CS 321 East 2nd Investors, LLC (B-423215)
You should not care.
Category: Process issue
Date: 10 March 2025
URL: https://www.gao.gov/products/b-423215
CS 321 East 2nd Investors, LLC, protested the terms of a GSA request for lease proposals (RLP) for office space in Los Angeles, alleging that certain provisions were unduly restrictive of competition. The protester challenged the required square footage, the mandate for a single building, and the area of consideration:
Square footage requirement: The protester argued that GSA’s requirement for 57,558 ABOA square feet was excessive given increased telework and technological advances. GAO found GSA’s justification reasonable, citing the Federal Public Defender’s need for confidentiality, physical case files, and dedicated workspace for all employees at least one day per week.
Single-building requirement: The protester claimed GSA’s mandate for contiguous space in one building was unnecessary. GAO upheld GSA’s rationale that consolidating space would improve efficiency, reduce operational costs, and streamline management.
Area of consideration: The protester challenged the RLP’s expanded search area, arguing it allowed space too far from the federal courthouse. GAO dismissed this challenge, finding the protester lacked standing since its own building was within the search area and its argument aimed to limit competition.
GAO denied the protest on square footage and single-building requirements and dismissed the challenge to the area of consideration for lack of standing.
Digest
- Protest challenging terms of a lease solicitation as unduly restrictive of competition is denied where the record shows that the provisions are reasonably necessary to meet the agency’s legitimate needs.
- Protest challenging a lease solicitation’s area of consideration is dismissed where the protester fails to establish that it is an interested party to challenge the area of consideration where its building is within the area and the protester effectively argues for more restrictive specifications.
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