The EB-5 Paradox

EB-5 Visas have been an important post-recession tool in Miami for raising money, but have also fueled unaffordable housing in the City.

The EB-5 Visa is a US immigration program where foreign persons can gain visas or green cards through investing in US ventures. In order to qualify, a candidate must invest between $500,000 and $1 Millon (depending on the area) into a venture that creates at least 10 jobs. If you want more information, see the stock footage filled video below created by a financial institution called GreenAccess that specializes in the program:

The program has raised $14 billion of investment in the US since 2008 when developers and start-ups began targeting this program at the start of the Great Recession. Since traditional sources of capital dried up, new ways were needed to fill the gap between traditional loans and raised capital. Since the great recession, the program has only increased in volume, especially in Florida. In 2011, the program brought $10.5 million in capital funding. In 2013, that number increased to $150.5 million and growing. This represents a large part of the capital funding of real estate projects in South Florida, but furthermore, is determining the types of projects developers are building.


The definition of “investment” is not well defined for this program, and there is no restriction as to financial return or payment from developers, causing a lot of fraud and misleading in the program. The programs operate through regional centers, like GreenAcres who made the video above, usually private, that are approved by the US Department of Citizenship and Immigration Services. These offices farm for EB-5 candidates all over the world, and connect them with projects in the states. They handle the financial planning and holding and take fees for those services.

Render of Paramount World Center

In Miami, most of these investments land in luxury real estate projects. These are projects that are planned with EB-5 Visa investment and buyers in mind. In other words, developers create a building product that is a good candidate for easy investment that translates into a sale of a condo. For example, the Paramount World Center will give a 0.5% return on investor capital, which is essentially nothing, and at the end of construction, your investment secures you the option of buying a condo. Other projects such as the Hollywood Circle development raised 1/2 of their total project cost, or $100 million, through the EB-5 visa program. Other popular programs for this include restaurants and hotels.

The problematic investments occur in the luxury real estate space, where developers reserve massive blocks of their buildings for EB-5 visa applicants while ignoring qualified buyers in the states. This program allows developers to get essentially free money for financing, along with a qualified buyer, by signing a single piece of paper early in the process. This program is essentially incentivizing the building of luxury residential units over market rate ones, pushing up the market in cities that do not need it.

Congress is currently reviewing the program closely, as they have been kicking it down the road for the last year. They have passed multiple stop gap extensions, the next of which expires on September 30th, 2017. Many opponents, usually from states that do not benefit from the program, want to end it entirely or significantly increase the minimum investment amount. While supporters want to see it continue, many believe that it has opened itself up to fraud and needs reform, but would like a compromise increase that does not kill the program entirely.

Currently, the program has a 2 tiered investment minimum, having a lower minimum for investment in areas of needed economic development. This rule is not well enforced and could go a long way in helping to stifle the luxury investment pipeline. If it was enforced,  $1 million would be the minimum in areas of high employment, while the standard $500,000 would remain the minimum in areas of low employment. Congress must get creative in enacting policy that both raises the threshold, while not eliminating the good parts of the program, that truly create jobs and foster new business. There must be a middle ground where meaningful investment can occur while not over inflating real estate markets with foreign dollars in major cities, leaving locals with few options for good housing.

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Are Buses SMART?

While trains may have been promised, suburban areas of the SMART Plan are looking to Rapid Bus Systems for savings and long term thinking.


On Monday, Major Carlos Gimenez did what most politicians would not dare: He told the public they cannot have what was promised to them. Mayor Gimenez ran his reelection on the SMART rapid transit plan; An ambitious plan to create 6 new public transit corridors reaching every corner of Miami. Voters were promised some of these lines in 2002 when they voted in a half percent tax that yields $250 million a year. However, the rail they were promised in South Dade, and other suburban destinations, was postponed in favor of a different system.

