significant schedule risk by suggesting that the FAA has given the plan its blessing. For ‘example, the Air Force provides that “both offerors were required to coordinate preliminary FAA certification plans through the FAA Military Certification Office in Wichita, KS; this included planned time lines. The MCO coordination responses identified both certification plans as ‘viable approaches.” Second Supp. COSF, AR Tab 002 at 88. The Air Force also declares that “The FAA signature was not approval of the plan (since that occurs when the application is filed after contract award) but represented the FAA's opinion that the proposed certification approach was viable and complied with certification requirements. ‘The FAA also served as advisors to the SSET to assist the USAF in performing the analysis of the proposed approach and identifying both proposal and schedule risk issues.” Initial COSF, AR Tab 002 at 103-04. These post hoc rationalizations of the adequacy of NG/EADS? certification approach exaggerate the significance of the FAA's role and further suggest that the Air Force unreasonably evaluated NG/EADS? certification plan._As indicated in the formal FAA transmittal to the Air Force dated March 26, 2007, However, it further stat I1-J-iii, Thus, the FAA merely deemed. Moreover, with respect to the FAA's involvement in the evaluation process, Ultimately, the Agency Report's description of the FAA’s participation in the evaluation process suggests that the Air Force ignored the significant schedule risks inherent in NG/EADS’ complex certification plan because it assumed that the FAA had deemed that plan to meet the RFP requirements. However, this assumption was completely incorrect. In the end, the Air Force's failure to account for the substantial schedule and cost risks associated with NG/EADS’ proposal resulted in its untenable conclusion that NG/EADS" proposal to achieve IOC in was less risky than Boeing’s proposal to achieve IOC in FY15 4, The Agency Report Confirms That The Air Force’s Schedule Risk Assessment Ignores Critical Risks That Should Have Generated Adjustments To NG/EADS? Schedule. Boci g's Protest argued that the Air Force acted unreasonably in and that the Air Force’s treatment of the two offerors with 1 schedule risk differed greatly. See, e.g., Second Supp. Protest, AR Tab 003(c) at 72. 93Boeing pointed out that both offerors’ schedules were initially regarded as overly aggressive, as reflected in the early schedule risk assessments (SRAS). /d. While Boeing ‘was able to reduce the risk associated with its proposal through a significant schedule were able to accomplish the same result The Air Force response repeatedly emphasizes that Boeing was not forced to change its schedule. See, e.g., Second Supp. COSF, AR Tab 002 at 108 (“[T]he Air Force did not demand a change in Boeing’s schedule.” (emphasis in original); Initial COSF, AR Tab 002 at 103 (“The Air Force never directed Boeing to change its schedule.”). Instead, the Air Force argues, Boeing ‘elected’ to make schedule adjustments. With these statements the Air Force ignores the reality of the situation. The Air Force determined that Bocing’s initially proposed schedule was high risk, and Boeing recognized that this risk had to be mitigated. The Air Force acknowledges this point, noting that “[iJn the absence of any other acceptable mitigation plan, it was likely that the Air Force would have carried the Milestone C weakness and concluded that the initial schedule would have been high risk, perhaps even unacceptably high risk.” Initial COSF, AR Tab 002 at 105. During the evaluation process, the Air Force made it clear to Boeing that it would need to extend its schedule or accept the consequence of this unacceptably high risk. See, e.g., Mid-term Briefing to Boeing Minutes, Aug. 17, 2007, AR Tab 132 at 4 (“[I]t is Boeing's call as to the schedule they want to propose but they should understand that it is high risk. .. if they stay with this approach without substantive justification.”). While Boeing did not agree with the Air Force that its initially proposed schedule presented a high risk, it understood the Air Force's concerns and adjusted its proposal accordingly. ‘The Air Force’s treatment of NG/EADS was very different. 94Debrief to NG. Mar. 10, 2008, AR Tab 208 at 153. ‘The Air Force defends the reasonableness of the evolution of NG/EADS’ SRA, saying it “thoroughly addressed the schedule and performance risks may [sic] have been ited by NG's proposal. The Air Force reasonably and thoroughly considered MOL, AR Tab 001 at 163. As is discussed above in Section D.2.c, this assertion PY The Air Force attempts to support its decision to credit NG/EADS’ superficial solutions to the schedule risks it did identify by noting “there were many ways for an Offeror to mitigate schedule risks.” Second Supp. COSF, AR Tab 002 at 113. The Air Force further states that Boeing’s SRA argument “is incorrectly based on the assumption that risk could not be mitigated without changing the schedule, as Boeing had done. However Northrop Grumman mitigated its risk in other ways.” Id. While the Air Force is correct that there are many ways to mitigate schedule risk, the methods available obviously are dependent on the particular risk being evaluated. Boeing does not argue that the only mitigation for all schedule risks is changing schedule, it argues that the particular risks present in NG/EADS' production plan were clearly not mitigated by the methods they proposed. Thus, while Boeing was faced with an unacceptably high risk rating if it did not extend its schedule, Furthermore, while