Mvl USA, Inc. v. United States

In the United States Court of Federal Claims No. 25-1664 (Filed Under Seal: September 28, 2026) (Reissued for Publication: October 15, 2026) 1 *************************************** MVL USA, INC., * * Plaintiff, * * v. * * THE UNITED STATES, * * Defendant. * *************************************** Joseph L. Cohen, Burr & Forman LLP, Chicago, IL, counsel for Plaintiff. With whom were Kelsey M. Hayes, and David P.J. Timm, Washington, DC, of counsel. Alexander S. Brewer, U.S. Department of Justice, Civil Division, Washington, DC, counsel for Defendant. With whom was Lt Col Jeffrey Hannon, Department of the Air Force, of counsel. OPINION AND ORDER DIETZ, Judge. MVL USA, Inc. (“MVL”) protests a decision by the United States Department of the Air Force (“Air Force”) to award indefinite delivery/indefinite quantity (“IDIQ”) contracts to twelve offerors under Request for Proposal (“RFP”) No. FA890324R0023 for the worldwide Comprehensive Construction & Engineering (“C2E”) multiple award task order contract (“MATOC”). MVL argues that the Air Force relied upon an inadequately supported independent government estimate (“IGE”), that the Air Force conducted a flawed price reasonableness analysis, and that the Air Force failed to conduct a proper unbalanced pricing analysis. For the reasons set forth below, the Court finds that the Air Force’s IGE had a rational basis, but that its price reasonableness analysis was arbitrary and prejudicial, and that its unbalanced pricing analysis was arbitrary and contrary to law but not prejudicial. Accordingly, the Court GRANTS- IN-PART and DENIES-IN-PART MVL’s motion for judgment on the administrative record (“MJAR”), [ECF 34], and GRANTS-IN-PART and DENIES-IN-PART the government’s cross-MJAR, [ECF 38]. 1 This Opinion and Order was filed under seal on September 28, 2026, see [ECF 50], in accordance with the Protective Order entered on December 12, 2025, see [ECF 18]. The parties were given an opportunity to identify protected information, including source selection information, proprietary information, and confidential information, for redaction. The parties filed a joint status report on October 7, 2026, with proposed redactions. [ECF 52]. The Court accepts the parties’ proposed redactions. All redactions are indicated by bracketed asterisks, e.g., “[* * *].” I. FACTUAL BACKGROUND On July 27, 2023, the Air Force held an acquisition strategy panel to discuss the C2E requirement. AR 467. 2 In the panel briefing slides, the Air Force stated that the C2E requirement “is a follow-on IDIQ that continues to satisfy existing/ongoing requirements to support design and construction of new facilities [and] infrastructure; [and to] repair, renovate and/or restore existing facilities and infrastructure[.]” AR 473. The briefing explained that the impending expiration of the then-existing Regional Engineering and Construction (“RE&C”) and Worldwide Engineering and Construction (“WE&C”) contract vehicles necessitated the development of the C2E requirement. See AR 473. In July 2024, the Air Force issued the RFP for the C2E requirement as a best value procurement pursuant to Federal Acquisition Regulation (“FAR”) Part 15. AR 745, 891-92. It was amended six times. AR Tabs 15-20. 3 The RFP included a potential ten-year period of performance with a base ordering period of five years and five one-year option periods. AR 1658. According to the RFP, the Air Force “intend[ed] to make twelve (12) awards” to offerors in the full and open (“F&O”) competition category. 4 AR 1633. The RFP described its evaluation methodology as follows: The [Air Force] will utilize a highest technically rated offeror [(“HTRO”)] methodology. The HTRO method requires the offeror to score itself based on the objective criteria described in Section L – Instructions, Conditions, and Notices to Offerors or Respondents. The offerors’ proposals will be ranked based on initial self-scoring in the offeror completed Section L, Appendix L-05, which includes weighting for each factor. The [Air Force] will sort all proposals from the highest self-rated offeror to the lowest self-rated offeror. The [Air Force] will validate the highest proposed self-scores to fulfill . . . the F&O awards. If an offeror’s self-score is downward adjusted because of [Air Force] validation, and the offeror is no longer among the highest rated offerors, then the [Air Force] will validate the next highest self-rated offeror, until . . . the F&O awards are fulfilled with the highest government-validated scores (see paragraph 4.0 of this Section M). The [Air Force] will evaluate for small business participation acceptability (F&O Only) (see paragraph 5.0 of this Section M) and price reasonableness, completeness, and balance (see paragraph 6.0 of this Section M). If an offeror is found unacceptable in small business participation or is found to have unreasonable, incomplete or unbalanced pric[ing], the 2 The Court cites to the administrative record filed by the government at [ECFs 21, 30, 35, 41, 44] as “AR ___” and cites to tabs within the administrative records as “AR Tab ___.” When quoting from the administrative record, the Court omits unnecessary capitalization. 