The first piece of the SMART plan that was to be built is the South Dade extension, from Dadeland Station South to Florida City. This leg in the originally proposed Light Rail was estimated to cost $1.8 billion. Estimates for the same route using Bus Rapid Transit (BRT) are about 1/3 the price. For many of us, buses sound like inefficient, slow, unreliable services, and around most of Miami, that is true. However, if Miami follows a true BRT system, we can get a lot more out of our tax dollars, and relieve traffic on a city-wide level, at the same time.

Mass Transit studies show that it takes 20,000 people/sq mi to be profitable. The areas shown in yellow, orange, and red meet that criteria.

Perhaps Gimenez never should have promised something he did not understand the cost of, but we are going to put the political maneuvers aside for now. Today, he is being a responsible Mayor and allocating resources based on data, and working programs seen in other cities. The truth is that the densities in South Dade, Kendall, and the North Corridor do not meet the standards for mass transit use. Most areas adjacent to US1 in South Dade are less than 10,000 persons per sqmi. For rapid transit to be productive, you need at least 20,000 persons per sqmi. Spending billions of dollars on those 3 corridors may not make sense now, or in the near future, but spending a fraction of the cost on a BRT system does.


A true Bus Rapid Transit (BRT) must follow a number of criteria including raised platform boarding to eliminate slow downs, prepaid tickets at the station, and dedicated lanes with the ability to alter traffic signals to gain priority. It also can be built much more quickly, and demand for route changes can be more easily accommodated.

Gimenez also makes the point that choosing to use light rail or other rail technology may stifle us in the future from adopting more efficient future technologies, such as self-driving buses or destination direct transit. While may be a political line, it is a valid point that massive infrastructural payments do hold cities to particular contractors, products, and maintenance regiments that become costly. A BRT system is by design, piecemeal, and can be retrofitted more easily.

There are examples all over the US of successful BRT programs in car-based cities like Miami, such as Cleveland, Los Angeles, and Denver. These can act as models for Miami’s system and future growth. I am not saying that the SMART plan is a bad plan, in fact the opposite. It correctly identifies corridors that are both possible and popular for these initiatives, and it takes into account density, future development, and existing public transit use. However, the mediums for these lines must be tailored to each’s environment, density, and use estimates. This is what good governing looks like. It’s not sexy or inspirational, but it is making the city an inch better at a time and doing it pragmatically and efficiently.

A Bus Rapid Transit system is cheaper, more flexible, and can be implemented faster than a traditional light rail system. It also makes sense for suburban corridors that do not yet meet the density of where trains are useful. With these criteria in mind, ask yourself if you think that light rail is worth 3x as much money? Ask yourself if this were your business would you make the same decision? Finally, ask yourself if having light rail in lower-density zones is worth delaying or losing future projects that will benefit from the saved funding? For me, the answer is no. Let me know what you think in the comments!


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Miami, a Retail Paradise?

While retail jobs are falling across the Country, Miami has continued to add retail sqft across the city; But will that be enough for the new American Dream Mall?


There have been a plethora of articles describing what is being called the incoming “Retail Apocalypse” (The Atlantic, April 2017). 8 million people work in front-end retail services in the United States, making up about 6% of the total workforce. Since last October, 100,000 jobs have been lost in department store closings alone, with more predicted this coming year. These drops are attributed to an increase in e-commerce and restaurant/entertainment spending. For perspective, that is more people than worked in coal mining at its height of production. Despite these statistics, Miami developers continue to build and promise millions of square feet of retail development across the city.

While most retail statistics look bleak, South Florida remains a seemingly healthy market. While the national retail vacancy rate sits around 10%, Miami’s is 5.7%, with an average rent of $23.7 psf, the highest of any growing retail market in the country. Fortune Realty Group estimates the vacancy rate to drop over the next year to 4.7%, and the NOI to increase 10% as retail rents will rise due to increased demand. Miami-Dade County has 145,600 retail workers. While these numbers are good, it is important to zoom in and understand why Miami appears to be an anomaly among major cities.

