JOFOC Extension DEA (6IL0467) Redacted.pdf

Revised MAR 2026

Justification for Other Than Full and Open Competition, Extension

U.S. General Services Administration

PBS, Of f ice of Leasing

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

PROJECT NUMBER: 6IL0467

LEASE NUMBER: LIL18739

AGENCY NAME: JD DRUG ENF

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

The General Services Administration currently leases 25,000.00 ABOA/25,100.00 rentable square feet (RSF) of of fice space at Halsted Pershing Business Center, 815 W PERSHING RD, CHICAGO, IL under lease number LIL18739 for the JD DRUG ENF. The current lease expires May 10, 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 May 11, 2027.

The cost of this lease extension is $22.83 per rentable square feet for year 1 with a 3.75% annual escalation for years 2-5. The total contract value of this lease extension is $3,610,592.14.

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 of f icer 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, f inancial, 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. JD DRUG ENF’s mission requires they stay at their current location. The agency is still reviewing their long term space requirements. Time will not permit completion of a long-term procurement before lease expiration. And the incumbent lessor will not agree to an extension shorter than a 5-year term. Award to other than the current Lessor would require relocation of the entire requirement and would cause JD DRUG ENF 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.

The negotiated extension rate remains above the current GSA market assessment, the Lease Contracting Of f icer determined that awarding the extension is in the best interest of the Government. The negotiated extension will ensure continuity of operations and protect the Governments continued occupancy while providing suf f icient time to complete the long-term housing strategy and avoid the signif icant costs, schedule impacts, operational disruptions that would result f rom a lapse in occupancy or a short-notice relocation. Accordingly, the benef its of maintaining uninterrupted occupancy outweigh the premium associated with the negotiated extension rental rate.

Although the Lessors proposed extension rental rate is approximately 49 percent above the Government’s Pre-Award Assessment, acceptance of the proposal is determined to be in the best interest of the Government. Executing the lease extension will protect the Government’s continued occupancy and ensure uninterrupted mission operations while maintaining the agency’s presence in its existing location. In evaluating the Lessors proposal, GSA also reviewed current market data. A CoStar market analysis was conducted using comparable properties within the subject market. The reported rental rates for comparable properties were generally consistent with the Lessors proposed rates. Additionally, the CoStar comparable rates were quoted on a triple-net (NNN) basis, whereas the Lessors proposed extension rate is for a fully serviced lease. As a result, the Lessors proposed fully serviced rental rate represents additional value to the Government because it includes operating expenses and services that would otherwise be borne separately under a triple-net lease structure. Based on the market analysis, the comparable lease structures, and the operational need to preserve the agency’s continued occupancy without disruption, GSA has determined that acceptance of the Lessors proposed extension rental rate is fair and reasonable under the circumstances and represents the best value and best interest of the Government.

7. DESCRIPTION OF MARKET RESEARCH CONDUCTED AND THE RESULTS.

On May 20, 2026, market research was conducted using CoStar Report. The market research showed the rental rate within the market area ranges f rom $28.47 to $222.22. The GSA Pre-Award assessment received on June 24, 2026, indicated the proposed extension levelized rates were 49.4% above market.

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

Executing a 60-month lease extension at the current location is in the Governments best interest, as it prevents the lease f rom entering holdover status and ensures uninterrupted mission operations. The Lessor has advised that it will not consider an extension for a term shorter than f ive years.

Based on the information currently provided by DEA, the Government is not anticipated to incur signif icant risk by executing a f ive-year extension. DEA has indicated that additional time is needed to evaluate its long-term space requirements and formally submit those requirements to GSA. Furthermore, DEAs new or replacement lease procurements have historically required approximately three to four years to complete due to the specialized nature of the agency’s space requirements, the complexity of the Revised MAR 2026 acquisition process, and the time necessary to secure project funding. Accordingly, the proposed 60-month extension provides adequate time for long-term planning while maintaining continuity of operations.

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 Governments tenant improvements, the Government will consider the cost of moving f rom 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 Justif ication for Other than Full and Open Competition, the GSA Lease Contracting Of f icer certif ies that the award of a lease extension of 60 months for LIL18739 is in the Government’s best interest and that this Justif ication is accurate and complete to the best of the GSA Lease Contracting Of f icer’s knowledge and belief .

Melissa McKenna Date Lease Contracting Of f icer Branch Chief - Post Occupancy Division

12. PREPARER’S TECHNICAL CERTIFICATION

I certify that the supporting data used to form the basis of this Justif ication is complete and accurate to the best of my knowledge and belief .

L. Elaine Henderson Date

Concurred by:

Melissa McKenna Date

Acting Director - Post Occupancy Division

Concurred by:

Heather Cameron Date Senior Assistant General Counsel Real Property Law Division Of f ice of the General Counsel

Approved by:

Gina DiTommaso Date Competition Advocate