In Centerline Logistics Corporation, B-423838, et al. (Jan. 7, 2026), Centerline Logistics Corp. protested the Air Force’s award of a roughly $200 million fuel transportation services contract to Vane Line Bunkering. Centerline challenged multiple aspects of the evaluation and source selection decision, arguing that the agency applied unstated evaluation criteria, treated offerors disparately, failed to consider negative information “too close at hand,” and did not conduct meaningful discussions regarding the relevance of Centerline’s past performance. GAO denied the protest in its entirety. In doing so, the decision serves as a useful refresher on several important protest doctrines—and the high bar protesters must clear to prevail in a GAO protest.
The Decision
GAO denied the protest, ruling that:
- No Unstated Evaluation Criteria Were Applied: Centerline argued that the agency improperly focused on whether offerors had experience transporting jet aviation fuel as opposed to other types of fuel, claiming that emphasis was never disclosed. GAO disagreed, holding that consideration of fuel type was logically encompassed within the solicitation. The PWS expressly identified jet aviation fuel as a key requirement, and the past performance questionnaires specifically asked offerors to identify the types of fuel transported. GAO thus held that evaluating whether past performance involved jet aviation fuel was therefore reasonably and logically related to the stated evaluation criteria.
- Disparate Treatment Claims Failed Because the Proposals Were Different: Centerline alleged that the agency treated its past performance more harshly than the awardee’s. GAO rejected this argument, finding that the evaluation differences flowed from substantive differences in the underlying past performance references. In particular, GAO explained that the agency reasonably assigned higher relevance ratings where the awardee’s references matched the solicitation in more dimensions (scope, magnitude, and complexity), even where not every reference involved jet aviation fuel.
- The “Too Close at Hand” Doctrine Did Not Apply: Centerline argued that the agency failed to consider negative performance information about the awardee contained in U.S. Coast Guard Port State Information Exchange reports. GAO held that the doctrine did not apply because Centerline failed to show that the evaluators were actually aware, or reasonably should have been aware, of that information. GAO reiterated that the obligation to consider “too close at hand” information is narrow and applies only where the information is known to the specific evaluators involved in the source selection.
- No Duty to Raise Non-Significant Weaknesses During Discussions: Centerline contended that discussions were not meaningful because the agency failed to inform it that its past performance was viewed as less relevant due to the lack of jet aviation fuel experience. GAO rejected this argument, explaining that the agency did not view this as a deficiency or significant weakness, but rather as a distinguishing factor between proposals. Agencies are not required to discuss every weakness, only deficiencies and significant weaknesses, and GAO reaffirmed that a discriminator need not be raised in discussions.
- Best-Value Tradeoff Was Reasonable: Finally, GAO upheld the agency’s best-value decision, noting that the awardee’s superior past performance reasonably justified paying a small price premium (approximately 0.19 percent). Because GAO found the underlying evaluation unobjectionable, the tradeoff decision likewise stood.
Key Takeaways for Contractors
- Not Every Consideration Is an Unstated Criterion: Agencies may evaluate factors that are logically encompassed by the solicitation, even if not spelled out with granular precision.
- Disparate Treatment Requires Apples-to-Apples Comparisons: To succeed, protesters must show that proposals were materially indistinguishable. Differences in underlying experience will defeat past performance disparate treatment claims.
- “Too Close at Hand” Is a Narrow Doctrine: Publicly available information is not enough. Protesters must show that evaluators actually knew, or should have known, about the information during the evaluation.
- Meaningful Discussions Do Not Mean Exhaustive Discussions: Agencies are not required to identify every comparative weakness or discriminator during discussions, even if that weakness ultimately proves decisive.
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