Since the recession, the major growth in Miami retail has been primarily in the luxury space. Both the Design District and Brickell City Centre together have added close to a million square feet of luxury retail in the past 3 years. Before 2000, Bal Harbour was the only place for luxury brands in Miami due to a protectionist lease stipulation. After 2002, and the opening of Merrick Park, there are 6 major locations for luxury brands around the city: Aventura, Merrick Park, the Design District, Dadeland Mall, and Brickell City Centre.

While both Aventura and Dadeland existed before this date, both expanded their luxury retail makeup in the past decade. While brands like Macy’s and JC Penny are seeing shoppers move online, luxury buyers still appear to go into the store to make purchases, and Miami is a robust market for luxury shopping. This is due to both tourism and international residents, who typically patronize these locations. For example, in 2012, visitors staying at Brickell hotels alone spent $800 million on shopping in South Florida, mostly in the luxury space. There appears to be room for everyone in the “top shelf” of Miami retail, with no signs of slowing down.

The 5-ton elephant in the Miami retail space, however, is the pending American Dream Mall in the North West corner of Miami-Dade County. In an age of declining retail and rapid urbanization, this project is a suburban, isolated mall, with 1 million square feet of commercial retail. It occupies a figurative peninsula made by the intersection of two highways, I-75 and FL-Turnpike, and promises to include an indoor amusement park, ski slope, water park, and ice skating rink. This fun house is reminiscent of American Mid-Century optimism but does not reflect obvious trends in the market, and overestimates the appetite for its existence. The creators argue that they are focusing on “experiential retail” spaces, however, those types of stores look for flagship locations, usually not in suburban locations, as they are more marketing focused, rather than profit machines. Nevertheless, the mall claims it will create 14,000 service jobs and will be a destination for Miami.

There is space for growth in thoughtful, targeted retail in Miami, but the American Dream mall appears to be reaching for a place long abandoned by conventional wisdom. Perhaps it is a destination that can attract more annual visitors than the Magic Kingdom, as reports claim, but it is the wrong project at the wrong time for a city that is aiming to diversify and upscale its workforce. Miami remains a Retail Paradise for niche luxury retail, but is not immune to larger moves in the marketplace, and should take note of them.


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The Beckham Deal is Good for Miami

How Miami pushed a run of the mill bad stadium deal, into a new kind of agreement.

On Tuesday, June 6th, 2017, Miami Commissioners cleared the largest hurdle of a 4-year battle to bring an MLS team and stadium to Miami. The vote was specifically to allow a 3-Acre Parcel of County land to be sold for the stadium grounds, completing a 9-Acre assemblage along the Miami River. This process began with a proposal for a curvaceous stadium located on Biscayne Bay and given for free. It is ending with a better solution for a nuanced, simpler stadium design located in Overtown, and fully paid for by its privately funded ownership (The Miami Beckham United Team).

Initial Stadium Proposal on Watson Island, along the McCarthur Causeway, by Architectonica

When David Beckham first proposed a new MLS team in Miami, it is important to understand the context. In 2009, only 4 years before Beckham’s proposal, the county approved $400 million in bonds to build a new stadium for the Marlins in Little Havana. The total cost of the stadium was close to $500 million and sits mostly empty on game days. For fronting the bill for the stadium, the City was entitled to no revenue from the stadium or property. Not property taxes, naming rights fees, non-game stadium rentals, tickets, boxes, or concessions.

The Marlins deal is particularly angering, especially this past month, as a deal to sell the team at a massive profit was publicized. This deal would give zero dollars to the taxpayers that made the team so valuable through their risk taking, while all of the profit would go to Marlins Owner Jeffrey Loria.  An owner who, despite asking for hundreds of millions of dollars from the county, refused to open his books to show the later reported profitability of the team. There is also reporting that shows how Loria paid himself and Marlins President, Samson, millions as “contractors” to the team, through a Wikileaks dump of internal Marlins accounting books. There is much more to cover with what was wrong with the Marlins deal that later led to the recall of Mayor Alvarez, but this article is about the new deal for an MLS stadium. While The Miami Beckham United Team may have started with a proposal similar to that of the Marlins, it was quickly made clear by Mayor Gimenez and others that it would not pass and they had to find another solution.

