higher‑priced is dismissed as legally insufficient where the solicitation expressly permitted award of a higher technically rated proposal with a higher price. 2. Protest alleging that the unsuccessful offeror notice contained incorrect information is dismissed as legally insufficient because post-award notices are procedural matters that are unrelated to the validity of the award. 3. Protest alleging that the agency unreasonably evaluated the protester's past performance is dismissed as legally insufficient where the solicitation precluded the agency from considering the protester's references where they were outside of the 3‑year window permitted by the solicitation. DECISION East Coast Flight Services, Inc. (ECFS), a small business of Easton, Maryland, protests the award of a contract to CSI Aviation, Inc., a small business of Killeen, Texas, under request for proposals (RFP) No. HTC711-25-R-C004, issued by the United States Transportation Command (USTRANSCOM), for fixed-wing services. The protester contends that the agency unreasonably evaluated proposals, resulting in a flawed source selection decision. We dismiss the protest because, as filed with our Office, it does not establish a valid basis for challenging the agency's action. BACKGROUND On March 18, 2025, in accordance with Federal Acquisition Regulation (FAR) part 15, USTRANSCOM issued the RFP as a set-aside for small businesses. RFP at 1. The solicitation anticipated the award of a contract for fixed-wing services. RFP at 1; Req. for Dismissal at 1. The solicitation provided for award on a best-value basis, using a tradeoff process considering the following factors: business proposal, technical capability, past performance, and price. RFP at 2. The agency received timely proposals from both ECFS and CSI. Req. for Dismissal at 2. On September 18, 2025, USTRANSCOM notified the protester that award had been made to CSI in the amount of $20,162,235. Req. for Dismissal, Attach. 3, Unsuccessful Offeror Notice at 1. After requesting and receiving a debriefing on September 22, 2025, ECFS filed this protest with our Office. Protest, attach. 4, Debriefing at 1. DISCUSSION ECFS sets forth the following in its protest: (1) the award “appears to constitute government waste”; (2) the unsuccessful offeror notice contained incorrect information concerning ECFS's proposal; (3) ECFS has five years of experience on a prior contract for these services from “August of 2015 to December [2020]”[1]; and (4) ECFS received a past performance rating of satisfactory confidence and the awardee received a rating of substantial confidence. Id. The agency filed a request for dismissal of the protest in its entirety, arguing that the protest fails to provide “any facts or legal basis regarding [a]gency error.” Req. for Dismissal at 1. For the reasons discussed below, we dismiss all four arguments as legally insufficient.[2] Our Bid Protest Regulations, specifically 4 C.F.R. § 21.1(c)(4) and (f), require that a protest include a detailed statement of the legal and factual grounds of protest, and that the grounds stated be legally sufficient.  This requirement contemplates that protesters will provide, at a minimum, credible allegations that are supported by evidence and are sufficient, if uncontradicted, to establish the likelihood of the protester's claim of improper agency action.  Warfighter Focused Logistics, Inc., B-423546; B-423546.2, Aug. 5, 2025, 2025 CPD ¶ 169 at 4. Price Evaluation ECFS asserts that the difference between its price and the awarded price “appears to constitute government waste.” Protest at 1.