No. The official Gold Card framework consists of a processing fee and a gift to the U.S. government, followed by processing under existing immigrant categories; no land purchase substitutes for the gift. A passive land purchase also does not satisfy EB-5, though a qualifying active enterprise involving real estate must be assessed under EB-5's separate investment and job-creation rules.
The gift cannot be replaced by an asset purchase under any reading
The Gold Card program, as described on its official page and FAQ, has two financial components: a nonrefundable processing fee of US$15,000 per person and, after successful vetting, a gift of US$1 million to the U.S. government for the principal applicant, with the same fee and gift for each accompanying spouse or unmarried child under 21. The word gift is precise.
The money is given to the government; it is not invested, held, secured on anything or returned. There is no provision under which an applicant may instead buy farmland, purchase a business or deposit funds in a bond. The confusion arises because EB-5 does involve an investment, but EB-5 requires capital at risk in a new commercial enterprise that creates at least ten full-time jobs, and passive ownership of agricultural land satisfies neither element.
A landowner who wants permanent residence therefore faces a real choice between the Gold Card gift and an actual EB-5 investment, and his existing land is relevant to neither except as a possible lawful source of funds. Re-verify the terms on the official page before acting.