Trump Backs Biden-Era EO Mandating PLAs for Large Federal Construction Projects

In a surprising continuation of his predecessor’s labor policy, President Donald Trump’s administration announced on June 12, 2025

that it will maintain the federal requirement for project labor agreements (or PLAs) on large-scale federal construction projects in accordance with President Joe Biden’s Executive Order 14063 (EO 14063).

The move, outlined in Office of Management and Budget Memorandum M-25-29, confirms and clarifies prior guidance implementing EO 14063. It preserves the requirement that federal agencies use PLAs for federal construction contracts valued at $35 million or more, marking a rare moment of policy alignment across two very different administrations.

What Are PLAs?

PLAs are a special type of “pre-hire” collective bargaining agreement governing labor relations and working conditions for all workers, union or non-union, on a single construction project. PLAs standardize wages, benefits, dispute resolution procedures, safety protocols and other work conditions for the duration of a federal project. PLAs minimize labor disruptions, ensure a consistent and qualified workforce, as well as boost project efficiency.

Though often controversial in the political arena, PLAs are widely used in both public and private construction and are endorsed by many project owners, particularly on complex or large-scale projects.  Large construction projects involve numerous contractors and subcontractors, each with their own workforce performing discrete parts. PLAs provide an overall structure on a project, which applies to all contractors working in every aspect of the project throughout its entire duration, as well as facilitate coordination of these multiple parties.

President Biden’s Executive Order 14063
  • Originally signed in February 2022, EO 14063 required all federal executive agencies to use PLAs on federally funded construction projects of $35 million or more, with three narrow exceptions: 
  • A PLA would not advance the government’s interest in achieving efficiency in federal procurement. 
  • The contracting agency determines that “based on an inclusive market analysis, requiring a project labor agreement on the project would substantially reduce the number of potential bidders so as to frustrate full and open competition.” 
  • “Requiring a [PLA] on the project would otherwise be inconsistent with statutes, regulations, etc.”
Trump’s Unexpected Endorsement

Despite President Trump’s historical criticism of organized labor and union-friendly policies, the administration’s June 12, 2025 memorandum not only leaves EO 14063 intact but actively encourages its continued enforcement.  The OMB memo M-25-29 reaffirms the benefits of PLAs for large-scale federal projects and precludes federal agencies from blanket deviations from the PLA requirement. It also provides that “agencies should use PLAs when practicable and cost-effective” and instructs agencies to “rescind any deviations related to PLAs that were issued prior to the date of this guidance.”

The 2025 memo rescinded portions of OMB’s 2024 guidance and clarified the process for analyzing whether utilizing a PLA would “substantially reduce the number of potential bidders so as to frustrate full and open competition.” It also makes clear that “other exceptions recognized in [EO 14063], implementing regulations, and OMB guidance remain in effect.”  

Why Trump Is Keeping PLAs

While Trump has previously criticized union influence in education, manufacturing and government policy, his administration appears to view PLAs through a pragmatic, pro-construction lens. The Trump administration appears to recognize that PLAs have benefits, including: 

  • PLAs ensure a steady supply of skilled labor during a tight construction labor market.
  • PLAs harmonize work rules across multiple trades.
  • PLAs eliminate delays through no-strike provisions.
  • PLAs support the expansion of apprenticeships and training programs to meet future construction needs.
  • PLAs improve worker safety. 
  • PLAs reduce worker misclassification.

President Trump’s support for PLAs also reflects a strategic effort to court blue-collar union voters, particularly in battleground states. 


Grant Collins is a specialist in labor and employment law at Felhaber Larson. Reach him at gcollins@felhaber.com

Published: August 28, 2025

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