3 The Court cites Amendment 0005 when discussing Section M of the RFP because Amendment 0006 does not include Section M. See generally AR Tab 20. 4 The RFP also contemplated making fifteen awards to offerors in the small business set aside category. AR 1632. 2  [Air Force] will validate the next highest self-rated offeror and then evaluate that offeror for small business participation acceptability and price reasonableness, completeness, and balance. *** [T]he F&O offerors with a combination of the HTRO, past experience ratings and a complete, balanced, and reasonable price will represent the best value to the government. AR 1635. The RFP also stated that the Air Force will conduct “an integrated assessment of the proposals, . . . [however,] the [HTRO] evaluation methodology is not a tradeoff.” AR 1632. It further explained that the Air Force, “either without discussions or after discussions occur, will award basic contracts . . . [to] the F&O offerors with a combination of the HTRO, past experience ratings and a complete, balanced, and reasonable price[.]” AR 1635. The instant protest relates to the Air Force’s evaluation of price under the RFP— specifically its analysis of price reasonableness and price balance. Regarding the price factor, the RFP stated that the Air Force “will evaluate the proposed [Total Evaluated Price (“TEP”).]” AR 1638. It explained that “[t]he TEP is automatically calculated in Appendix L-08 Labor Rates Table when proposed [not-to-exceed (“NTE”) firm-fixed-price (“FFP”)] fully burdened labor rates are entered in the applicable cells.” Id.; see also AR 1758, 1773, 1775 (requirement to submit proposed hourly labor rates for all labor categories in Section L Appendix L-08 Labor Rates Table). Upon entry of the proposed NTE FFP fully burdened labor rates by the offeror, “the hours provided by the [Air Force] are multiplied by the . . . labor rates for the predetermined mix of labor categories across all years of the ordering periods[.]” AR 1638. “The sum of these hours applied to the offeror’s proposed . . . labor rates for each labor category across all years determines the TEP.” Id. The RFP advised that “the [labor] rates proposed by the offeror will become contractually binding . . . should the offeror be awarded a contract.” Id. It further stated that the “labor rates are ceiling rates and shall be utilized for future competitive task orders, single-source task orders, and task order modifications that utilize fixed-price pricing structure; however, when competing for task orders, discounted or lower rates may be proposed.” Id. Regarding price reasonableness, the RFP stated that the Air Force “will evaluate the proposed [TEP] for reasonableness using the techniques described in FAR 15.404-1,” AR 1639, and that “[g]enerally, the government may rely upon adequate price competition to establish fair and reasonable price and may use adequate price competition as the basis for the fair and reasonable price determination at both the IDIQ and [task order] levels,” id. It further stated that, “[f]or the [Air Force] to determine a TEP to be reasonable, the TEP must represent a price . . . that does not exceed the price a prudent person would pay in the conduct of competitive business.” Id. Regarding price balance, the RFP “cautioned against submitting an unbalanced offer,” AR 1638, and stated that the Air Force “will analyze offers to determine whether they are unbalanced with respect to price,” id. The RFP further stated: Per FAR 52.215-1(f)(8), the [Air Force] may determine that a proposal is unacceptable if the prices proposed are materially 3  unbalanced between line items or subline items. Unbalanced pricing exists when, despite an acceptable [TEP], the price of one or more contract line items is significantly overstated or understated as indicated by the application of cost or price analysis techniques. The [Air Force] may also consider an offer unbalanced if there is a significant difference between proposed prices from year to year, including option years, such that they are above or below what would be considered a reasonable adjustment for inflation. A proposal may be rejected