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YOU CALL THIS GAMBLING?

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The rest of the time, Bullhead City is crass. Usually, it is also hot. Temperatures along the river, only a few hundred feet above sea level, regularly top those in Phoenix. The flood of people has taxed water lines and sewers to the limit.

None of that matters. "The growth of the casinos, which need places to house their workers, and the retirees coming in, especially from California, has slowed hardly at all, despite the recession," says Kathe Baker, the Mohave County assessor.

The Mohave planning department, an hour's drive to the east in the sleepy county seat of Kingman, lists more than a hundred subdivisions built or planned around Bullhead City.

Bullhead City is crawling with real-estate agents who are busy as blackjack dealers. "Starting in about late '88 and going until early '90, properties here flipped for major bucks," says Nancy Robbins, an assistant to Baker. "It was like the whole county just turned over, and it continued right up until August, when the Persian Gulf War started."

Real-estate experts marvel at the meteoric rise in land prices. "We'd been studying the [Bullhead City] market for about two years, and in that time, prices went from about $3,000 per acre to $9,000 per acre," says Dave Brown, Phoenix-based president of Homes by Dave Brown. "Now the same land is worth $25,000 to $30,000 an acre."

Brown says he expects to break ground soon on a 200-acre planned community located south of Bullhead City in an area called Mohave Mesa, where land values are highest. Set back from the raucous highway, Mohave Mesa is distinguished by lush golf courses, custom homes and large lots. It is the area's prime draw for those with upscale tastes.

Phil Jost, a broker with Sun Desert Realty in Bullhead City, says he's heard of some raw land in the neighborhood going for $15,000 an acre, "but that's the absolute cheapest that I know of."

The only apparent exception in this trend is a 585-acre parcel being offered for trade to Walter Biewer by the BLM. The feds' asking price? Just under $7,000 an acre.

"Seven thousand dollars per acre??" Phil Jost can hardly believe his ears. "Gosh, if a guy bought land in that area for $15,000 an acre, he could cut it into forty-acre parcels and it'd sell like hotcakes at $25,000 to $30,000 [an acre].

"There's a parcel right next to there that just sold for $18,000 an acre, unimproved, so how the heck can this other be worth only $7,000?" Jost says. "Seven thousand is 25 percent of the going rate. And knowing the government, it wouldn't surprise me if somebody talks them into it."

DOCUMENTS RELATING to eleven land trades over a three-year period near Bullhead City reveal a consistent bottom line. And the biggest beneficiaries of the exchanges seem to be the people who arrange them, not the taxpayers, who are the nominal owners of public land.

The trend is all the more startling in Bullhead City because, long after the real-estate crash in metropolitan Phoenix, the Mohave County enclave continued to be a red-hot market.

BLM land swaps are always an easy target but the criticism isn't always fair, counters one thirty-year veteran of the agency.

"In a land exchange, you're making a closed deal with a private individual, while in any other land transaction, you do it at public auction," says Glenn Collins, now deputy commissioner of the Arizona Department of Land. "So it can always be subjected to that criticism, `Did the public get cheated?' and BLM all over the West has been criticized.

"In fairness, you have to recognize their management objectives. BLM's goal is to use land with development potential to acquire land, usually remote, that needs to be protected."

The dimensions of the speculative profits made by land traders are fairly easy to quantify--at least $7 million on trades involving fewer than 3,000 acres of land in Mohave County alone since 1988. But numbers alone cannot tell the whole story.

The real value of the trades can only be measured against their purpose, which is to acquire for the national patrimony other lands deemed richer in natural treasures. These decisions are made by the gatekeepers in the federal agencies, primarily the Bureau of Land Management.

The gatekeepers--appraisers, managers and scientists charged with valuing the lands--do not concede they have erred. By their definition, the land-exchange program is a success. Through it, they have added thousands of important or unique acres to the nation's system of wilderness areas, parks and refuges.

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Kathleen Stanton