According to the NBCC, the implementation of CPAs discriminates against black workers, usually non-unionized, and also prevents contractors from using casual workers. [103] [104] According to the U.S. Pan-Asian American Chamber of Commerce, the majority of its members are small businesses unfairly affected by PDOs, in part because of rising costs and lower worker benefits. [105] The Boston Harbor Recovery Project, which began in the 1980s, has become the focus of the debate over the legality of CSFs. [9] [10] When the Massachusetts Water Resources Authority decided to use a PLA for the project that only requires union work[11] associated Builders and Contractors of Massachusetts/Rhode Island, Inc. questioned its legality and asserted that the use of a PLA was prohibited by the National Labor Relations Act.