JOFOC Ext Data (6MN0208)_Redacted.pdf
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- Attached to
- Lease Extension Without Competition
- Solicitation number
- 6MN0208
About this file
Justification for Other Than Full and Open Competition, Extension
This is a Justification for Other Than Full and Open Competition (JOFOC) for a lease extension filed by the U.S. General Services Administration, PBS Office of Leasing, for Project Number 6MN0208. GSA seeks to extend the current lease for 31,257.00 assignable square feet and 35,905.00 rentable square feet of office space at 100 Washington Building, 100 Washington Avenue South, Minneapolis, Minnesota, under lease number LMN18281. The current lease expires January 31, 2027, and GSA requests approval to negotiate a 60-month extension with the incumbent lessor commencing February 1, 2027, without full and open competition.
The justification cites 41 U.S.C. 3304(a)(1) and implements authority through FAR 6.103-1 and GSAR 570.405 for sole-source authority. The contracting officer selected the rationale that the government encounters unexpected delays outside its control in acquiring replacement space. GSA asserts that remaining at the current location is in the government's best interest while revising long-term space requirements to comply with the USE IT Act and utilization rate requirements. Market research conducted on August 12, 2026, using Bullseye and CoStar demonstrated that the anticipated rental rates fall within current market range and are fair and reasonable. The extension avoids operational disruption from relocation and unnecessary move and replication costs. GSA notes that lessors increasingly cannot secure financing for three-year extensions and are unwilling to sign short-term deals; GSA policy now permits extensions up to five years to secure mission-critical space and provide time for subsequent full and open procurement. The document was signed by Lease Contracting Officer Kovas Palubinskas on September 28, 2026, and received concurrences from Thomas Nisivaco (one level above LCO), Gina Ditommaso (Competition Advocate), and Robert Foltman (Office of the General Counsel, Real Property Law Division).
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Text version
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: 6MN0208
Agency Name:
1. NATURE AND/OR DESCRIPTION OF ACTION BEING APPROVED.
The General Services Administration currently leases 31,257.00 ABOA/35,905.00 rentable square feet (RSF) of office space at 100 WASHINGTON BUILDING, 100 WASHINGTON AVE S , MINNEAPOLIS, MN under lease number LMN18281 for the The current lease expires January 31, 2027.
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 February 1, 2027.
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. It is in the best interest of the Government to remain in their current location as they revise their long term requirements to meet USE IT Act and utilization rate requirements. Award to other than the current
Docusign Envelope ID: F8E410CD-36AE-8F50-814D-7EAFEF94995A
Lessor would require relocation of the entire requirement and would cause to incur move and replication costs that would not be recovered through competition.
Lessors are increasingly unable to secure financing for three-year extensions and are no longer willing to sign short term deals in many markets. GSA policy has followed suit, and now permits extensions up to 5 years. Committing to a 5 year extension term is necessary to secure this mission-critical space and provide sufficient time to conduct a full an open procurement after submits its long-term requirements.
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 MINNEAPOLIS, MN showed the rental rate within the market area ranges from .
Therefore, the anticipated rental rates for this lease extension of per RSF, are within the current market range for this submarket and are deemed fair and reasonable by the GSA Lease Contracting Officer. It is noted that this rental rate includes parking for 56 spaces, which runs per space per month in the CBD of Minneapolis.
7. DESCRIPTION OF MARKET RESEARCH CONDUCTED AND THE RESULTS.
On August 12, 2026, market research was conducted using Bullseye, CoStar. 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.
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.
