JOFOC -Redacted.pdf

Revised Nov 2023

Justification for Other Than Full and Open Competition, Extension

U.S. General Services Administration

GSA Leasing

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

PROJECT NUMBER: 3VT0066

Agency Name: U.S. Citizenship and Immigration Services (USCIS)

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

The General Services Administration currently leases 52,388 ABOA/54,081 rentable square feet (RSF) of office space at 38 River Road, Essex Junction, VT under lease number LVT04942 for the U.S.

Citizenship and Immigration Services (USCIS). The current lease expires January 21, 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 January 22, 2026.

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 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.

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.

The agency had previously planned to consolidate with an adjacent lease (LVT00333) upon expiration of the current lease. This plan was developed prior to the implementation of the Return to Office (RTO) mandate. The increased on-site staffing requirements have resulted in space constraints that prevent the

Docusign Envelope ID: 56D3AE53-2478-4CFF-A2C7-2CC7B0BB4D52 agency from proceeding with the planned relocation. The agency requires continued occupancy of its current premises to ensure adequate workspace and uninterrupted operations. GSA was informed of the agency’s change of plans in February 2025. Due to time constraints and internal staffing shortages, initiating and completing a new leasing process was not feasible within the required timeframe. As a result, negotiating an extension of the existing lease was determined to be the most practical and operationally sound solution.

Discussions were held with the lessor to secure a lease extension. The lessor indicated that they were only willing to proceed under a five (5) year term with five (5) years firm. This extension was approved on the Leasing Acquisition Pause Tracker on November 18, 2025.

It is in the best interest of the Government to remain at the current location during the extension period.

Award to other than the current Lessor would require relocation of the entire requirement and would cause USCIS 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 GSAM 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 Leasing Specialist in Essex Junction, Vermont market area indicates that prevailing full-service rental rates range from

Based on the market analysis described below in Section 7, the anticipated rental rate for the proposed lease extension falls within the established market range for this submarket. Accordingly, the Lease

Contracting Officer has determined that the anticipated cost to the Government is fair and reasonable.

7. DESCRIPTION OF MARKET RESEARCH CONDUCTED AND THE RESULTS.

Market research was conducted by the Leasing Specialist in support of a lease extension on December 3, 2025, to confirm that the estimated rental rate is consistent with current market conditions. Sources included CoStar reports and analysis of comparable GSA leases within the submarket. The research showed that full-service rental rates for comparable properties range from .

The CoStar report listed three spaces for lease with sufficient square footage for this requirement. Only one space listed an asking rental rate, which was The MG rate was converted to a GSA full-service equivalent by adding , representing the average operating cost paid by GSA in the market (based on 5 other leases), fo

Additionally, a market verification call was placed to the property representative for 1060 Hinesburg Rd, South Burlington, VT, a comparable property for which pricing information was not publicly available through CoStar. Information obtained from this call confirmed an asking rate of placing the property at the upper end of the identified market range.

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. It will also allow the agency to work on a long-term plan to comply with the recent Return to Office (RTO) mandate.

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 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 60 months for LVT04942 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_____________________ Bridget Ginty, 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______________________ Eduardo DePina, Leasing Specialist

Reviewed/Concurred by:

Legal Counsel

1/13/2026

1/13/2026

1/14/2026

Approved by:

Gina DiTommaso, Competition Advocate

1/15/2026