5CA1623 - CBP SF - Ext Signed JOTFOC REDACTED.pdf

Revised Nov 2023

Justification for Other Than Full and Open Competition, Extension

U.S. General Services Administration

GSA Region Moderate Leasing Group A

Department Of Homeland Security (DHS): Customs and Border Protection (CBP) Field Operations Facilities

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

PROJECT NUMBER: 5CA1623

Agency Name: Customs and Border Protection (CBP) Field Operations Facilities

1. NATURE AND/OR DESCRIPTION OF ACTION BEING APPROVED.

The General Services Administration currently leases 12,552 ABOA/15,777 rentable square feet (RSF) of office space along with 5 secured/structured parking spaces at 33 New Montgomery St., San Francisco, CA under lease number GS-09P-LCA03439 for the CBP. The current lease expires April 30, 2026.

Approval is requested to negotiate a lease extension with the incumbent Lessor without full and open competition for continued occupancy at this leased location. The procedures for pursuing a lease extension are detailed in GSAR 570.405: Lease extensions.

2. DESCRIPTION OF THE SUPPLIES OR SERVICES REQUIRED TO MEET THE AGENCY’S NEEDS

(INCLUDING ESTIMATED VALUE).

The government requires an extension of the current lease for 36 months to commence on May 1, 2026.

The estimated cost of this lease extension is per rentable square feet per year for an annual cost of and a total contract value of (includes a 3% annual increase to Shell costs, Structured parking and Antenna costs as reflected in the below table)

Shell

Operating

Parking

Antenna

Total

3. IDENTIFICATION OF STATUTORY AUTHORITY PERMITTING OTHER THAN FULL AND OPEN

COMPETITION.

41 U.S.C. 3304(a)(1): Only one responsible source and no other supplies or services will satisfy agency requirements. This statutory authority is implemented through FAR model deviation 6.103-1 of the FAR Council’s model deviation to FAR Part 6 (adopted by GSA RFO-2025-06, Class Deviation for FAR Part 6) and GSAR 570.405. Award to any other offeror would result in substantial duplication of costs to the Government that is not expected to be recovered through competition.

Docusign Envelope ID: 119A6D1B-AC14-41C2-82BD-B54549909A5D

4. DEMONSTRATION THAT THE PROPOSED CONTRACTOR’S UNIQUE QUALIFICATIONS OR

NATURE OF THE ACQUISITION REQUIRES THE USE OF THE AUTHORITY CITED.

A cost-benefit analysis shows that the Government cannot expect to recover substantial relocation and duplication costs through competition. It is in the best interest of the Government to remain in the current location. The current space is already built to meet CBP’s requirements. An award to other than the current Lessor would require relocation of the entire requirement and would cause CBP to incur move and replication costs that would not be recovered through competition. Relocation costs are estimated to be Additionally, this allows the Government to make use of existing tenant improvements, avoiding replication of tenant improvement costs estimated to be approximately The total amount of move and replication costs that would not be recovered through competition is estimated to be

5. DESCRIPTION OF EFFORTS MADE TO ENSURE THAT OFFERS ARE SOLICITED FROM AS

MANY POTENTIAL SOURCES AS IS PRACTICABLE.

In accordance with GSAM 570.106(d) and 570.405, an advertisement is not required for extensions.

6. DEMONSTRATION BY THE CONTRACTING OFFICER THAT THE ANTICIPATED COST TO THE

GOVERNMENT WILL BE FAIR AND REASONABLE.

Market research conducted by the Lease Contracting Officer in San Francisco, CA showed the fully serviced rental rate ranges from to This rate excludes parking costs, estimated at per space and antenna costs estimate of RSF. Nor does the rate consider the impact of a short-term lease action which imposes significant restrictions on the Lessor’s ability to seek favorable financing. While the rate of is outside the market range, it remains advantageous for the Government to remain in place and execute an extension. Alternate locations would necessitate substantial costs for tenant improvement, replication and moving, estimated to be approximately inevitably leading to mission disruption and associated downtime, which justifies the current rental rate. Therefore, the anticipated rental rate for this lease extension of per RSF, is deemed fair and reasonable by the GSA Lease Contracting Officer.

7. DESCRIPTION OF MARKET RESEARCH CONDUCTED AND THE RESULTS.

On November 21, 2025, market research was conducted using Co-Star. The market research showed the fully serviced rental rate within the market area ranges from to for office space and a range of to per month for surface parking spaces. No data was presented to support Antenna space required to fulfill the Agency’s requirement.

8. OTHER FACTS SUPPORTING USE OF OTHER THAN FULL AND OPEN COMPETITION.

Remaining at the current location under a 36-month extension avoids a holdover and allows the Government to continue operations without disruption.

9. LIST OF SOURCES, IF ANY, THAT EXPRESSED, IN WRITING, AN INTEREST IN THE

ACQUISITION.

N/A

10. STATEMENT OF ACTIONS, IF ANY, THE AGENCY MAY TAKE TO REMOVE OR OVERCOME

ANY BARRIERS TO COMPETITION BEFORE ANY SUBSEQUENT ACQUISITION.

There are no systemic barriers to competition. If the agency has a continuing need for space upon lease expiration, GSA will follow all authorities, regulations and policies applicable to lease acquisition. Should there be remaining useful life in the Government’s tenant improvements, the Government will consider the cost of moving from the existing location, and the cost to build out new space when deciding whether to undergo a competitive action.

Docusign Envelope ID: 119A6D1B-AC14-41C2-82BD-B54549909A5D

Additionally, objective scrutiny will be given to the customer agency’s mission and security requirements (if applicable) to eliminate unnecessary agency space requirements that may be deemed unduly restrictive.

11. CONTRACTING OFFICER CERTIFICATION.

By signature on this Justification for Other than Full and Open Competition, the GSA Lease Contracting Officer certifies that the award of a lease extension of 36 months for GS-09P-LCA03439 is in the Government’s best interest and that this Justification is accurate and complete to the best of the GSA Lease Contracting Officer’s knowledge and belief.

________________________________ Date_____________________ William Fletcher, Lease Contracting Officer

12. PREPARER’S TECHNICAL CERTIFICATION.

I certify that the supporting data used to form the basis of this Justification is complete and accurate to the best of my knowledge and belief.

__________________________________ Date______________________ William Fletcher, Lease Contracting Officer

Concurred by:

________________________________ Date______________________ Jeanette Torres, Branch Chief

Concurred by:

____________________________________ Date______________________ Kristin Ritter, Moderate Division Director

Approved by:

_________________________________ Date______________________ Gina Ditommaso- Competition Advocate

Docusign Envelope ID: 119A6D1B-AC14-41C2-82BD-B54549909A5D

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