JOFOC Ext Data (6KY0083)_Redacted.pdf

Revised MAR 2026

Justification for Other Than Full and Open Competition, Extension

U.S. General Services Administration

PBS, Office of Leasing

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

PROJECT NUMBER: 6KY0083

Agency Name: VBA

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

The General Services Administration currently leases 61,226.00 ABOA/66,114.00 rentable square feet (RSF) of office space at WATERFRONT PLAZA, LOUISVILLE, KY, 325 W MAIN ST , LOUISVILLE, KY under lease number LKY60163 for the VBA. The current lease expires October 31, 2026. Approval is requested to negotiate a lease extension combined with an expansion of 3,107 ABOA SF 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 and expansion of the current lease for 60 months/36 months firm to commence on November 1, 2026. The estimated cost of this lease extension and expansion 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: FAR 6.103-1 (GSA RFO-2025-06) and 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 in situations such as, but not limited to, the following:

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.

It is in the best interest of the Government to remain at the current location during the extension period.

VBA is being considered to backfill space recently vacated at the Odell Horton Federal Building. Due to questions regarding the possible disposition of the building, a potential lease procurement is on hold while

Docusign Envelope ID: 7621F2EF-ABE7-8194-8119-D73557B47E01 the federal option is fully examined. In addition, because the lease is near expiration, it is vital to protect VBA’s occupancy at the current location. Award to other than the current Lessor would require relocation of the entire requirement and would cause VBA to incur move and replication costs that would not be recovered through competition.

Lessors are increasingly unable to secure financing for three-year extensions and are no longer willing to sign short term deals in many markets. GSA policy has followed suit, and now permits extensions up to 5 years.

The expansion of 3,107 ABOA SF is within the scope of the lease. VBA occupied the space previously, and had released the space under the efforts to reduce the federal footprint and increase in telework and remote work. With the new requirements for agency’s Return To Office to the fullest extent possible, VBA needs the space as soon as possible. The space has not been utilized by a new tenant, so offers an opportunity to acquire space for VBA that will not entail financial outlays similar to new space and is available immediately.

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

MANY POTENTIAL SOURCES AS IS PRACTICABLE.

In accordance with GSAR 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 LOUISVILLE, KY showed the rental rate within the market area ranges from $

Therefore, the anticipated rental rates for this lease extension of $ per RSF, are within 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 August 10, 2026, market research was conducted using Bullseye, CoStar, Current GSA Leases. 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 a 60 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.

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 LKY60163 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_____________________ Kovas Palubinskas, 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______________________ Kovas Palubinskas, Lease Contracting Officer

Concurred by:

Thomas Nisivaco Date

One Level above LCO (if applicable)

Concurred by:

Gina Ditommaso Date

Competition Advocate (if applicable)

Reviewed for legal sufficiency by:

Robert Foltman Date

Office of the General Counsel, Real Property Law Division (if applicable)

9/28/2026 | 16:18:45 BST

9/28/2026 | 15:01:21 BST

9/28/2026 | 15:01:21 BST

9/29/2026 | 13:33:06 BST

9/29/2026 | 13:36:24 BST

Certificate Of Completion Envelope Id: 7621F2EF-ABE7-8194-8119-D73557B47E01 Status: Completed

Subject: Complete with Docusign: JOFOC Ext Data (6KY0083).pdf

Source Envelope:

Document Pages: 3 Signatures: 5 Envelope Originator:

Certificate Pages: 2 Initials: 0 Kovas Palubinskas

AutoNav: Enabled

EnvelopeId Stamping: Enabled

Time Zone: (UTC) Dublin, Edinburgh, Lisbon, London

1800F F St NW

Washington DC, DC 20405 kovas.palubinskas@gsa.gov

IP Address: 136.226.18.73

Record Tracking Status: Original

9/28/2026 2:56:52 PM

Holder: Kovas Palubinskas kovas.palubinskas@gsa.gov

Location: DocuSign

Security Appliance Status: Connected Pool: FedRamp

Signer Events Signature Timestamp Gina Ditommaso gina.ditommaso@gsa.gov

For Crofton Whitfield

US General Services Administration

Security Level: Email, Account Authentication (None)

Signature Adoption: Pre-selected Style

Using IP Address: 136.226.20.89

Sent: 9/28/2026 3:00:50 PM

Viewed: 9/28/2026 4:18:17 PM

Signed: 9/28/2026 4:18:45 PM

Electronic Record and Signature Disclosure:

Not Offered via Docusign

Kovas Palubinskas kovas.palubinskas@gsa.gov

Lease Contracting Officer

US General Services Administration

Security Level: Email, Account Authentication (None)

Signature Adoption: Pre-selected Style

Using IP Address: 136.226.18.73

Sent: 9/28/2026 3:00:51 PM

Viewed: 9/28/2026 3:01:07 PM

Signed: 9/28/2026 3:01:21 PM

Electronic Record and Signature Disclosure:

Not Offered via Docusign

Robert Foltman robert.foltman@gsa.gov

US General Services Administration

Security Level: Email, Account Authentication (None) Signature Adoption: Pre-selected Style

Using IP Address: 136.226.18.50

Sent: 9/28/2026 3:00:52 PM

Viewed: 9/29/2026 1:32:39 PM

Signed: 9/29/2026 1:33:06 PM

Electronic Record and Signature Disclosure:

Not Offered via Docusign

Thomas Nisivaco thomas.nisivaco@gsa.gov

LCO

US General Services Administration

Security Level: Email, Account Authentication (None)

Signature Adoption: Pre-selected Style

Using IP Address: 136.226.15.34

Sent: 9/28/2026 3:00:52 PM

Viewed: 9/29/2026 1:36:14 PM

Signed: 9/29/2026 1:36:24 PM

Electronic Record and Signature Disclosure:

Not Offered via Docusign

In Person Signer Events Signature Timestamp

Editor Delivery Events Status Timestamp

Agent Delivery Events Status Timestamp

Intermediary Delivery Events Status Timestamp

Certified Delivery Events Status Timestamp

Carbon Copy Events Status Timestamp

Witness Events Signature Timestamp

Notary Events Signature Timestamp

Envelope Summary Events Status Timestamps Envelope Sent Hashed/Encrypted 9/28/2026 3:00:52 PM

Certified Delivered Security Checked 9/29/2026 1:36:14 PM

Signing Complete Security Checked 9/29/2026 1:36:24 PM

Completed Security Checked 9/29/2026 1:36:24 PM

Payment Events Status Timestamps