Army Corps Cleared to Require Union Pact in South Dakota Award

Feb. 25, 2026, 6:17 PM UTC

HHI Corp. failed to show that the US Army Corps of Engineers unlawfully included a project labor agreement requirement in an Air Force construction project worth $55 million, the GAO said in a decision released Wednesday.

PLAs are pre-hire collective bargaining agreements with one or more labor organizations that establish terms and conditions for specific construction project. HHI said the requirement limits competition in violation of the Competition in Contracting Act.

But the Federal Acquisition Regulation requires agencies to include PLAs in large-scale construction projects, the GAO said, and market research didn’t indicate the requirement would substantially reduce the number ...

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