JOFOC.pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SECTION 1: IDENTIFICATION OF THE AGENCY AND THE CONTRACTING ACTIVITY

Department of State Contracting Activity

☒ Overseas Post Rome, Italy

Requiring Activity Facility Section, Rome, Italy

SECTION 2: NATURE AND/OR DESCRIPTION OF THE ACTION BEING APPROVED

Approval is requested to award on a sole-source basis to GEA Restauri Srl for the repairs and refurbishments project described in Section 3 on behalf of the Requiring Activity.

The expiration date of this authority to act under a Class Justification and Approval (J&A) is September 30, 2025.

The result of this action shall be a Firm-Fixed-Price (FFP) contract.

SECTION 3: DESCRIPTION OF SUPPLIES/SERVICES REQUIRED TO MEET THE AGENCY’S NEEDS

Background

Embassy Rome plans to undertake repairs and refurbishments at Villa Taverna, the Rome Chief of Mission Residence (CMR). The renovation will include refurbishing the air conditioning system in the Ambassador's private quarters and second floor, as well as replacing four bathrooms and a kitchenette located on the second floor, including the Presidential Suite area.

The scope of work includes:

• Installation of heating, ventilation, and air conditioning equipment

• Plumbing and electrical system replacement

• Installation of new cabinetry

• Wall and floor tiling installation

• Masonry work

• Specialized air conditioning services

The estimated period of performance will begin immediately after the award, ensuring compatibility with the CMR's official events and the Ambassador's stay.

The estimated value of this project is US dollars $500,000.00.

SECTION 4: IDENTIFICATION OF THE STATUTORY AUTHORITY PERMITTING OTHER THAN

FULL AND OPEN COMPETITION

This acquisition is conducted under the authority of 41 USC 3304, as implemented by FAR 6.3 and substantiated by the following:

☒ FAR 6.302-2 – Unusual and compelling urgency.

SECTION 5: DEMONSTRATION THAT THE PROPOSED CONTRACTOR’S UNIQUE

QUALIFICATIONS OR THE NATURE OF THE ACQUISITION REQUIRES USE OF THE AUTHORITY

CITED

The contractor’s unique qualifications are needed because the project is exceptionally complex. The repairs and refurbishments project is exceptionally complex for the following reasons: the property, constructed in the 15th century, is listed on the Secretary of State’s Register of Culturally Significant Property; the villa is the permanent residence of the US Ambassador to Italy; the villa is regularly used as temporary quarters for the President, Vice President, Cabinet Secretaries, and other high level officials and dignitaries; and, the villa is utilized for significant high level diplomatic meetings and events. Recent bathroom plumbing failures have disrupted villa operations. Recent radon tests have dictated the need to upgrade HVAC systems to ensure the health and safety of occupants. The requirement to maintain villa operations will necessitate the work to start immediately but shift to phases as villa operations dictate. Delays in the project could disrupt representational functions and diplomatic engagements, which are critical to the U.S. Government’s relationship with the host nation.

GEA Restauri (GEA) has been chosen due to their demonstrated extensive knowledge and experience in construction projects in Villa Taverna. GEA recently completed a project in Villa Taverna of similar scope, complexity, and cost. GEA has a thorough understanding of the existing systems and infrastructure, including specialized air conditioning systems, plumbing and electrical systems. This familiarity ensures efficient integration of new systems with existing infrastructure, minimizing risks and delays. GEA also understands the unique nature of villa operations and has successfully performed work. GEA has coordinated closely with the Ambassador and his family.

GEA has been an Embassy contractor for more than 15 years. They possess specialized capabilities in air conditioning system refurbishment, plumbing, and electrical systems, which are critical for the renovation of the Presidential Suite area. Their expertise in wall/floor tiling and cabinetry installation further supports the unique requirements of this project. These capabilities align with the Department of State’s standards for representational areas, ensuring both aesthetic and functional requirements are met. GEA has the proven capacity and flexibility to shift its work plan to satisfy the unpredictable demands of the villa operations.

SECTION 6. DESCRIPTION OF EFFORTS TO ENSURE THAT OFFERS WERE SOLICITED FROM AS

MANY POTENTIAL SOURCES AS IS PRACTICABLE, INCLUDING WHETHER A NOTICE WAS OR

WILL BE PUBLICIZED AS REQUIRED BY FAR SUBPART 5.2 AND, IF NOT, WHICH EXCEPTION

UNDER FAR 5.202 APPLIES

A synopsis of the proposed procurement was not published on SAM.gov because the contract action is being made under the conditions described in FAR 6.302-2, which allows for exceptions due to unusual and compelling urgency. Specifically, FAR 5.202(a)(2) provides an exception to the requirement for publishing a synopsis when the urgency of the need precludes delays associated with the synopsis process. Given the critical nature of the renovation and its impact on official representational functions, this exception applies.

