JUSTIFICATION AND APPROVAL_GLS Interim Contract Action_2025 10 31.pdf

J&A, Other Than Full and Open, GSA Leasing Support Services, Interim Contract

JUSTIFICATION AND APPROVAL

OTHER THAN FULL AND OPEN COMPETITION

GSA LEASING SUPPORT SERVICES

1. Contracting Activity

The General Services Administration (GSA), Public Building Service (PBS), Office of Leasing plans to contract by means other than full and open competition. This is a Sole Source

Justification (SSJ).

2. Nature and/or Description of the Action Being Approved

This justification supports the award of a sole source contract for Leasing Support Services to ensure continued performance of critical services during the transition between the current GLS

Plus contract and the future GLS Max contract. The bridge contract will be executed on a sole source basis under the authority of FAR 6.302-2, Unusual and Compelling Urgency. The justification detailing the unusual circumstances and compelling urgency precluding full and open competition, and the serious injury to the Government if there is a delay in award is detailed in this justification.

The contract will provide for a base period of six (6) months, with options to extend, if necessary, to cover the gap in services anticipated due to delays in awarding the follow-on contract.

The total estimated value, based on maximum net commissions for a one-year period, is

$520,535,557.

3. Description of Supplies or Services Required

GSA PBS is responsible for the acquisition and administration of leasehold interests and other real estate services in support of other federal agencies. As of the end of FY 2023, GSA had a total leased inventory of 7,638 leases with 177,404,648 square feet in 6,551 buildings located across the United States and territories.

Since the mid-1990s, GSA's lease acquisition workload has increased while the staffing of realty personnel has decreased. With directions to downsize and combine like efforts in the mid-1990s, GSA regional offices awarded eight (8) different real estate broker contracts to the private sector to test the feasibility of outsourcing GSA's Realty services. Over time, PBS recognized the regional contracts containing differing terms, conditions, and pricing structures. Following an

Inspector General (IG) report in 2002 which identified multiple problems, GSA sought to centralize this function through the award of a national broker contract. Through various iterations, the national broker contract has become a critical part of fulfilling GSA’s mission to provide leased space to federal agencies.

The current contract, GLS Plus, was awarded on 13 May 2020. GLS Plus was awarded with four geographic zones and a menu of services. Each zone covers multiple regions, with the exception of the fourth zone, which covers only Region 11. Two contracts were awarded per zone, with the exception of the fourth zone which had three contract awards. The zonal awards, administered nationally, continued the consistency of services provided by the contractors within zones, and opened the national requirement to small businesses. The final option year of GLS Plus was set to expire on 15 July 2025. GLS Plus contract is currently under a three-month extension through

15 Oct 2025 under FAR 52.217-8, with option to be extended through 15 January 2026.

A replacement contract, GLS Max, was in development with the solicitation set to be issued in early 2025. As the solicitation was in development, the government offered the Deferred

Resignation Program (DRP) for employees wishing to exit federal service. All 1102 contracting personnel previously responsible for administering the leasing program participated in the DRP, leaving the office without qualified lease acquisition staff at a critical time. A new team was assigned to draft the GLS Max solicitation; however, unforeseen administrative challenges have delayed the procurement process for an estimated six to nine months.

The Leasing Support Services contract delivers mission-critical real estate support to agencies across the Federal Government and the Department of Defense (DoD). Due to the essential nature of these services, any gap in contract coverage would result in unacceptable operational disruptions.

4. Identification of the Statutory Authority Permitting Other Than Full and Open Competition

The statutory authority permitting other than full and open competition is 10 U.S.C. § 3204(a)(2)

/ 41 U.S.C. § 3304(a)(2), as implemented by FAR 6.302-2 – Unusual and Compelling Urgency.

5. Demonstration the Nature of the Acquisition Requires Use of Authority Cited

This justification is based on the urgent and compelling need to maintain continuity of mission-critical services. A lapse in Leasing Support Services would severely hinder GSA’s ability to acquire and manage leased space for Federal and DoD agencies. The current contractors are already fully mobilized, integrated into GSA systems, and have the necessary knowledge of ongoing projects, which makes them best positioned to provide seamless continuation of services under this bridge contract. GSA is currently developing the solicitation for the replacement contract, GLS Max. This effort is expected to take a minimum of six to nine months to get to award. Post-award, any new contractors will require additional time getting security requirements and training prior to being issued a notice to proceed.