if the contracting officer determines that the lack of balance poses an unacceptable risk to the [Air Force]. AR 1638-39. On November 7, 2024, the Air Force received nineteen proposals in response to the RFP. AR 18046. Once the Air Force completed its initial evaluations, it determined that “[d]iscussions were required to have enough offerors [found] acceptable for [small business participation] as originally only four of the [sixteen] evaluated proposals were acceptable.” AR 16448. Because “all proposals had prices that were complete, balanced and reasonable, . . . price was not a part of the discussions.” Id. Discussions occurred from May 22, 2025, through August 5, 2025. Id. Thereafter, the Air Force “tentatively determined [that MVL’s small business participation was] acceptable,” AR 16434, and it ranked MVL thirteenth out of sixteen proposals, AR 16410, 16442-43. On August 14, 2025, the offerors submitted final proposal revisions. AR 18046. After evaluating the final proposals, the Source Selection Evaluation Board (“SSEB”) concluded that all the proposed pricing was “evaluated and determined to be complete, balanced, and reasonable by the pricing analyst and the [contracting officer].” AR 18133. The SSEB also concluded that all the proposals were acceptable under the small business participation factor, except MVL’s proposal. Id. According to the SSEB, “MVL omitted the required information in their [small business subcontracting plan] that they had previously submitted in discussions [and that] [t]herefore, the MVL small business subcontracting plan is determined unacceptable.” Id. However, the SSEB noted that “[i]f MVL were considered within the HTRO and therefore, an ‘apparently successful offeror[,’] this error in the small business subcontracting plan could be remedied as part of the contracting officer’s responsibility determination process.” Id. Thereafter, “[t]he SSEB recommend[ed] award to the top [twelve] [HTROs] with acceptable small business participation and complete, balanced, and reasonable pric[ing].” AR 18134. The SSEB’s recommendation did not include MVL, id., which finished fourteenth in the final validated scores, AR 18078. Next, the Source Selection Advisory Council (“SSAC”) “reviewed the SSEB’s evaluation and findings to ensure their accuracy, consistency, and supportability in accordance with the evaluation criteria” and concurred with the evaluation and findings. AR 18135. The SSAC unanimously recommended that the top twelve offerors receive contract awards. Id. The Source Selection Authority then conducted an “extensive review of the documentation and [consulted] with the [SSAC], [SSEB], and [his] advisors [and] determined that the proposals submitted by 4 the [] [twelve] [HTRO] . . . represent the best value to the Air Force as described in the C2E [RFP].” AR 16446. On September 22, 2025, the Air Force issued a debriefing to MVL. AR 18033. In the debriefing, the Air Force informed MVL that it “was not selected for award,” id., because its “proposal[] ranked [fourteenth] out of the validated offerors,” AR 18034. Shortly thereafter, the Air Force issued contracts to the twelve HTROs. AR 16536 (executed contract for ECC Expeditionary Constructors LLC); AR 16666 (same for Gilbane Federal JV); AR 16796 (same for Tutor Perini Corporation); AR 16843 (same for CMS COLAS Construction LLC); AR 17053 (same for CDM Constructors Inc.); AR 17184 (same for Flatiron Dragados Constructors, Inc.); AR 17314 (same for Parsons Government Services Inc.); AR 17361 (same for Contrack Watts Inc.); AR 17573 (same for SSLSCO, Ltd.); AR 17704 (same for Bering-Weston JV, LLC); AR 17835 (same for Exp Federal Inc.); AR 17966 (same for Hensel Phelps Construction Co.). II. PROCEDURAL HISTORY On October 6, 2025, MVL filed a complaint in this court challenging the Air Force’s award decision. Compl. [ECF 1]. The Court held an initial status conference on October 8, 2025. See [ECF 6]. During the conference, MVL stated that it would not seek preliminary injunctive relief “unless the [Air Force] issues a material task order with a value exceeding $35,000,000.” [ECF 7]. Additionally, the government advised “that it planned to file a motion to stay the proceedings in this case due to the lapse in appropriations” to fund the Department of Justice, which MVL did not oppose. Id. As part of its motion to stay, the government “agreed to provide additional details on the status of the [C2E] procurement . . . , including the potential for a voluntary stay in contract performance.” Id. On October 10, 2025, the government filed an unopposed motion to stay the case. [ECF 8]. In its motion, the government stated the following: The . . . Air Force does not anticipate awarding any task order under the [C2E] worldwide [IDIQ] [MATOC] during the pendency of the lapse in appropriations. If the . . . the Air Force intends to award a task order greater than thirty-five million dollars ($35,000,000.00) to any C2E MATOC awardee under the C2E MATOC during the pendency of the lapse in appropriations, the government will notify [MVL] prior to award. Id. at 2. 