Department Clarifies That Roads Which Do Not Physically Exist Still Count Under ‘Quantum Construction Standards’
MANILA, Philippines – The Department of Public Works and Highways announced Tuesday a sweeping reclassification of previously flagged ‘ghost projects’ under a new framework the department is calling ‘Imagination-Based Infrastructure,’ a designation that officials say will allow completed budget disbursements to be counted as project completions without the traditional requirement that something physical be built at the location where the money was allocated.
Department spokesperson Rodrigo Concreto told reporters that the new classification addresses ‘a persistent definitional gap’ in how Philippine infrastructure is assessed, noting that existing audit standards were ‘designed for a different era of project delivery.’ Under the revised framework, a road that exists in the project budget, the project documentation, and the project completion report – but not, technically, on the ground – will be classified as ‘existing in principle,’ a status that qualifies for full disbursement and final sign-off without the historically required physical inspection.
The Commission on Audit Responds
The Commission on Audit, which has spent the better part of the past decade documenting the gap between infrastructure budgets and infrastructure outcomes, responded to the DPWH announcement with a statement that it would ‘study the reclassification framework carefully.’ This is the most aggressive language the Commission typically deploys short of an adverse audit finding, and represents what observers describe as ‘institutional concern expressed within the vocabulary available to an institution that depends on the agencies it audits for cooperation.’ The Commission’s most recent audit of DPWH identified billions of pesos in project disbursements for which physical completion could not be confirmed, a finding the Department at the time described as ‘a documentation matter.’
‘The Secretary assured reporters that invisible infrastructure still counts as infrastructure under revised accounting standards,’ said a source familiar with the briefing, declining to be named because he is still employed. ‘He used the analogy of dark matter. Dark matter makes up most of the universe and yet cannot be directly observed. He said DPWH projects operate similarly. Someone in the back row asked if dark matter is subject to procurement law and the press conference ended shortly afterward.’
The Scale of the Problem
According to the Manila Bulletin, the Philippine government has over the past decade allocated tens of billions of pesos to infrastructure projects across flood control, road networks, bridges, and public buildings, with completion rates that the Commission on Audit has described as ‘significantly below target,’ which in audit language means ‘the money went somewhere and the projects did not.’ Flood control infrastructure in Metro Manila has been a particular area of concern, given that Manila floods regularly with the consistency of a scheduled event despite years of flood control budget disbursements that, by the project documentation, should have addressed this by now.
The Institute for Creative Accounting – which we acknowledge does not exist but which clearly should – estimated in a report that was never commissioned and therefore never suppressed that ‘imagination-based infrastructure’ could, if counted toward the national asset registry, increase the Philippines’ stated infrastructure stock by 34 percent without requiring additional spending, which is the most efficient form of infrastructure investment ever documented and also, regrettably, entirely fictional. The Department of Finance has not commented on whether Imagination-Based Infrastructure assets would be eligible for securitization, which is perhaps for the best.
What Legitimate Infrastructure Looks Like
It should be noted, in the interest of fairness, that the Philippines has built real and significant infrastructure over the past decade, including expressways, airports, and public transport systems that represent genuine investment in national connectivity and economic capacity. The Manila Times has documented the Marcos administration’s infrastructure programme with both the project list and an honest accounting of the gap between announcements and completions, a gap that is not unique to the current administration and that reflects structural problems in project management, procurement, and contractor performance that predate and will outlast any specific government.
The broader challenge, which the Imagination-Based Infrastructure reclassification does nothing to address and several things to worsen, is that the Philippines needs physical roads, bridges, and flood control systems, not creative taxonomies of their absence. Metro Manila floods every typhoon season. That is not an imagination problem. That is a drainage problem, a flood control problem, and a budget execution problem, all of which require concrete, pipes, pumps, and physical installation by workers at specific locations on specific dates. Whether the DPWH’s new framework accommodates this reality is something the next monsoon season will answer more definitively than any press conference.
The structural precedent set by Imagination-Based Infrastructure is difficult to overstate. If a disbursed but unbuilt road counts as a completed road, then the Philippine government’s infrastructure programme is, on paper, among the most successful in Southeast Asia. The Commission on Audit’s adverse findings, which have historically been the mechanism by which ghost projects are identified and officials held accountable, become under this framework not adverse findings but ‘definitional disputes,’ a reclassification that is as elegant as it is alarming. The Department of Justice has not yet commented on whether Imagination-Based Infrastructure can be the subject of a plunder charge, which under Philippine law requires proof that public funds were taken through misappropriation. Whether ‘infrastructure that exists in principle’ meets the definition of ‘infrastructure’ for purposes of the criminal code is, apparently, now an open question, and one that the Commission on Audit’s lawyers are presumably exploring with great interest and some urgency.
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