GAO Dismisses Encon Design-Build Protest as Untimely
GAO dismissed Encon DesbuildJV4, LLC’s protest over phase-one selection in a FAR subpart 36.3 design-build procurement because the post-selection briefing was not a legally required debriefing. The decision reinforces that offerors generally have 10 calendar days from when they knew or should have known a protest basis, and solicitation references to FAR Part 15 do not necessarily extend that deadline.