5 The Court granted the motion to stay. [ECF 9]. On November 14, 2025, the government informed the Court that appropriations had been restored, [ECF 10], and on November 17, 2025, the Court lifted the stay and ordered the parties to file a joint status report with a proposed schedule for further proceedings. 5 The Court cites to the filings on the docket using the page numbers generated by the CM/ECF system. When quoting from the filings on the docket, the Court omits unnecessary capitalization. 5  On December 2, 2025, the parties filed a joint status report with a proposed briefing schedule. [ECF 14]. The parties also agreed on the following regarding a voluntary stay of performance: The . . . Air Force may award a task order under the [C2E] worldwide [IDIQ] [MATOC] to any small business set-aside awardees during the pendency of these proceedings. If the . . . Air Force intends to award a task order greater than thirty-five million dollars ($35,000,000) to a[n] [F&O] competition C2E MATOC awardee under the C2E MATOC during the pendency of these proceedings, the government will notify [MVL] reasonably in advance of making an award. Id. at 2. The Court adopted the proposed schedule on December 5, 2025. [ECF 15]. The government filed an unopposed motion to amend the schedule on January 5, 2026, to request additional time for filing the administrative record. [ECF 19]. The next day, the Court granted the requested additional time and adopted the revised schedule. [ECF 20]. The government filed the administrative record on January 20, 2026. [ECFs 21-22]. On February 3, 2026, MVL filed an unopposed motion to amend the schedule because it was “conferring [with the government] concerning potential settlement and [] discuss[ing] the completeness of the administrative record[,] . . . [which] necessitate[d] an enlargement of time[.]” [ECF 26] at 1-2. The Court granted MVL’s motion and adopted the amended schedule on February 6, 2026. [ECF 27]. On February 24, 2026, MVL filed another motion to amend the schedule. [ECF 28]. In the motion, MVL stated as follows: On February 4, 2026, the government agreed to provide additional documents omitted from the administrative record. On February 12, 2026, [MVL] discovered that the government also failed to include the individual evaluator worksheets in the administrative record. The parties conferred and the government acknowledged the omission and promised to provide the same. On February 23, 2026, the government provided the [forty-eight] omitted worksheets. As of the date of this filing, the government has not yet provided the final certification of the completeness of the record. Id. at 2. The Court granted the amended schedule on March 3, 2026. [ECF 29]. Thereafter, on March 6, 2026, the government filed the corrected administrative record. [ECF 30]. MVL filed another motion to amend the schedule on March 24, 2026, to allow additional time for the government “to formally correct the administrative record with the documents” related to the IGE. [ECF 31] at 2. The Court granted this motion on March 31, 2026. [ECF 32]. On April 8, 2026, MVL filed its MJAR, [ECF 34], and a motion to amend its complaint “to conform its bid protest complaint to the arguments in its [MJAR],” [ECF 33]. On April 23, 2026, the government filed an unopposed motion to correct the administrative record to include “missing documents . . . related to the [IGE],” [ECF 35] at 1, and an unopposed motion to amend 6 the schedule, [ECF 36]. The Court granted both unopposed motions on April 27, 2026. [ECF 37]. Thereafter, the government filed its cross-MJAR, [ECF 38], on May 8, 2026, and an unopposed motion to supplement the administrative record, [ECF 41], on May 28, 2026. 6 The MJARs are fully briefed, Pl.’s Reply & Resp. [ECF 39]; Def.’s Reply [ECF 42], and the Court held oral argument on June 3, 2026, see [ECF 37]. 7 III. STANDARD OF REVIEW The Tucker Act grants this court jurisdiction “to render judgment on an action by an interested party objecting to a solicitation by a Federal agency for bids or proposals for a proposed contract or to a proposed award or the award of a contract or any alleged violation of statute or regulation in connection with a procurement or a proposed procurement.” 