SIGNED - 4AZ0269 - Extension Justification (JOFOC) Redacted.pdf
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- 6CA1264 - ACTIVE SAM Registration. pdf
- Solicitation number
- 4AZ0269
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This is a Justification for Other Than Full and Open Competition document for a lease extension submitted by the U.S. General Services Administration's PBS Office of Leasing.
GSA seeks approval to extend lease number LAZ03201 for 60 months commencing June 16, 2026, without full and open competition. The incumbent lessor will continue providing 31,868 ABOA/36,108 rentable square feet of office space. The extension period spans two phases: June 16, 2026 through June 15, 2029, and June 16, 2029 through June 15, 2031. The contract value and specific rental rates per RSF for shell rent and operating cost rent are redacted in the document. The statutory authority for sole-source award is 41 U.S.C. 3304(a)(1), implemented through FAR 6.103-1 and GSAR 570.405. The justification cites documented organizational and financial uncertainties delaying the agency's relocation planning to federally controlled space as the primary rationale. GSA conducted market research on July 13, 2026, using CoStar and identified zero acceptable alternative locations within the delineated area. Recent market surveys confirm the proposed rental rates fall within the current market range for the Tucson, Arizona submarket and are fair and reasonable. The document was signed and approved on August 4, 2026, by Lease Contracting Officer Christine R. Wong, with concurrence from the Branch Chief PRACA, Competition Advocate, and Office of the General Counsel.
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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: 4AZ0269
Agency Name:
1. NATURE AND/OR DESCRIPTION OF ACTION BEING APPROVED.
The General Services Administration currently leases 31,868 ABOA/36,108 rentable square feet (RSF) of office space at under lease number LAZ03201 for the
The current lease expired on June 15, 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 June 16, 2026. The estimated cost of this lease extension is per rentable square feet for June 16, 2026 – June 15, 2029 and per rentable square feet for June 16, 2029 – June 15, 2031.
Rent Type Annual Amount
06/16/2026-
06/15/2029
Annual Amount
06/16/2029-
06/15/2031
Shell Rent
Operating Cost Rent*
Total Annual Rent
Shell Rent 6/16/26 – 6/15/29 - /RSF multiplied by 36,108 RSF
Shell Rent 6/16/29– 6/15/31 - /RSF multiplied by 36,108 RSF
Operating Rent 6/16/26 – 6/15/31 - /RSF multiplied by 36,108 RSF
The total contract value of
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
Docusign Envelope ID: F44B32EE-0577-8C86-83E4-8FBDCDFEB55B
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. Additional time is needed to finalize the agency's requirements and proceed with the long term procurement. Award to other than the current Lessor would require relocation of the entire requirement and would cause 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.
Recent market surveys conducted by the LCO in Tucson, AZ, the closest market comps showed the first year fully serviced rental rate in Southern Tucson to be per RSF for industrial and -per RSF for office per CoStar.
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.
7. DESCRIPTION OF MARKET RESEARCH CONDUCTED AND THE RESULTS.
On July 13, 2026, the LCO conducted market research using CoStar and identified zero potentially acceptable alternative locations that might meet the agency’s needs within the delineated area.
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.
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 LAZ03201 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_____________________
Christine R. Wong, 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______________________ Christine R. Wong, Leasing Specialist
Concurred by:
Marissa Williams Date
Branch Chief PRACA
Concurred by:
Gina DiTommaso Date
Competition Advocate (PR)
Reviewed for legal sufficiency by:
Robert Foltman Date
Office of the General Counsel, Real Property Law Division
8/4/2026 | 07:59:39 PDT
8/4/2026 | 07:59:39 PDT
8/4/2026 | 18:12:03 BST
8/4/2026 | 21:25:04 BST
8/4/2026 | 18:14:47 BST
| Justification for Other Than Full and Open Competition, Extension |
| PBS, Office of Leasing |
| 1. NATURE AND/OR DESCRIPTION OF ACTION BEING APPROVED. |
| 2. DESCRIPTION OF THE SUPPLIES OR SERVICES REQUIRED TO MEET THE AGENCY’S NEEDS (INCLUDING ESTIMATED VALUE). |
| 3. IDENTIFICATION OF STATUTORY AUTHORITY PERMITTING OTHER THAN FULL AND OPEN COMPETITION. |
| 4. DEMONSTRATION THAT THE PROPOSED CONTRACTOR’S UNIQUE QUALIFICATIONS OR NATURE OF THE ACQUISITION REQUIRES THE USE OF THE AUTHORITY CITED. |
| 7. DESCRIPTION OF MARKET RESEARCH CONDUCTED AND THE RESULTS. |
| 8. OTHER FACTS SUPPORTING USE OF OTHER THAN FULL AND OPEN COMPETITION. |
| 9. LIST OF SOURCES, IF ANY, THAT EXPRESSED, IN WRITING, AN INTEREST IN THE ACQUISITION. |
| 10. STATEMENT OF ACTIONS, IF ANY, THE AGENCY MAY TAKE TO REMOVE OR OVERCOME ANY BARRIERS TO COMPETITION BEFORE ANY SUBSEQUENT ACQUISITION. |
| 11. CONTRACTING OFFICER CERTIFICATION. |
| 12. PREPARER’S TECHNICAL CERTIFICATION. |
File details come from the government source that posted it. Updated .