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Arguably that should be even easier to make. Find a good artist who's willing to take a bit of a gamble, program some excuse gameplay, usually some sort of puzzle game, and you're pretty much set. If your audience knows what they're there for, really the game is just a vehicle for the eye candy.

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Although I'm not sure it will fulfil the goals of making middle games the post mentions like building team expertise.

Unless you're doing a very unusual city builder I guess.

You won't build technical or design expertise, but I can see it being something that's easy enough to do as a side gig or as an experiment to see what it's like to publish a game on Steam or wherever. You can use that to decide if you want to invest more effort into it, while also making a bit of money. Low risk, low difficulty, low reward; perfect for learning.

To be honest, "erotic city builder" is such a novel concept that now I want someone to tackle it.

While I can’t argue against the idea of an erotic city builder I feel like it’s antithetical to the actual doom guy advice

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