28 U.S.C. § 1491(b)(1). This waiver of sovereign immunity “covers a broad range of potential disputes arising during the course of the procurement process,” including objections to an award decision by a federal agency. Sys. Application & Techs., Inc. v. United States, 691 F.3d 1374, 1380-81 (Fed. Cir. 2012) (citations omitted). “When proceedings before an agency are relevant to a decision in a case, the administrative record of those proceedings must be . . . filed with the court.” RCFC 52.1(a). Parties may then “file a[n] [MJAR] for the Court to assess whether [the agency], given all disputed and undisputed facts in the record, acted in compliance with the legal standards governing the decision under review.” Agile Def., Inc. v. United States, 143 Fed. Cl. 10, 17 (2019) (citations omitted); see also Palantir USG, Inc. v. United States, 904 F.3d 980, 989 (Fed. Cir. 2018) (“In deciding [cross-motions under Rule 52.1(c) of the Rules of the United States Court of Federal Claims (“RCFC”)], the court considers ‘whether, given all the disputed and undisputed facts, a party has met its burden of proof based on the evidence in the record.’” (quoting A & D Fire Prot., Inc. v. United States, 72 Fed. Cl. 126, 131 (2006))). This procedure is “designed to provide for trial on a paper record, allowing fact-finding by the [] court.” Bannum, Inc. v. United States, 404 F.3d 1346, 1356 (Fed. Cir. 2005)). When a party challenges an agency’s contract award decision, the court reviews the decision using the standard of review set forth in the Administrative Procedure Act (“APA”), 28 U.S.C. § 1491(b)(4), which states that “the courts shall review the agency’s decision pursuant to the standards set forth in section 706 of title 5.” Section 706 provides that “the reviewing court shall . . . hold unlawful and set aside agency action, findings, and conclusions found to be . . . arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law.” 5 U.S.C. § 706. “In applying the APA to protests . . . [the court] determine[s] whether ‘(1) the 6 In its motion to supplement, the government seeks to “[s]upplement[] the administrative record with [AR] Tab 111’s native Excel file . . . because metadata of [AR] Tab 111 is not addressed in the administrative record and is necessary so that the Court can conduct ‘meaningful judicial review.’” [ECF 41] at 2-3 (quoting Axiom Res. Mgmt. v. United States, 564 F.3d 1374, 1379-80 (Fed. Cir. 2009)). 7 On September 18, 2026, MVL filed a motion requesting that “the Court [] issue a [temporary restraining order] to prevent the [Air Force] from making three awards in excess of $35 million dollars without reasonable advance notice to MVL, in violation of the parties’ agreement.” [ECF 45] at 1. The government filed a response opposing the request on September 24, 2026, [ECF 49], in which “[t]he government assert[ed] that [such an order] would cause widespread logistical, regulatory, and mission-support harm to the United States, such that MVL cannot prevail on a balance of harms analysis, nor can MVL show that [such an order] is in the public interest,” id. at 6. The government attached three declarations to its response. [ECFs 49-1, 49-2, 49-3]. The Court held a hearing on September 25, 2026. [ECF 48]. During the hearing, MVL voluntarily withdrew its request for a temporary restraining order. 7 procurement official’s decision lacked a rational basis; or (2) the procurement procedure involved a violation of regulation or procedure.’” Weeks Marine, Inc. v. United States, 575 F.3d 1352, 1358 (Fed. Cir. 2009) (quoting PGBA, LLC v. United States, 389 F.3d 1219, 1225 (Fed. Cir. 2004)); see also Motor Vehicle Mfrs. Ass’n of U.S. v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43 (1983) (stating that the court will not uphold an agency decision where the agency “relied on factors which Congress has not intended it to consider, entirely failed to consider an important aspect of the problem, offered an explanation . . . counter to the evidence before [it], or is so implausible [] it could not be ascribed to a difference in view or the product of agency expertise”). The standard of review is “highly deferential,” Advanced Data Concepts, Inc. v. United States, 216 F.3d 1054, 1058 (Fed. Cir. 2000), however, “[w]henever a procurement decision is without a rational basis or is based upon a clear violation of law, that decision must be set aside,” FirstLine Transp. Sec., Inc. v. United States, 100 Fed. Cl. 359, 376 (2011). “[T]o prevail in a protest[,] the protester must show not only a significant error in the procurement process, but also that the error prejudiced it.” Data Gen. Corp. v. Johnson, 78 F.3d 1556, 1562 (Fed. Cir. 1996) (citations omitted); see