Project 2025's Labor Agenda: Weakening Worker Power on Federally Funded Transit and Road Projects
Project 2025's proposals target the mechanisms that ensure federal transportation dollars support good wages and safety. By calling to repeal the Davis-Bacon Act, end Project Labor Agreement (PLA) requirements under the FAR, and ban card-check union recognition (via NLRA amendments), this agenda would undercut worker standards on federally funded road, bridge, and transit construction projects, driving down wages and reducing the likelihood that major infrastructure projects are built by skilled, trained, and safe workforces. Some of these proposals are already in motion through executive orders on PLAs and rulemaking at DOL; others require legislation.
The connection between the Department of Labor and the Department of Transportation may not be obvious, but it is direct and powerful. When the federal government funds a new highway, a transit line, or a bridge, the rules governing who builds it and for what pay are set by the Davis-Bacon Act and often by Project Labor Agreements (PLAs) imposed via Federal Acquisition Regulation (FAR) clauses. These bedrock laws don't just protect workers; they ensure public money builds quality infrastructure efficiently by attracting a skilled, trained workforce. Project 2025 calls for repealing the Davis-Bacon Act and ending mandatory PLAs on federal projects, claiming they are a 'tax on American families' that 'drive up costs.' The stated goal is to allow 'markets to determine market wages' and to base procurement 'on the contractors that can deliver the best product at the lowest cost.'
In transportation terms, this is a recipe for race-to-the-bottom construction. The Congressional Budget Office confirms that repealing Davis-Bacon would reduce federal construction costs but also lower wages. In practice, this means transit agencies and state DOTs would be left with fewer tools to ensure that workers on federally funded projects are paid a local, living wage. Combined with the call to 'end all mandatory' PLAs—currently in motion through Executive Order 13202 (reinforced under Trump)—this would dismantle the framework that has helped build major projects like the Second Avenue Subway and countless highway expansions with a highly trained, unionized workforce. The result is not 'efficiency' but increased risk of wage theft, higher turnover, and lower-quality construction, all of which directly threatens the safety and durability of the infrastructure the Department of Transportation is charged with building.
The broader attack on union organizing methods—banning card-check recognition (via proposed amendments to the National Labor Relations Act) and eliminating the NLRB's contract bar rule—further weakens the ability of transportation and construction workers to organize and demand fair wages and safety standards. While these specific proposals remain proposed legislation and would require congressional action, they signal a clear intent to make it far harder for workers to form unions in the first place, including on large infrastructure projects. For anyone who believes that federal infrastructure dollars should build high-quality, long-lasting roads, bridges, and transit systems while supporting good American jobs, this entire section of Project 2025 is a blueprint for the opposite outcome.
The humanitarian alternative
Congress and the administration should reaffirm and strengthen Davis-Bacon prevailing wage protections and Project Labor Agreement requirements on all federally funded transportation projects. This should include expanding PLAs as a standard tool on large-scale transit and rail projects to ensure reliable scheduling, cost predictability, and access to a skilled workforce. Instead of weakening union organizing, the DOT should partner with DOL to expand registered apprenticeship programs and create direct pathways for disadvantaged workers into high-quality construction careers on infrastructure projects. Rejecting the card-check ban and defending the NLRB's contract bar rule are essential to maintaining worker voice and safety.
Rollback path — how this gets undone
This action has already been implemented. These are the concrete levers that could reverse it.
- Defeat the Davis-Bacon Repeal Act in Congress Congressional allies must block passage of the repeal act and mobilize committee opposition to prevent any legislative weakening of prevailing wage requirements.
- Rescind executive orders ending mandatory PLAs A future presidential administration can revoke or replace EOs that restrict PLAs on federal construction, restoring procurement guidance that prioritizes quality and worker standards.
- Rescind or delay finalized OLMS investigation rule A future DOL can rescind the proposed OLMS rule expanding investigation authority without a complaint, or Congress can pass a Congressional Review Act disapproval resolution if the rule is finalized before a certain date.
- Defeat legislation codifying the card-check ban and contract bar elimination Defeat any bills that would ban card-check recognition or eliminate the NLRB's contract bar rule through filibuster or committee action in the Senate.
- Legislatively codify Davis-Bacon and PLA requirements Congress can pass new legislation, such as a 'Infrastructure Worker Standards Act,' that would statutorily mandate prevailing wages and PLAs on all major federally assisted transit and highway projects.
Original source — excerpted
project2025 Project 2025 ch. 19: Department of Transportation (pp 635-637)"— 602 — Mandate for Leadership: The Conservative Promise Office of Labor-Management Standards Initiative. Currently, the Office of Labor-Management Standards (OLMS) may investigate potential employer mal - feasance with regard to union funds in the absence of any complaint by a worker or union but may not do the same with regard to potential union malfeasance. If OLMS has evidence that a union may be violating the law based on information available to the agency (such as annual financial disclosure reports, information developed during an audit of a union’s books and records, or information obtained from other government agencies) it should be permitted to open an investigation. It should have the same enforcement tools available for both employers and unions. l Revise investigation standards. The Office of Labor-Management Standards should revise its investigation standards to authorize investigations without receiving a formal complaint. Persuader Rule. During the Obama Administration, DOL created significant regulatory burdens for employers with respect to the advice that employers receive about union activity. As a general matter, employers who hire lawyers or oth…"