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Justification for Other Than Full and Open Competition, Extension

This is a Justification for Other Than Full and Open Competition (J&A) document for a lease extension submitted by the U.S. General Services Administration's PBS Office of Leasing on behalf of the USDA Forest Service.

The General Services Administration seeks approval to extend Lease Number LCA03296 for office space located at 825 North Humboldt Avenue, Willows, California, without competitive bidding. The current lease expired on March 31, 2026, and the space is in holdover status. The extension request covers 17,938 ABOA / 26,635 rentable square feet of office space for a 60-month period commencing April 1, 2026. The Government invokes 41 U.S.C. 3304(a)(1) (sole source authority) under FAR 6.103-1 and GSAR 570.405, citing unexpected delays in acquiring replacement space. The succeeding lease project (3CA1534), which began in November 2023, has been delayed and paused as of November 12, 2024, with further delays occurring after March 2025 due to GSA reorganization and changes in lease contracting officers. Additionally, the USFS has changing space requirements and must validate long-term housing needs before proceeding. Market research conducted on June 18, 2026, using CoStar found no available properties in Willows meeting the agency's minimum requirements; therefore, escalation-based analysis was performed to establish fair and reasonable pricing within current market ranges. The justification emphasizes that relocating to an alternative location would require relocation costs and operational disruption, making extension of the current lease the most economical course of action. The document was signed by Lease Contracting Officer Yen Banh on July 6, 2026, and approved by Competition Advocate Gina DiTommaso on July 14, 2026.

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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: 6CA1224

Agency Name: USDA Forest Service (USFS)

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

The General Services Administration currently leases 17,938 ABOA / 26,635 rentable square feet (RSF) of office space at 825 N Humboldt Ave, Willows, CA under lease number LCA03296 for the USFS, which is currently in holdover because LCA03296 expired on March 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 60 months to commence on April 1, 2026.

The estimated cost of this lease extension is 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

A 5-year extension to Lease LCA03296, which expired on March 31, 2026, is required to get LCA03296 out of holdover and to protect Government occupancy while the long-term succeeding lease project (3CA1534) is completed. Although 3CA1534 began on or about November 2023, the succeeding lease project appears to be delayed and/or paused after November 12, 2024.

Further, given USFS’s changing needs, the long-term succeeding lease action (3CA1534) remains on pause until USFS validates its long-term housing requirements for 3CA1534.

The government is consolidating various agencies and the contracting officer needs to extend the terms of some leases to establish a common expiration date

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Revised MAR 2026

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 to get LCA03296 out of holdover and to protect Government occupancy while the Government works through issues that caused the following unexpected delays that the Government encountered.

a. Although the succeeding lease procurement, 3CA1534, began on or about November 2023, 3CA1534 appears to be delayed and/or paused after November 12, 2024.

b. Further, due to impacts of GSA Reduction in Force and Re-Organization in 2025, including but not limited to changes of Lease Contracting Officers for 3CA1534, work on 3CA1534 was further delayed and/or paused after March 2025.

c. Furthermore, given USFS’ changing needs, the long-term succeeding lease procurement action remains on pause until USFS validates its long-term housing requirements for 3CA1534.

Award to other than the current Lessor would require relocation of the entire requirement and would cause USFS 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 Willows, CA showed the rental rate within the market area ranges from .

Therefore, the anticipated rental rates for this lease extension of , 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 June 18, 2026, market research was conducted using CoStar, which showed “no properties in the target area of Willows, CA, meet the agency’s minimum requirement.” Accordingly, market research was conducted using escalations based on current rates. 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.

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File details come from the government source that posted it. Updated .