6. Description of Efforts Made to Ensure Offers Are Solicited from as Many Sources as

Practicable

Given the urgency of the requirement and the short timeline between the expiration of the current contract and the anticipated award of GLS Max, GSA will not have sufficient time to conduct a competitive acquisition for interim services. A new competition will take months to develop, risking a lapse in services. However, efforts will be made to ensure that the GLS Max solicitation is completed and awarded as quickly as possible. Given these circumstances, GSA plans to issue a 6-month bridge contract with option to extend services under FAR 52.217-8 for up to an additional 6-month period up to one year, not to exceed the time necessary for the agency to enter into another contract through use of competitive procedures.

7. Determination by the Contracting Officer That the Anticipated Cost to the Government Will

Be Fair and Reasonable

The Contracting Officer will determine the price to be fair and reasonable by utilizing price analysis techniques to include market rates, comparison with previous contract prices (including the GLS Plus rates), independent government cost estimates, and any available historical pricing data. The short duration and scope of the bridge will be limited to the minimum required to meet urgent needs, helping to ensure reasonable cost.

8. Description of the Market Research Conducted

Due to the urgency and the short duration of the bridge contract, extensive market research was not feasible. Prior market research from the GLS Max acquisition effort has shown the existence of multiple capable sources. This bridge contract is only intended as a stopgap measure to allow time for a full and open competition for GLS Max.

9. Any Other Supporting Facts

The GLS Plus contract expired on 15 July 2025 and is currently operating under a FAR

52.217-8 extension, which cannot be extended beyond 15 January 2026.

All 1102 contracting personnel previously responsible for administering the GLS Plus contract participated in the deferred resignation program, leaving the office without qualified acquisition personnel at a critical time.

A new acquisition team was assigned to draft the GLS Max solicitation in April 2025.

The new team faced delays after being tasked with developing an alternate acquisition strategy that aligned with the new administration’s goals

Current and projected leasing task volumes have increased, making continued support critical. A lapse in services would result in a significant backlog in lease actions, affecting space delivery to federal agencies and possibly resulting in higher lease costs due to delays.

The estimated cost to the Government based on the value of lease actions that would not be acquired are $2,602,677,787

10. Listing of Sources, if Any, That Expressed Interest in the Acquisition

All current contractors under the GLS Plus IDIQ will be contacted. The GLS Plus award includes eight contracts; however, two contractors hold separate contracts in different geographical zones, resulting in a total of six distinct active contractors.

GLS Plus

Zone 1

47PA0520D0009 Jones Lang LaSalle, Americas, Inc.

47PA0520D0008 CBRE, Inc.

Zone 2

47PA0520D0005 Savills, Inc.

47PA0520D0004 Public Properties

Zone 3

47PA0520D0007

Carpenter/Robbins Commercial Real Estate, Inc.

47PA0520D0006 Cushman & Wakefield

Zone 4

47PA0520D0003 CBRE, Inc.

47PA0520D0002 Public Properties

47PA0520D0001 Savills, Inc.

All interested vendors will have an opportunity to compete under the full and open GLS Max solicitation once released.

11. Actions the Agency May Take to Remove or Overcome Barriers to Competition in the Future

GSA is actively finalizing the GLS Max competitive solicitation, which will be issued under full and open competition. This bridge is solely to address the gap period for the minimum amount of time required and will not be used to delay or replace a competitive acquisition.

Certifications/Concurrences/Approvals

1. Requirements Personnel: I certify that any supporting data that is the responsibility of technical or requirements personnel (e.g., verifying the Government’s minimum needs or requirements or other rationale for limited sources) and which form a basis for the justification are complete and accurate.

Signature Date

Name: Crofton Whitfield

Title: Assistant Commissioner, Leasing Division

PBS Office of Leasing

2. Concur: Office of General Counsel

Name: Heather R. Cameron

Title: Senior Assistant General Counsel

3. Approved: Contracting Officer

- I certify that the justification is accurate and complete to the best of my knowledge and belief.

- I have determined that the order represents the best value (as defined in FAR 2.101) and results in the lowest overall cost alternative (considering price, special features, administrative costs, etc.) to meet the Government’s needs.

Name: Felipe Jolles

Title: Contracting Officer

4. Concur: One-Above the Contracting Officer

Name: John Kelley

Title: Supervisory Contract Specialist

5. Approved: Competition Advocate

Name: G.W.Emge

Title: PBS Acting Regional Commissioner, Region 8

6. Approved: Head of Contracting Activity

Signature Date

Name: Liliana DelBonifro

Title: Deputy Assistant Commissioner

Office of Acquisition Management

7. Approved: Senior Procurement Executive

__10/31/2025__________

Date

_//S// Approved on a separate document_

Signature

Name: Jeffery Koses

Title: GSA Senior Procurement Executive