also Bannum, Inc., 404 F.3d at 1351 (stating that “[a] bid protest proceeds in two steps,” with the court first “determin[ing] whether the government acted without rational basis or contrary to law when evaluating the bids and awarding the contract,” and then “determin[ing], as a factual matter, if the bid protester was prejudiced by that conduct”). “[T]o establish prejudice, a protester must show that, had it not been for the alleged error in the procurement process, there was a reasonable likelihood that the protester would have been awarded the contract.” Data Gen. Corp., 78 F.3d at 1562. A plaintiff must establish that an error was prejudicial before a court “set[s] aside a bid award, regardless of whether the error identified . . . was arbitrary and capricious action or . . . a violation of law.” Sys. Stud. & Simulation, Inc. v. United States, 22 F.4th 994, 997 (Fed. Cir. 2021) (citing DynCorp Int’l, LLC v. United States, 10 F.4th 1300, 1308 n.6 (Fed. Cir. 2021)). Accordingly, “there is no presumption of prejudice when a protestor demonstrates irrationality in an agency decision.” Id. at 998. IV. DISCUSSION MVL raises three challenges to the Air Force’s price analysis. MVL argues that the Air Force relied upon an IGE that was not supported by the administrative record, that the Air Force conducted a flawed price reasonableness analysis, and that the Air Force failed to properly evaluate the offerors’ proposals for unbalanced pricing. As explained below, the Court finds that while the Air Force’s IGE was adequately supported, its price reasonableness analysis was arbitrary, and its unbalanced pricing analysis was arbitrary and contrary to law. The Court also finds that, despite establishing that the Air Force’s flawed price reasonableness analysis was prejudicial, MVL has not done so for the Air Force’s improper unbalanced pricing analysis. A. The Air Force’s IGE was Adequately Supported MVL argues that the IGE used by the Air Force to conduct its price reasonableness and unbalanced pricing analysis “is unsupported by the [] administrative record.” [ECF 34] at 19 (emphasis omitted). It states that “after several requests . . . to correct the administrative record, [the Air Force] finally located and produced an Excel version of the IGE (which appears to be a 8 draft),” id. (citations omitted), and that “[i]n ‘support’ of the IGE, the [Air Force] included a September 2024 email thread (‘C2E Pricing Model IGE’) and an undated ‘pricing research’ spreadsheet, id. (citations omitted). According to MVL, the email thread “reveals that the [Air Force] immediately expressed a lack of confidence in the IGE, flagged the IGE as potentially problematic, and considered the rates used in the IGE to be ‘really elevated.’” Id. at 19-20 (quoting AR 18213). MVL contends that the Air Force “seemingly based the IGE on ‘[Fiscal Year (“FY”)]25 rates for current contractors that received recent modifications or [are] awaiting modifications,’” id. at 19 (quoting AR 18213), and that “[t]hese rates were supposedly compared against actual contractor rates from two distinct efforts . . . but the present administrative record fails to identify those efforts or describe how those efforts are similar to the solicited C2E effort,” id. (citation omitted). MVL also argues that “absent from the record is documentation or analysis regarding how the [Air Force] prepared the IGE.” Id. at 20. In response, the government asserts that the “administrative record demonstrates that the IGE was rationally calculated,” [ECF 38] at 23 (emphasis omitted), because “[t]he Air Force used the predecessor contract vehicles, the WE&C and RE&C, fully burdened labor rate[] obligations[,] . . . calculated the labor rates to create the IGE by using ‘FY25 rates for current contractors that received recent modifications or [are] awaiting modifications’ . . . [and] then used ‘around [***]% of the high values of the senior level positions for each labor rate [in the IGE],’” id. (emphasis omitted) (quoting AR 18213). The government further asserts that “the calculated labor rates [are] explained by . . . the pricing research worksheet that the Air Force used to create the labor rates for the IGE.” Id. The government states that “[t]he administrative record does not contain any notion that the labor rates used in the IGE were unreasonably high,” id. at 25, and that MVL “fail[s] to adequately challenge the validity of the labor rates used in either RE&C and WE&C, or the Air Force’s decision to use [***]% of the high rates of those contract vehicles,” id. at 26. The record shows that the Air Force’s IGE has a rational basis. “[A]n IGE need not be supported with exhaustive