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Comment letter sent from ACEC President & CEO Linda Bauer Darr on October 18, 2022, to the FAR, recommending that A/E firms and their employees be exempt from Project Labor Agreements (PLAs). Employees of engineering firms perform critical roles on construction sites. These include field representatives and surveyors monitoring that the work is being performed in compliance with design documents. To perform such work, these personnel must remain independent and objective.