After looking at a number of sites, the MLS stadium will be built in Overtown.

A major part of the Beckham deal that cannot be overlooked is the role of Major League Soccer (MLS). A usual “expansion fee” for a new MLS team runs at about $150 million. When Beckham signed with the LA Galaxy, he was given a sweetheart deal of $25 million for a few minor concessions. They required him not to change the city once announced, and a Downtown location. This did not allow Beckham to shop around in different cities, or vie for a suburban location. He had to find a spot in Miami, and he wanted it to be waterfront. This gave the city the power in the negotiations, where they did not give any concessions in taxes or bonds, and sold the land to the future owners at market price. It was a new precedent for a city that had given money to every other sports team on multiple occasions.

Render of final Stadium Proposal in Overtown by Populus Architects

The site in Overtown is a bit of a strange choice, given the parking proposal. The stadium plans to offer no on-site parking, expecting all to take Metrorail, bus, ride-share, or water taxi to games. Miami has had a storied past with the car (See previous article Vroom City), however in a situation that is not recurring, this could work. It is not the perfect site by any means, but it does have all of the pieces needed. It is two blocks from the rail line, and if they properly create off-site lots with free shuttles, as well as water taxi service, it may become a simple part of arrival to the games. The overall design is slender, non-invasive, and porous. It interacts with its community and creates visual connections between fans and people. This is a welcome breath of fresh air from the originally flashy, enclosed proposal.

This privately funded deal will be good for the investors who went into it, good for the city that will reap taxes from it, and good for the people of Miami who will have new city institution to be proud of. Between 2000-2010 the US has spent $12bn in taxpayer money in sports stadiums. If other sports organizations do not stop demonizing the cities that they depend on, then their sports will begin to be demonized by those that pay for them. The NFL, NBA, and MLB are large profitable organizations that will ruin their fan bases if they continue to blackmail and coerce City Governments into paying for their excessive needs. Perhaps by waiving large “expansion fees,” like the MLS, and other owner roadblocks, they can afford to build practical stadiums that do not burden taxpayers but still provide a cultural institution that everyone can be proud of.


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Traffic, Safety Concern Residents Near Possible Beckham Stadium

John Oliver on on City Stadiums:



The original version of this article claimed the MLS gave a discount deal on the expansion fee for the city, not as a part of the LA Galaxy contract.

Miami Style: The Intra-Block

New Projects claiming to be Urban Wonders are just glorified Malls.

Note: Miami Style Posts seek to define Architectural or Urban Trends used in Miami.

The Intra-Block project is usually a multi or single block urban project that seeks to create a new “promenade” within its boundaries, effectively ignoring the streets surrounding it. There are a series of suburban-sited and newer urban-sited projects that act in this manner. Developers enjoy the intra-block, as it gives them ultimate control as to trespassing, event hosting, and does not rely on municipalities to upkeep sidewalks and streets. However, these large-scale projects are missing an opportunity to redefine their communities and be part of engaging and ultimately activating the neighborhoods around them.

New projects such as the Mana Wynwood Plan fit this description. It creates a seemingly generous intra-block promenade while ignoring NW 22ND Lane and 22ND Street. This large pedestrian alley creates for an interesting site plan but does not allow for the street to flood into it. “Wynwood Park” is a particularly frustrating project, labeling itself a civic amenity, while simply being a block mall with a small protected green within. The Brickell City Center project is a playground within its borders but is almost opaque to the street. Its aluminum banding and lack of thoughtful street retail reinforce this point, creating a secluded promenade within. All of these projects call themselves “multi-use urban projects,” while they appear to all be borrowing ideas from the simple suburban open-air mall.