Docusign Envelope ID: F8E410CD-36AE-8F50-814D-7EAFEF94995A
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 60 months for LMN18281 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_____________________ Kovas Palubinskas, 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______________________ Kovas Palubinskas, Lease Contracting Officer
Concurred by:
Thomas Nisivaco Date
One Level above LCO (if applicable)
Concurred by:
Gina Ditommaso Date
Competition Advocate (if applicable)
Reviewed for legal sufficiency by:
Robert Foltman Date
Office of the General Counsel, Real Property Law Division (if applicable)
Docusign Envelope ID: F8E410CD-36AE-8F50-814D-7EAFEF94995A
9/28/2026 | 16:55:11 BST
9/28/2026 | 16:55:11 BST
9/29/2026 | 13:39:51 BST
9/29/2026 | 13:41:44 BST
9/29/2026 | 21:24:39 BST
Certificate Of Completion Envelope Id: F8E410CD-36AE-8F50-814D-7EAFEF94995A Status: Completed
Subject: Complete with Docusign: JOFOC Ext Data (6MN0208).pdf
Source Envelope:
Document Pages: 3 Signatures: 5 Envelope Originator:
Certificate Pages: 2 Initials: 0 Kovas Palubinskas
AutoNav: Enabled
EnvelopeId Stamping: Enabled
Time Zone: (UTC) Dublin, Edinburgh, Lisbon, London
1800F F St NW
Washington DC, DC 20405 kovas.palubinskas@gsa.gov
IP Address: 136.226.18.73
Record Tracking Status: Original
9/28/2026 4:52:33 PM
Holder: Kovas Palubinskas kovas.palubinskas@gsa.gov
Location: DocuSign
Security Appliance Status: Connected Pool: FedRamp
Signer Events Signature Timestamp Kovas Palubinskas kovas.palubinskas@gsa.gov
Lease Contracting Officer
US General Services Administration
Security Level: Email, Account Authentication (None)
Signature Adoption: Pre-selected Style
Using IP Address: 136.226.18.73
Sent: 9/28/2026 4:54:38 PM
Viewed: 9/28/2026 4:54:56 PM
Signed: 9/28/2026 4:55:11 PM
Electronic Record and Signature Disclosure:
Not Offered via Docusign
Thomas Nisivaco thomas.nisivaco@gsa.gov
LCO
US General Services Administration
Security Level: Email, Account Authentication (None)
Signature Adoption: Pre-selected Style
Using IP Address: 136.226.15.34
Sent: 9/28/2026 4:55:12 PM
Viewed: 9/29/2026 1:39:41 PM
Signed: 9/29/2026 1:39:51 PM
Electronic Record and Signature Disclosure:
Not Offered via Docusign
Robert Foltman robert.foltman@gsa.gov
US General Services Administration
Security Level: Email, Account Authentication (None) Signature Adoption: Pre-selected Style
Using IP Address: 136.226.18.50
Sent: 9/29/2026 1:39:52 PM
Viewed: 9/29/2026 1:40:41 PM
Signed: 9/29/2026 1:41:44 PM
Electronic Record and Signature Disclosure:
Not Offered via Docusign
Gina Ditommaso gina.ditommaso@gsa.gov
For Crofton Whitfield
US General Services Administration
Security Level: Email, Account Authentication (None)
Signature Adoption: Pre-selected Style
Using IP Address: 136.226.20.89
Sent: 9/29/2026 1:41:45 PM
Viewed: 9/29/2026 9:24:19 PM
Signed: 9/29/2026 9:24:39 PM
Electronic Record and Signature Disclosure:
Not Offered via Docusign
In Person Signer Events Signature Timestamp
Editor Delivery Events Status Timestamp
Agent Delivery Events Status Timestamp
Intermediary Delivery Events Status Timestamp
Certified Delivery Events Status Timestamp
Carbon Copy Events Status Timestamp
Witness Events Signature Timestamp
Notary Events Signature Timestamp
Envelope Summary Events Status Timestamps Envelope Sent Hashed/Encrypted 9/28/2026 4:54:38 PM
Certified Delivered Security Checked 9/29/2026 9:24:19 PM
Signing Complete Security Checked 9/29/2026 9:24:39 PM
Completed Security Checked 9/29/2026 9:24:39 PM
Payment Events Status Timestamps
File details come from the government source that posted it. Updated .