Extension_JOFOC_Template_(Oct_2025)_-_Redacted..pdf

Justification for Other Than Full and Open Competition, Extension

U.S. General Services Administration

GSA Region 2 Leasing

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

PROJECT NUMBER: 5PR0164

Agency Name: Department of Labor (DOL)

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

The General Services Administration currently leases 5,147 ABOA/5,778.01 rentable square feet (RSF) of office space at Santander Tower at San Patricio, B7 Calle Tabonuco, Guaynabo, Puerto Rico under lease number LPR19182 for the Department of Labor (DOL). The current lease expires November 06 2025. 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 November 07, 2025. The estimated cost of this lease extension is $43.24 per rentable square feet per year for an annual cost of $249,809.95 and a total contract value of $749,429.85

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

X 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.

The tenant improvement (TI) payments for the current space will be completed in November 2025. This

Docusign Envelope ID: A88B00CA-0500-4A0F-8498-0BC6F552AD6F allows the government to utilize the existing tenant improvements, preventing a replication cost of

$171,455.90, which includes a 5% amortization rate. The current space at Santander Tower at San

Patricio, B7 Calle Tabonuco, Guaynabo, Puerto Rico, is already constructed to meet the immediate needs of the Department of Labor (DOL) and will not require any improvements during the extension term. The facility also meets FSL Level 1 security requirements. GSA is currently working to finalize the agency's long-term housing needs to secure a longer firm term. To continue supporting the agency's mission and ensure occupancy at their current location while the new, longer procurement is underway, an extension is needed.

Award to other than the current Lessor would require relocation of the entire requirement and would cause Department of Labor (DOL) 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, 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 the Guaynabo Area, Puerto Rico showed the rental rate within the market area ranges from $42.25 to $44.00.

Therefore, the anticipated rental rates for this lease extension of $43.24 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 27,2025, market research was conducted using Local market data and independent market research and revealed few potential building withing two (2) other buildings evaluated for comparable market information from the sources of market data recollected. The market research showed the rental rate within the market area ranges from $ 42.25 to $ 44.00 per RSF within the Guaynabo area, Puerto Rico vicinity that appear to have the available square footage necessary to meet agency’s requirements.

Market asking rental rates do not typically reflect the services included in a fully serviced Government lease, as a result, the market data has been adjusted to reflect a fully serviced rental rate for a government lease. The rate of $43.24 per RSF are withing the current market range for this extension.

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.

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 LPR19182 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_____________________

Thomas Landron Morales, 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______________________

Thomas Landron Morales, Leasing Specialist