5CO0626 - Redacted OTFO_Redacted.pdf

Revised Nov 2023

Justification for Other Than Full and Open

Competition, Extension U.S. General Services Administration

PBS Leasing Division

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

PROJECT NUMBER: 5CO0626

Agency Name: CD NTIA

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

The General Services Administration currently leases 27,774.00 ABOA/28,588.00 rentable square feet (RSF) of office space at Sterling Circle, 3122 Sterling Circle, Boulder, CO under lease number LCO15027 for the CD NTIA. The current lease expires March 20, 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 18 months, 11 months firm to commence on March 21, 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 $

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 GSAR 570.405. In accordance with GSAR 570.405, use of the sole source authority is appropriate when the government experiences a delay in acquiring replacement space.

The agency occupying the leased space is scheduled to move into other Federally controlled space, but encounters unexpected delays in preparing the new space for occupancy

The government encounters unexpected delays outside of its control in acquiring replacement space

The government is consolidating various agencies and the contracting officer needs to extend the terms of some leases to establish a common expiration date

The agency occupying the space has encountered delays in planning for a potential relocation to other federally controlled space due to documented organizational, financial, or other uncertainties

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

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

The First Responder Network Authority (FirstNet Authority), and independent entity within National Telecommunications Information Administration (NTIA) under the Department of Commerce is currently housed in a 28,588 rsf lease at 3122 Sterling Circle, Boulder, CO which expires 3/20/26. GSA is conducting a succeeding lease procurement (2CO0704) to keep the agency at its current location for a term of 10 years, 8 years firm. However, in August 2025 when GSA was preparing the RLP for FirstNet’s approval, the agency requested GSA pause the succeeding lease procurement. Instead, FirstNet requested GSA negotiate a lease extension for a term not to exceed 12 months firm, while it awaits Congressional reauthorization and associated funding for FY27 and beyond (see attached).

In October 2025 FirstNet requested the firm term be reduced to 11 months. This was to align the expiration date of the requested firm term with their Congressional authority to exist as an independent entity within NTIA.

It is in the best interest of the Government to pursue a lease extension with the incumbent Lessor. An extension reduces the risk of committing to a long-term lease while FirstNet’s reauthorization is still pending. Additionally, executing a lease extension eliminates the possibility for holdover tenancy.

Upon reauthorization, GSA will continue to procure a long-term solution that aligns with FirstNet’s authorities and approved budget.

Additionally, an award to other than the current Lessor would require relocation of the entire requirement and would cause CD NTIA to incur move and replication costs that would not be recovered through competition.

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.

Recent market research conducted by the Lease Contracting Officer in BOULDER, CO showed the rental rate within the market area ranges from $ $

Therefore, the anticipated rental rates for this lease extension of $ per RSF, are below the current market range for this submarket and are deemed fair and reasonable by the GSA Lease Contracting Officer.

7. DESCRIPTION OF MARKET RESEARCH CONDUCTED AND THE RESULTS.

On June 26, 2025, market research was conducted using CoStar and Colliers Reports. The market research showed the rental rate within the market area ranges from $ $

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

Remaining at the current location under an 18 month, 11 month firm 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.

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 18 months for LCO15027 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_____________________ Darrin Hotaling, 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______________________ Darrin Hotaling, Lease Contracting Officer

13. APPROVAL

___________________________________________________ Date______________________ Gina DiTommaso, Competition Advocate

See FAR 6.104-2 (GSA Class Deviation RFO-2025-07) for appropriate signature threshold levels.