Project labor agreements in D.C.: The $50 million rule explained

Required by law on the District’s largest builds: project labor agreements in D.C.

Project labor agreements in D.C. are not optional on the District’s largest construction jobs. Under D.C. Code § 2-356.06, the mayor must require a project labor agreement on multi-trade construction contracts of $75 million or more, and a 2024 law lowered that bar to $50 million for projects first included in the capital improvement plan for fiscal 2026 through 2032 and later.

The District writes the requirement directly into its procurement law rather than leaving the choice to each agency. That makes the District one of the few jurisdictions in the region where its largest public jobs carry a PLA by default. Council members, agency staff and residents can see how that rule compares with state laws across the region at whatisapla.com.

Carpenters on the District’s public jobs are part of the Eastern Atlantic States Regional Council of Carpenters, which represents 42,000 union carpenters across six states and Washington. Its apprenticeship programs feed the District’s own push to put residents to work on public construction, one registered apprentice at a time.

When does D.C. law require a project labor agreement?

Three conditions trigger the requirement. The PLA must advance the District’s interest in labor-management stability and in compliance with laws on safety and health, equal employment opportunity and labor standards. The project must need multiple contractors or subcontractors employing workers in multiple crafts or trades. And the contract’s total construction cost, excluding planning and ongoing operations and maintenance, must be expected to reach $75 million, or $50 million for projects first included in the capital improvement plan proposed for fiscal 2026 through 2032 and any later period. The Council set the lower threshold in the Revised Project Labor Agreement Cost Threshold Amendment Act of 2024, which took effect Aug. 24, 2024.

What must a D.C. project labor agreement include?

The code sets seven required elements. Every covered PLA must:

• bind every contractor and subcontractor on the project
• guarantee against strikes, lockouts and similar job disruptions
• set prompt, binding procedures for resolving labor disputes
• provide ways for labor and management to cooperate on productivity, quality, safety and health
• include any added requirements the chief procurement officer considers necessary
• outline how project spending will support the District’s Certified Business Enterprises and Equity Impact Enterprises
• outline a diversity plan for recruiting minority group members, women and residents of disadvantaged communities into jobs and apprenticeships

The mayor may waive the requirement only by posting a determination and findings online for at least 10 calendar days before the solicitation is advertised. The findings must show the project does not meet the criteria or that a PLA would be contrary to the District’s interests. The posting window gives contractors, unions and residents time to review the reasoning before bids go out, which keeps each waiver decision in public view.

How did the D.C. project labor agreement law develop?

The requirement sits in the Procurement Practices Reform Act of 2010. The Council added the PLA section in 2016 through the Procurement Integrity, Transparency, and Accountability Amendment Act, but it could not take effect until its cost was included in an approved budget. The Fiscal Year 2019 Budget Support Act supplied that step, and the requirement took effect Oct. 30, 2018. The 2024 amendment then lowered the threshold and added the business enterprise and diversity plans. One carve-out remains: the section does not apply to a capital project that bundles multiple public improvements, though any single improvement that meets the criteria on its own is still covered.

Can non-union contractors work on D.C. PLA projects?

Yes. The statute binds every contractor and subcontractor engaged in construction on a covered project to the agreement, which means union and non-union firms work under the same terms. Any qualified contractor can bid. The Certified Business Enterprise plan each PLA must include is written to widen, not narrow, the field of local firms that share in District construction spending.

Which D.C. projects have been built under PLAs?

The District funded three projects to carry out the requirement in fiscal 2019, and the Office of the Chief Financial Officer has reported the Banneker High School project among them as completed. Public-private builds use PLAs as well: the Office of the Deputy Mayor for Planning and Economic Development publishes the project labor agreement for the D.C. United stadium. Federal construction inside the District follows Executive Order 14063, which requires PLAs on federal projects of $35 million or more unless an exception applies.

READ MORE: Community benefits of PLAs: 5 ways projects can widen opportunity

How do PLAs support D.C. residents and taxpayers?

District law pairs PLAs with local workforce rules. Contractors holding District construction contracts of $500,000 or more must register an apprenticeship program with the D.C. Apprenticeship Council, and First Source agreements require employers to turn to the Department of Employment Services before other referral sources when they hire. The research answers the taxpayer question too. The strongest peer-reviewed studies find no statistically significant cost effect, the short answer to do PLAs increase costs, and a peer-reviewed study of 313 public works projects in Sacramento County, California, found PLA projects finished 15% to 17% faster.

D.C. Council members, agency project managers and community groups can browse the latest PLA news and research and see the benefits these agreements bring to public construction.

READ MORE: Project labor agreements do not raise costs, research review finds

Frequently Asked Questions

Does D.C. require project labor agreements?

Yes. D.C. Code § 2-356.06 requires the mayor to include a PLA requirement in solicitations for large, multi-trade construction contracts that meet the statute’s criteria.

What is the PLA threshold in D.C.?

$75 million in total construction cost, or $50 million for projects first included in the capital improvement plan proposed for fiscal 2026 through 2032 and later.

When did D.C. lower the threshold to $50 million?

The Revised Project Labor Agreement Cost Threshold Amendment Act of 2024, D.C. Law 25-202, took effect Aug. 24, 2024.

Can the mayor waive the PLA requirement?

Yes, by posting a determination and findings online at least 10 calendar days before advertising the solicitation. The findings must show the project falls outside the criteria or that a PLA would be contrary to the District’s interests.

Must a D.C. PLA include a no-strike clause?

Yes. Guarantees against strikes, lockouts and similar job disruptions are required by statute.

Do D.C. PLAs include diversity commitments?

Yes. Each PLA must outline a plan for recruiting minority group members, women and residents of disadvantaged communities into jobs and apprenticeships.

Can non-union contractors work on D.C. PLA projects?

Yes. The agreement binds every contractor and subcontractor on the project, and any qualified firm can bid.

Do federal projects in D.C. require PLAs?

Federal construction follows Executive Order 14063, which requires PLAs on projects of $35 million or more unless an exception applies.

Do PLAs raise construction costs?

No. A research review by the Institute for Construction Employment Research found no statistically significant cost increase in the strongest studies.