USCIS throws EB-5 Program another curveball

I always enjoy talking with Jeffrey B. Carr. He is one of the most creative thinkers about EB-5 issues, particularly when it comes to economics and job creation.
Jeff is president and economist at Economic Policy Resources of Williston, Vermont (eb5economics.com).  I spoke with him Monday, March 5, when I addressed a special EB-5 seminar for Immigration Lawyers on the Web (ILW) in Orlando, Florida.
Jeff and I discussed a new "jobs displacement" issue that has popped up in who knows how many requests for additional evidence.  USCIS recently papered the country with requests that applicants show their investment project will not "displace" existing U.S. workers.
He said there is disagreement now between how USCIS defines a "direct job" and how EB-5 economists, generally, define a "direct job".  He said EB-5 economists can produce a rationale for counting tenant jobs as direct jobs.
The "tenant jobs" issue came up within the past couple of weeks after USCIS issued a memo declaring that "tenant jobs" are not "direct jobs".  Then we started seeing the RFEs referring to "jobs displacement".  I think this is going to get much worse for all of the stakeholders in the EB-5 Program, including -- most importantly -- foreign investors.
As a practical (real world) matter, the "jobs displacement" issue is never a consideration because the economy -- locally, regionally, nationally -- is constantly changing and evolving.  Some sectors of the economy and companies or industries do well; others don't.  Competition is a big part of this.  Businesses that compete effectively and adapt succeed; others fail.  A new hotel is built in a locale; an older hotel loses occupancy and closes.  That's life.