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memorandum that merely encouraged the use of PLAs on contracts over $5 million for <br /> construction projects,including renovation and repair work,for federally owned facilities.16 <br /> Subsequently, few projects were conducted under government-mandated PLAs because the <br /> regulatory process that established the rules in which the federal government could require and <br /> use PLAs delayed implementation of the Clinton memo. Also, few federal agencies opted to <br /> mandate PLAs on federal construction projects, as documented in a May 5, 1998, U.S. <br /> Government Accountability Office(GAO)report:Project Labor Agreements: The Extent of Their Use <br /> and Related Information. The GAO report found that it is nearly impossible to show any savings <br /> or increased quality derived from the use of government-mandated PLAs.17 <br /> On February 17, 2001, under Executive Order 13202, President George W. Bush canceled the <br /> Clinton order by effectively prohibiting government-mandated PLAs on federal and federally <br /> assisted construction projects. The executive order declared that neither the federal government <br /> nor any agency acting with federal assistance should require or prohibit construction contractors <br /> to sign union agreements as a condition of performing work on a government construction <br /> project.18 On April 6, 2001, the Bush Administration amended Executive Order No. 13202 <br /> with Executive Order No. 13208, which exempted any project that already had at least one <br /> contract awarded with a PLA from Executive Order 13202.19 <br /> Some of the largest unions in the country,including the AFL-CIO,insisted that the order illegally <br /> interfered with their collective bargaining rights under the NLRA. They filed suit in federal court <br /> (Building & Construction Trades v. Allbaugh), and on November 7, 2001, a United States District <br /> Court Judge issued an injunction blocking the President's order. The Justice Department <br /> 16 Ibid.,3. <br /> 17U.S.Government Accountability Office,Project Labor Agreements:The Extent of Their Use and Related <br /> Information,GGD-98-82,(May 29,1998),http://www.gao.gov/products/GGD-98-82. <br /> 18 Worcester Municipal Research Bureau,"Project Labor Agreements on Public Construction Projects:The <br /> Case for and Against,"Report No.01-4(May 21,2001):7,http://www.wrrb.org/reports/public- <br /> administration/2001/05/the-use-of-project-labor-agreements-on-public-construction-projects/. <br /> 19 Exec.Order No.13208,3 C.F.R.187(2001) <br /> The Anticompetitive Effects of Project Labor Agreements on Public Construction in Washington State 9 <br />