I have advocated the use of 'lots' for many years but that has always been as a tool in achieving the strategic objectives of the organisation, for example, ease of access to SMEs. If 'lots' are not strategically aligned with the organisation's objectives then, to me, they should not be used.
'Lots' are just one of an array of strategic sourcing options which should be considered - they should not, however, be the default option. Nevertheless, the EU now expects public sector procurers to document why 'lots' are not used and therefore implies, they are the option of preference. The implication is that at some stage that documentation will be need to be produced as some sort of discoverable evidence in defence of a professional judgement by the CPO.
Now I am not against a CPO documenting an options appraisal which justified why 'lots' were not used, on the contrary I would like to see more procurement decisions led out in logical argument. However, I feel those documented justifications should be for internal scrutiny and not something which the EU should demand.
I also have concerns of what this could lead to. For example,
