Can one protest a BPA (off the FSS) even though no TO/PO have been issued?

Do you mean: Can one protest the award of a BPA? If so, the answer is yes.

See e.g., Seaborn Health Care, Inc. v. U.S., 101 Fed. Cl. 42 (2011) and Vinculum Solutions, Inc., GAO Decision B-406760, 2012 CPD para. 249.

Thank you Vern. If an agency receives a "protest" that is no where near meeting the FAR 33 protest requirements, should that agency stay the contract and respond to the 'protest' or can the agency just ignore the gripe e-mail. My thought is we look into the gripe (about the awardee not meeting the SCA) but do not have to stay the contract (which is a BPA with no TO so it is does not really matter anway) and it is more or less at the agency's discression. Thanks again for your time.

I assume that when you say "an agency receives a protest" you mean a protest addressed to the agency, not to the GAO or the Court of Federal Claims.

I assume that when you say "FAR 33 protest requirements" you mean the requirements in FAR 33.103(d) and (e).

I have no idea what you mean by "gripe e-mail." Does the gripe email fit the definition of protest in FAR 33.101? If so, then it is a protest. If not, then it is not.

If an agency receives a protest as defined by FAR 33.101, then the CO should do exactly what FAR 33.103(f), (g), and (h) and agency procedures say that he or she should do. If the agency receives a complaining email that does not fit the definition of protest in FAR 33.101, then the CO need not follow those procedures.

FAR does not say what an agency is to do if it receives a protest that does not conform to the requirements in FAR 33.103(d) and (e). I am not aware of any FAR solicitation provision that imposes those requirements on unsuccessful offerors. As a CO, I would not ignore such a protest. I would contact the protester, direct its attention to FAR 33.103(d) and (e), and ask it to comply with those instructions within the protest filing deadline. I would tell it what I think the deadline is based on FAR 33.103(e) and the definition of "day" in FAR 33.101. If the protester refuses or otherwise fails to resubmit by the deadline, I would seek advice of agency counsel and probably deny the protest as received.