Miami has had open air malls for decades. Locations such as Sunset Place, Mary Brickell Village, Coco-Walk, and Bayside Marketplace act as “intra-block” promenades, like the new projects mentioned above. Sunset Place, Coco-Walk, and Bayside are all in the process of a renovation to make them more pedestrian friendly and mixed-use, to create more profitable and inviting centers. Mary Brickell ignores the street surrounding it and acts as a destination without activating much around it until much later.

Not all new urban projects are acting in this way. The Miami World Center and Downtown Doral are embracing the street and using it as a major player in their urban plans. Both of these projects are larger in scale, and both use the street as a tool to move people through and into their projects. Perhaps this is simply a consequence of their scale and municipal connections, but I think they are a model of projects developed carefully and with municipal collaboration.


Design District
Design District Urban Plan


It is understandable why so many new projects choose to use the Intra-Block as a tool. It allows for control of people entering the property, it allows them to host events within their boundaries, and it is a tool of place making. However, there is a hybrid between these called the “Porous Block” where all sides can leak can into a central promenade. This is employed in the design district. While the project is missing targets in visitors and profits for retailers, the urban plan is intelligent, and acknowledges the streets and creates a new one at the same time. Hopefully, they can find stores that people want to visit and rents that will allow them to be profitable, but as of now, it seems to be a playground of facades and empty stores. The Intra-Block will continue to be a part of the urban design of Miami, but it is not too late for some projects to activate the streets around them at the same time. They find it both activating and profitable.

The Intra-Block will most likely continue to be a part of the urban design of Miami, but it is not too late for some projects to activate the streets around them. They may find it engaging and profitable.


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Why Miami Grid?

A description of my obsession with the Miami Grid, and why I named this Blog after it.

In 1978 a little known architect, named Rem Koolhaas, doing his PhD in New York City, wrote and published Delirious New York, a manifesto of sorts talking about the creation of the urban fabric of Manhattan. In it, he claims that the city’s regular, elongated grid of avenues and streets allows for an architecture that is irregular. These irregularities create “hot spots” in the city when they occur, making important spaces in seemingly unimportant places. Furthermore, the advanced laying out of the Manhattan grid, up to 155th St., decades before there was any development north of Houston St., was a bold move. It created a system of development that would later engulf the island, and allowed for organized capitalistic chaos. The founders of Miami acted much the same way, when creating the grid system that we still use today.

Illustration of Miami’s Grid

For those who don’t know, Miami is made up of four cardinal quadrants, separated by Miami Ave running N-S, and Flagler St. running E-W. It is a graphic method of way-finding, where one can locate an address without having to know block numbers or street names by heart. It also created a bold system of development, long before there were more than 10 buildings in the city.

A macro 1 mi by 1 mi grid was set up of streets and avenues occurring every 16 streets and every 10 avenues as a blanket across the city. These major roads generally pass through obstacles such as highways, trains, parks, and waterways, allowing even access across the city, while allowing for “chaos” to occur within each of the larger grid squares. This is the “super-block” version of Koolhaas’ vision of the unbiased grid. In New York it acts on the block scale, and in Miami it acts on the neighborhood scale. This allowed for early developers and newly incorporated cities to assemble larger pieces of land and plat them at will. This created variation in the grid, while allowing for generally even access across it.

This relationship between macro and micro urbanism is the story of the development of Miami. Early developers and city planners were able to work with seemingly blank gridded squares. Today’s developers and land assemblers must work within the decisions of platted lots made when those first pioneers created them decades before. There are a number of elements that break the grid, and these sometimes create “hot spots” or “isolated spots,” depending. The first were geographic, being the Miami River, where the first settlements of Miami began. The second were transportation related. involving the railroad, highways, and federal roads like US1 (see previous article on these here).