Preliminary market research was conducted in accordance with FAR Part 10 to identify potential sources capable of meeting the requirements. This research included reviewing past performance records, consulting with subject matter experts, and analyzing the availability of contractors with the necessary expertise, security clearances, and familiarity with the Villa Taverna CMR infrastructure. The results confirmed that GEA Restauri is uniquely positioned to fulfill the requirements efficiently and within the urgent timeline.

Further market research was deemed unnecessary due to the urgency of the requirement.

SECTION 7. DETERMINATION BY THE CONTRACTING OFFICER THAT THE ANTICIPATED COST

TO THE GOVERNMENT IS FAIR AND REASONABLE

The Contracting Officer has anticipated the cost to be USD $500,000, which has been deemed fair and reasonable based on:

1. The proposed cost is consistent with pricing from previous renovation projects completed by GEA Restauri, including their recent work in the Ambassador's private quarters, and by other contractors carrying out similar work.

2. An IGCE was developed based on the scope of work, including specialized air conditioning refurbishment, plumbing, electrical systems, cabinetry installation, and masonry work. The proposed cost aligns closely with the IGCE, confirming its reasonableness.

3. Market research was conducted to assess prevailing rates for similar renovation services in the local area. The proposed cost is consistent with market prices for high-quality renovation work involving specialized systems and finishes, further supporting its fairness.

By signing the justification, the Contracting Officer makes the determination that the USD $500,000 to the Government is expected to be fair and reasonable.

SECTION 8. DESCRIPTION OF THE MARKET RESEARCH CONDUCTED (SEE PART 10) AND THE

RESULTS OR A STATEMENT OF THE REASON MARKET RESEARCH WAS NOT CONDUCTED

Market research was limited due to the compelling and unusual urgency of the requirement. The immediate need to renovate the Villa Taverna CMR, including the Presidential Suite area, precluded a broader search for alternative sources. The urgency of the project, combined with GEA Restauri’s proven expertise and availability, supported the decision to limit competition.

The research focused on contractors with experience in high-profile government property renovations, specialized capabilities in air conditioning systems, plumbing, electrical systems, and masonry work.

SECTION 9. ANY OTHER FACTS SUPPORTING THE USE OF OTHER THAN FULL AND OPEN

COMPETITION

The required delivery schedule is immediate, with work beginning upon contract award. GEA Restauri’s availability to start work immediately ensures that the project aligns with the operational schedule of the Villa

Taverna CMR. Pursuing competition would result in delays that are prohibitive and would not support program requirements.

The renovation project must be completed within 12 months to ensure compatibility with the Ambassador’s stay and official events. The lead time required for onboarding a new contractor and conducting first article testing is prohibitive and would not support the program requirements. GEA Restauri’s familiarity with the infrastructure eliminates the need for first article testing, ensuring timely completion of the project and saving Government costs.

SECTION 10. LISTING OF THE SOURCES, IF ANY, THAT EXPRESSED, IN WRITING, AN INTEREST

IN THE ACQUISITION

None

SECTION 11. STATEMENT OF THE ACTIONS, IF ANY, THE AGENCY MAY TAKE TO REMOVE OR

OVERCOME ANY BARRIERS TO COMPETITION BEFORE ANY SUBSEQUENT ACQUISITION FOR

THE SUPPLIES OR SERVICES REQUIRED

The Government recognizes the importance of fostering full and open competition for future acquisitions of similar supplies or services.

SECTION 12. CERTIFICATIONS

All reviews and approvals should be completed in the order listed unless otherwise authorized or required.

TECHNICAL AND REQUIREMENTS CERTIFICATION (FAR 6.303-2(b))

I certify that the facts and representations under my cognizance which are included in this Justification and its supporting acquisition planning documents, except as noted herein, are complete and accurate to the best of my knowledge and belief.

Technical Cognizance:

SIGNATURE:

Name Date Title

CERTIFICATIONS (Continued)

CONTRACTING OFFICER CERTIFICATION (FAR 6.303-2(a)(12)) I certify that this submission is accurate to the best of my knowledge, and that it contains complete information necessary to enable other officials to make an informed recommendation for approval or disapproval.

SIGNATURE:

Contracting Officer

09/23/2025 15:29 GMT

Kerns, Michael (KernsMF@state.gov)

09/24/2025 06:13 GMT

Sheridan, Crystal (SheridanCD@state.gov)

SECTION 13. APPROVALS

HCA

Management Counselor

09/24/2025 13:01 GMT

Richards, Cynthia (RichardsCS@state.gov)

09/24/2025 15:46 GMT

Simons, David (SimonsDW@state.gov)