Redacted LCA01728_Justification_for_Other_Than_Full_and_Open_Competition.pdf

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U.S. General Services Administration

GSA Region 9

Real Estate Acquisition Division

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

PROJECT NUMBER: 2CA1797

Agency Name: Social Security Administration (SSA)

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

The General Services Administration currently leases 18,460 ABOA/20,952 rentable square feet (RSF) of office space at 501 S. Vincent Ave., West Covina, CA under lease number GS-09-LCA01728 for the SSA.

The current lease has a rental rate of REDACTED per RSF per year and expires 9/10/24. Approval is requested to negotiate one renewal option with the incumbent Lessor without full and open competition for continued occupancy at this leased location. The right to pursue a renewal option is detailed in GSAR 570.401: Renewal Options.

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

(INCLUDING ESTIMATED VALUE).

GSA has confirmed the need for a renewal option at this leased location. SSA is in process of evaluating future long term space needs, including what adjustments should be made to office designs and space allocation standards in the post-COVID work environment. Renewal options allow the Government to protect occupancy while this evaluation occurs.

This requirement is to add one five-year renewal option. The estimated cost of the option is REDACTED per RSF per year for an annual cost of REDACTED. The total contract value of these options is estimated to be REDACTED.

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. In accordance with FAR 6.302-1, it is determined that award to any other offeror would result in substantial duplication of costs to the Government that are not expected to be recovered through competition.

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. Award to other than the current Lessor would require relocation of the entire requirement and would cause SSA to incur move and replication costs that would not be recovered through competition. Relocation costs are estimated to be REDACTED. Additionally, this allows the Government to make use of existing tenant improvements, avoiding replication costs of REDACTED. Current space includes, but is not limited to, private offices, large training/conference room, private and public restrooms, interview areas/barrier walls, and large waiting room.

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

MANY POTENTIAL SOURCES AS IS PRACTICABLE.

Per the requirements of GSAR 570.401, the GSA Lease Contracting Officer placed a notice in the System for Award Management, Contracting Opportunities (SAM) on 2/21/24 for 10 days. There were no responses to the SAM notice.

In addition, GSA conducted market research using CoStar to locate alternative locations.

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

THE GOVERNMENT WILL BE FAIR AND REASONABLE.

A cost-benefit analysis was completed following the procedures set forth in GSAR 570.402-6. The cost of relocating SSA using the low-cost estimate exceeds the cost of remaining at 501 S. Vincent Ave., West Covina, CA. The total savings to the Government is REDACTED.

Therefore, the proposed rental rates for this renewal of REDACTED for the renewal 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 April 13, 2023 GSA conducted market research using CoStar and identified 5 potentially acceptable locations (4 plus the incumbent) that might meet the agency’s needs within the delineated area. The locations are in Class A or B office space with available square footage to meet the agency’s requirements. In addition, GSA placed a notice conforming to GSAR 570.402-2 on SAM.gov on 2/21/24.

The incumbent Lessor’s expression of interest indicated that a rate would be REDACTED per RSF for the renewal option.

See Figure 1 below for the results of the market research and SAM notice, including the incumbent.

Address Source [EOI/CoStar, etc.] Estimated Full Service Rental Rate

501 S. Vincent Ave., West Covina, CA

EOI REDACTED

100 N Barranca St., West Covina, CA

CoStar REDACTED

2934 E Garvey Ave, West Covina, CA

CoStar REDACTED

933 Glendora Ave., West Covina, CA

CoStar REDACTED

4900 Rivergrade Rd., West CoStar REDACTED

501 Vincent LLC (Incumbent)

Covina, CA

^adjusted for CoStar market average operating rent of REDACTED.

^^adjusted for REDACTED yearly market escalations.

Figure 1: Market Research Comparables

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

SSA is satisfied with the leased space and the GSA Lease Administration Manager confirmed the Lessor is responsive. There are no documented fire protection and life safety deficiencies for the location. There have been no previous renewal options added to this lease and there is no increase in square footage.

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

ACQUISITION.

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 addition of one renewal option 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.

3/5/2024 REDACTED Date

Susan Baghdikian, 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.

Eric Johnson, Leasing Specialist

CONCUR:

Peter Zepeda, Branch Chief

Jessica L. Escobedo R9 Leasing Advocate for Competition

3/11/2024

Pamela Collins, Director Real Estate Acquisition Division

3/11/2024

Marilyn Paik, Reviewing Attorney R9 Assistant Regional Counsel

3/12/2024

Amanda Sweeney Deputy Regional Commissioner

APPROVED: REDACTED

Date

3/12/2024

Dan R. Brown, HCA Regional Commissioner Public Buildings Service Pacific Rim Region