details, [however,] the agency must be able to demonstrate the basis for the estimate, where . . . , the analysis is questioned.” Nutech Laundry & Textile, Inc. v. United States, 56 Fed. Cl. 588, 594 (2003). The court must be able to establish a rational connection between the IGE and the administrative record to ensure that it does not contain irrational assumptions. See id. at 595 (citing Overstreet Elec. Co., Inc. v. United States, 47 Fed. Cl. 728, 742 (2000)). Here, the Air Force’s IGE is a completed Appendix L-08 Labor Rates Table, which consists of an FFP Labor Rates Excel sheet containing fully burdened labor rates for each labor category for FY 2025 through FY 2034, as well as labor rates for an option to extend the services. AR Tab 111. This is the same pricing format that the RFP required the offerors to use to submit their proposed pricing. See AR 1758, 1773, 1775 (requirement to submit proposed hourly labor rates for all labor categories in Section L Appendix L-08 Labor Rates Table). Using this format, the Air Force entered fully burdened labor rates for each labor category based on labor rate data from current contractors under the RE&C and WE&C contract vehicles, the predecessor contracts to the C2E contract. See AR 18215 (internal Air Force email requesting “an IGE from the tech/requirements team,” explaining that “[t]he labor categories and hours are already there, so it is really just about inputting the [fully burdened labor rate] for each labor category and year,” and stating that the requirements team has “historical data they can use”); AR 18214 (email response providing a document with FY 2025 and FY 2026 labor rate ranges from the 9 RE&C and WE&C contracts); AR 18213 (email explaining that the IGE is based on “FY25 rates for current contractors that received recent modifications or awaiting modifications” and that the labor rates “average around [***]% of the high values of the senior level positions for each labor rate”). This approach for developing the IGE is explained in the internal Air Force emails, AR Tab 110, and is further substantiated by the labor rates in the IGE, AR Tab 111, and the pricing research containing the FY 2025 labor rates from the predecessor contracts, AR Tab 112. With this evidence, the Court can establish a rational connection between the IGE and the administrative record. See Nutech Laundry & Textile, Inc., 56 Fed. Cl. at 595; see also Veteran Shredding, LLC v. United States, 146 Fed. Cl. 543, 580 (2019) (finding that an agency does not need to support its IGE with notes or back-up documentation when the IGE is based on historical data), aff’d, 842 F. App’x 606 (Fed. Cir. 2021); URS Fed. Servs., Inc. v. United States, 142 Fed. Cl. 392, 406 (2019) (finding no requirement for agency “to produce . . . additional back-up documentation to support the rationality of [its IGE]” when the IGE is based on historical data and when the protester “does not challenge the validity of the numbers as accurate reflections of the historical data”); MED Trends, Inc. v. United States, 102 Fed. Cl. 1, 7 (2011) (finding agency use of an IGE prepared using historical data rational where “[t]he plaintiff has not demonstrated, or even alleged, that any of the[] particular figures were unreasonable or inaccurate[,] [n]or has it pointed to any authority for the proposition that the agency must provide a more detailed explanation of how its [IGE] was formulated”). The Court is not persuaded by MVL’s argument that the Air Force expressed a lack of confidence in the IGE and considered the rates used in the IGE to be elevated. See [ECF 34] at 19-20. While the internal emails show that an Air Force project manager initially inquired into why the labor rates “seem really elevated” as compared to his calculations, AR 18213, the emails also show that the same person was satisfied with the explanation, AR 18212 (internal Air Force email stating “Gotcha. That makes sense. Comparing these rates to the ones I calculated they were all just below the highest rates that were offered in the RE[&]C and WE[&]C”). The Court is also not persuaded by MVL’s argument that the record fails to describe how the RE&C and WE&C efforts are like the C2E effort. See [ECF 34] at 19. To the contrary, the record shows that the Air Force viewed the C2E MATOC as a follow-on to the RE&C and WE&C contracts to satisfy “existing/ongoing requirements.” AR 473. Therefore, it was logical for the Air Force to use historical labor rates from these predecessor contracts for the purpose of developing an IGE. B. The Air Force’s Price Reasonableness Analysis was Arbitrary MVL argues that “[t]he [Air Force] has provided no rational basis for its