The development of these “super-blocks” have created a diversity of neighborhoods within the larger grid. Little Havana for example has small platted lots, creating a dense fabric of small multi-family and retail locations. However, just across the river, Allapattah has larger platted lots, used for industrial and warehouse shopping types. Coconut Grove has small lots, creating a vibrant community for townhomes, small multi-family, and a slow pace of development with a few larger parcels. Wynwood has large platted lots, allowing for larger projects to take over. These larger plots in Wynwood have inspired a series of “internal block” projects that look into the blocks to create large social spaces of courtyard like Wynwood 25, or promenade like Mana Wynwood.

From way-finding, to access, to neighborhood platting, the Miami Grid affects our everyday lives here. It has created its culture of development, city planning, and its irregularities have created both places of access and isolation. The grid while regular, has allowed for a diversity in neighborhood types that is good for Miami and its future.

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The Virtue of AirBnB

Miami’s crusade against AirBnB does not understand the problem, and therefore, will not find a solution.


On March 20th, 2017, Mayors Regalado and Levine of Miami and Miami Beach respectively held a press conference citing their issues with AirBnB, and why they oppose its use in parts of their cities. From statements previously made, 3 main concerns tend to recur: The first is that the Miami and Miami Beach zoning codes both prohibit short term rentals (weekly or daily) in single family and small scale multi-family neighborhoods. The second concern is the effect that these short term renters have on neighborhoods, as transients change the quality of pocket communities. The final concern is for the hotel industry, which is made up of mostly small business owners who find it unfair that AirBnB seems to play by different rules than they are permitted to. While these are legitimate concerns, this posturing by the city is exaggerated, and for the wrong reasons. Instead of holding firm to past rules without compromise, there are ways that the city and people who simply want to rent their homes in it, can come to an equitable agreement.

Currently, in order for AirBnB to be legal in Miami, the location of the home must be in an area zoned for commercial short-term rentals. This land is almost never used for single-family housing and sometimes used for Condo or Apartment buildings. Most Condo or Apartment buildings have strong rules against short-term rentals as well, giving an owner very few options for legal or allowable rentals of their property in Miami. Zoning in many major cities, including Miami, has been updated in recent years to reflect simpler and more open rules that incentivize development, and allow neighborhoods to grow organically. While some steps have been taken to loosen the rules, a lot still needs to be rewritten to reflect an ever-changing landscape of property used in the new century.

Report by Think Tank, R Street ranking cities by friendliness to short term rentals.

City regulations differ widely city by city. Some mention short term rentals, while others ignore it. On an independent study by a think tank that leans towards libertarian views ranks cities by their ease of having an AirBnB. Miami ranks in the bottom quartile on this list.

The AirBnB issue is simply a small part of a larger conversation about the future of use-specific zoning. In the city of Miami, Live-Work zoning is not allowed in any single-family designations and Hotels are not allowed in many places that Multi-Family buildings are. Before the Miami21 Plan, a lot of areas were designated to specifically to allow for popularizing mixed-use development. These required variances to occur, however, with a sweeping change, the current zoning code is much less restrictive but can still go further. In a society where work and life are blending, storage and retail are brought together online, and home and hotel are becoming one in the same, restrictive zoning uses are not moving as fast as society itself.

Furthermore, AirBnB helps cities to solve some of their most pressing issues. In ever-densifying blocks with skyrocketing prices, the model of AirBnB only helps. If homes and rooms would sit empty if not for a short term rental, that efficient use of space prevents more space from needing to be built elsewhere. And if a person loses a job, or encounters a life change and they need supplemental income to keep or afford their home, AirBnB would save them of that as well. While there are legitimate concerns about neighborhood noise, background checks, and escalating situations, these can all be solved using other laws to allow people to use their own property to make our city more livable. Especially in a city catalyzed by tourism, Miami property owners simply want to partake in this thriving local sector available to them.


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