there are few bidders and each has significant market power, the ascending open auction is likely not the best choice. Sealed-bid auctions tend to attract the most players. Since it is easier to collude in a second price, sealed-bid auction, a first-price, sealed-bid auction is the best choice for helium sales. Such sales, however, would require open access to the Cliffside reserves or to swaps, and this access would require monitoring by BLM or some other regulatory body.