JOFOC 6IL0502 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: 6IL0502

Agency Name: Department of Transportation (DOT) Federal Aviation Administration (FAA)

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

The General Services Administration currently leases 158,137 ABOA / 188,768 rentable square feet (RSF) of office space and 760 parking spaces at 2300 E DEVON AVE, DES PLAINES, IL under lease number GS-05P-LIL16200 for the DOT FAA. The current lease expires October 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).

FAA’s mission is to provide the safest, most efficient aerospace system in the world. The role of the FAA Airports organization in meeting this goal is to provide leadership in planning and developing a safe and efficient national airport system to satisfy the needs of aviation interest in the United States.

The FAA has been housed in their current lease location since 1971. New leased space for the replacement of GS-05P-LIL16200 has been procured under Prospectus Number PIL-01-OH22. The new lease was awarded on September 29, 2023 and the space is currently under construction. Prospectus Number PIL-01-OH22 provides interim leasing authority, specifically, “GSA will execute such interim leasing actions as are necessary to ensure continued housing of the tenant agency prior to the effective date of the new lease. It is in the best interest of the Government to avert the financial risk of holdover tenancy.” In accordance with this authority and to ensure continued housing of the tenant agency, the Government requires an extension of the current lease for 9 months, 6 months firm to commence on October 21, 2026. This short-term lease extension is necessary to allow time for the new location to be ready for occupancy. The estimated cost of this lease extension is per rentable square feet per year for a total contract value of .

The delineated area is:

North: West Palatine Road to Willow Road; East: I-94E to I-90E to West Addison Street to North Pulaski Road to West Diversey Avenue; South: West Diversey Avenue to Route 43 to Grand Avenue to Route 20;

West: I-355W to I-290W to Route 53 to West Palatine Road.

There is no Federal space that can meet the needs of this requirement.

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.

The agency occupying the leased space is scheduled to move into other Federally controlled space, but encountered unexpected delays in preparing the new space for occupancy. FAA is responsible for furniture procurement and installation at the new long-term housing solution. A 9-month, 6-month firm lease extension, effective October 21, 2026, is needed to allow time for the furniture contract to be awarded, designed, and installed at the new location. Award to other than the current Lessor would require relocation of the entire requirement and would cause the DOT FAA to incur move and replication costs that would not be recovered through competition. Temporary relocation would be a severe disruption to FAA’s operation at this location and would result in duplication of costs estimated to be million (tenant improvement costs of million; security systems costs of million; IT costs of ).

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 the O’Hare Office Submarket showed the area market ranges from to . The anticipated rental rate of

. This rate reflects a premium often associated with short-term lease extensions. CoStar also does not consider costs of the 760 parking spaces under the lease. Considering the replication costs associated with relocating FAA to other leased space, it has been determined that it is advantageous for the Government to remain in the existing location on an interim basis until the new leased location is ready for occupancy.

Therefore, the anticipated rental rate for this lease extension of per RSF, for long-term leased rental rates for this submarket, is deemed fair and reasonable by the GSA

Lease Contracting Officer due to the short-term nature of this lease extension.

7. DESCRIPTION OF MARKET RESEARCH CONDUCTED AND THE RESULTS.

On July 27, 2026, market research was conducted using Co Star. No comparable properties were identified in the delineated area that could meet the square footage requirement. However, the market research showed the market area rental rates range from to . The anticipated rental rate of reflects a premium often associated with short-term lease extensions and CoStar also does not consider costs of the 760 parking spaces under the lease. It is noted that the current lessor is performing services required per the contract. As outlined above, it is in the best interest of the Government to remain in the existing location until the new leased location is ready for occupancy.

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

Remaining at the current location under a 9-month, 6-month firm extension avoids a holdover and allows the Government to continue operations without disruption. The incumbent lessor can house the Government’s current requirement for office space and parking space until the long-term housing solution is ready for occupancy. If the Government were to move, the disruption to FAA operations would adversely impact the agency’s mission and the costs to relocate FAA on a temporary basis outweigh the cost to remain in place.

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 9 months, 6 months firm for GS-05P-LIL16200 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_____________________ Christopher Bonfiglio, 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______________________ Christopher Bonfiglio, Leasing Contracting Officer

Concurred by:

Charels Vitale FOR Katrina Trimble Date Branch Chief, Moderate Risk Lease Acquisition Division, PRACC

Charles Vitale Date Director, Moderate Risk Leasing Acquisition Division West, PRAC

Reviewed for legal sufficiency by:

Leigh Erin S. Izzo Date Senior Assistant General Counsel, Office of the General Counsel, Real Property Law Division

Gina DiTommaso Date Competition Advocate

Approved by:

Crofton Whitfield Date Head of Contracting Activity