determination that the [twelve] awardees offered fair and reasonable pricing, as required by the [RFP] and FAR 15.402(a).” [ECF 34] at 20. MVL contends that “the [RFP] stated that the [Air Force] would evaluate offerors’ proposed TEPs for reasonableness using the techniques in FAR 15.404-1,” id., but the Air Force’s attempt “to determine whether offerors’ proposed prices were fair and reasonable by (1) comparing offerors’ yearly TEPs against the yearly TEPs in [the] IGE; and (2) comparing offerors’ overall TEPs against the ‘average’ overall TEP of the [sixteen] highest technically rated offerors and the overall TEP in the IGE” were both insufficient, id. at 21. First, because it alleges that the Air Force’s IGE is unsupported, MVL asserts that “the Court cannot conclude that the [Air Force’s] use of the IGE to support its price reasonableness determination was reasonable.” Id. at 22. Next, because it alleges that the Air Force merely “documented the 10 difference (both in percentage and dollar amount) between each offeror’s proposed TEP and the average . . . [and] stopped after listing the percentage of variance without any additional analysis,” id. at 24 (emphasis omitted), MVL asserts that the Air Force failed to conduct a meaningful price analysis using the average TEP, id. In response, the government states that “the administrative record establishes that the Air Force followed FAR 15.40[4]-1 in employing two price analysis techniques permitted by the FAR,” [ECF 38] at 27, which “included comparing both the overall average TEP received of all [sixteen] of the [HTROs] to the offeror’s proposed TEP, FAR 15.404-1(b)(2)(i), and comparing the offeror’s proposed TEP to the government’s IGE, [FAR] 15.404-1(b)(2)(v),” id. With respect to the Air Force’s comparison of the proposed TEPs to the IGE, the government argues that “the IGE is sufficiently supported by the administrative record . . . [and that there is no support for MVL’s argument] that because an IGE is higher than every offer[] received, . . . the IGE is irrational and should not be used in price reasonableness evaluation.” Id. at 30. Next, with respect to the Air Force’s comparison of an offeror’s TEP to the average TEP, the government argues that “[t]he difference between certain offeror’s prices received does not amount to such a difference that renders the agency’s price reasonableness analysis arbitrary or capricious.” Id. at 31. While “MVL identifies three offeror’s prices higher than the average TEP, evidently implying that these offeror’s prices are impermissibly high[,]” id., “this Court has routinely upheld price premiums of the size of [these three offerors],” id. at 32. According to the government, “MVL’s argument that those three offerors’ prices were unreasonable because they were higher is simply an unsuccessful protestor seeking to substitute their evaluation for the agency[’s].” Id. The Court finds that, while the Air Force rationally relied on its IGE to determine price reasonableness, its price reasonableness analysis using the average TEP was arbitrary. To assess price reasonableness, the RFP stated that the Air Force “will evaluate the proposed [TEP] for reasonableness using the techniques described in FAR 15.404-1.” AR 1639. The FAR provides that the contracting officer may use “[t]he analytical techniques and procedures described in [FAR 15.404-1] . . . , singly or in combination with others, to ensure that the final price is fair and reasonable.” FAR 15.404-1(a)(1). “Price analysis is the process of examining and evaluating a proposed price without evaluating its separate cost elements and proposed profit.” FAR 15.404-1(b)(1). To conduct a price analysis, “[t]he [g]overnment may use various price analysis techniques and procedures to ensure a fair and reasonable price.” FAR 15.404-1(b)(2). Such techniques and procedures include the “[c]omparison of proposed prices received in response to the solicitation[,] . . . [the] [c]omparison of the proposed prices to historical prices paid, whether by the [g]overnment or other than the [g]overnment, for the same or similar items[,] . . . [and the] [c]omparison of proposed prices with independent [g]overnment cost estimates[.]” FAR 14.404- 1(b)(2)(i)-(ii), (v). “FAR 15.404-1 leaves the choice of price-analysis technique to a contracting officer’s reasonable judgment in the context of an individual procurement.” DynCorp Int’l, LLC, 10 F.4th at 1310. The record in this case shows that the Air Force assessed price reasonableness using a combination of two techniques. It compared each offeror’s proposed TEP to the IGE, and it compared each offeror’s proposed TEP “to the average of the evaluated HTRO F&O propose