Reliance on Accuracy of Government Estimate of Quantities

Such reliance is entirely proper as a contractor has no affirmative duty to substitute its own evaluation of site conditions for that provided in the solicitation. Western Contracting Corp., 82-1 BCA at ¶ 76,806.

Quantity estimates or other interpretive data which appear in a solicitation are assumed to be based on relevant underlying information available to the government, and therefore to be accurate. “If the bidder were not entitled to so regard it, its inclusion in the invitation would be surplusage at best or deception at worse.” Womack v. United States, 182 Ct. Cl. 399, 389 F.2d 793, 800 (1968). In addressing a contractor’s reliance on a government estimate, the Court of Claims noted that a bidder “is entitled to rely on government estimates as representing honest and informed conclusions.” Id. See also Magnus Pac. Corp. v. United States, 133 Fed. Cl. 640, 683 (2017).

Updated: August 3, 2018