No. Construction activity and a qualifying infrastructure project are different things, and the reduced US$800,000 level depends on the qualifying basis actually established for the investment. Ask counsel to review the project against current criteria rather than accepting the description used in its own promotional materials. Sort the claim by its owner. A new commercial enterprise or its promoter asserts the basis; the investor carries the consequence if that assertion does not hold, and must still meet the requirements no project can satisfy on their behalf, including capital at risk, the required job creation, and engagement at least at the policy level.
Reviewing the claimed basis rather than the description
A review looks for the basis asserted, the evidence supporting it, and whether the same basis is carried consistently through the offering documents and the intended petition. If the reduced amount cannot be supported, the qualifying investment is US$1,050,000. The other core requirements are unaffected by the label: capital genuinely at risk, and at least ten qualifying full-time jobs per investor, none of them your spouse or children.
Request the underlying analysis and the records it rests on, then have counsel you retained read them. An investor engaged at the policy level is still engaged; distance from daily operations does not excuse ignorance of what the petition asserts, since the petition is filed in the investor's name and the investor signs it.