Extension Justification Redacted.pdf
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- Attached to
- Justification for Other Than Open and Full Competition Federal contract opportunity
- Solicitation number
- 6PR0148
About this file
This is a Justification for Other Than Full and Open Competition document for a GSA lease extension approval.
GSA is seeking approval to extend the current lease for USDA office space at 654 Munoz Rivera Avenue, Hato Rey, Puerto Rico (Lease No. LPR18955) without competitive bidding. The lease encompasses 12,192 ABOA/14,875 rentable square feet and currently expires August 31, 2026. The requested extension is for twelve months commencing September 1, 2026, with an estimated annual cost of $556,984.97. The justification cites 41 U.S.C. 3304(a)(1) as authority for sole-source contracting, implemented through FAR 6.103-1 and GSAR 570.405, based on the agency's documented organizational and relocation planning delays. GSA is concurrently processing a new/replacing lease (LPR00477) with the incumbent lessor that will consolidate space requirements from 35,558 RSF to 29,301 RSF—an 18% reduction—and the one-year extension provides necessary time to complete lease award and tenant improvement buildout. Market research conducted January 5, 2026, using JLL Market Research established that Hato Rey rental rates range from $28.00 to $40.00 per RSF, and the proposed extension rate is below this market range. The contracting officer Eduardo Vidal certified that remaining at the current location avoids operational disruption and that the extension represents the government's best interest, particularly given that switching to a different lessor would impose unrecoverable relocation and replication costs.
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Text version
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: 6PR0148
Agency Name: USDA
1. NATURE AND/OR DESCRIPTION OF ACTION BEING APPROVED.
The General Services Administration currently leases 12,192 ABOA/ 14,875 rentable square feet (RSF) of office space at 654 Munoz Rivera Ave., Hato Rey, PR under lease number LPR18955 for the USDA. The current lease expires August 31, 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 Twelve (12) months to commence on September 1, 2026. The estimated cost of this lease extension is per rentable square feet per year for an annual cost of $556,984.97 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.
GSA currently leases a total of 35,558 rentable square feet (RSF), yielding 30,660 ABOA SF, for six USDA divisions at 654 Muñoz Rivera Avenue in San Juan, PR. These operations are currently held under Leases No. LPR18955 and LPR19045, which are both set to expire on 08/31/2026.
(b) (5)
(b) (5)
GSA is in the process of awarding a new/replacing lease (LPR00477) to the incumbent Lessor. This new lease will consolidate the requirement into 29,301 RSF (25,151 ABOA SF), plus an additional 140 RSF of free space. This consolidation represents an 18% reduction in the Government’s footprint. A one-year extension of the current leases is required to provide sufficient time to award the new lease and complete the necessary Tenant Improvement buildout. Moreover, awarding to a different Lessor would require a full relocation, causing the USDA 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 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 Hato Rey, PR showed the rental rate within the market area ranges from $28.00 to $40.00.
Therefore, the anticipated rental rates for this lease extension of per RSF is below the current market range for this submarket and is deemed fair and reasonable by the GSA Lease Contracting Officer.
7. DESCRIPTION OF MARKET RESEARCH CONDUCTED AND THE RESULTS.
On January 5, 2026, market research was conducted using JLL Market Research. The market research showed the rental rate within the market area ranges from $28.00 to 40.00, without Tenant Improvements or BSAC.
8. OTHER FACTS SUPPORTING USE OF OTHER THAN FULL AND OPEN COMPETITION.
Remaining at the current location under a Twelve (12) 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. The Government conducted a competitive lease procurement in 2025, and the incumbent Lessor was identified as the Awardee for the new/replacing lease based on a Lowest Priced, Technically Acceptable award criteria.
Additionally, objective scrutiny was given to the customer agency’s mission and security requirements 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 Twelve (12) months for LPR19045 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_____________________ Eduardo Vidal, Lease Contracting Officer
(b) (4)
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______________________ Eduardo Vidal, Lease Contracting Officer
Approved by:
Eduardo Vidal, Lease Contracting Officer Date
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