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Investigating a Case of Alleged Collusion in Michigan Public Oil and Gas Lease Auctions

By Lucas Do

The state of Michigan administers oil and gas lease auctions semiannually through the Department of Natural Resources. In June 2012, the international news outlet Reuters published allegations of bid-rigging following the Department’s May 2010 auction. This paper empirically investigates the validity of Reuters’ allegations by analyzing auction bid sheets from 2008 to 2018 as well as other data reflecting market conditions over time. To this end, I first formulate a benchmark structural model of bidders’ valuations and estimate it with auction data from a period during which I assume no collusion occurred. Then, I extend the benchmark model by endogenizing bidders’ decision to collude. Using the extended model and the estimated benchmark parameters, I apply the simulated method of moments to solve for the collusive probability that “best” explains the observed bids during the alleged period of collusion. After discovering strong evidence for bid-rigging, I run counterfactual simulations to estimate the revenue damage caused to the state of Michigan by this non-competitive bidding behavior. I find that the hypothetical revenue damage, summed over the entire alleged collusive period, totals over $450 million. However, although these findings lend support to Reuters’ allegations and are contrary to the Department of Justice’s conclusion in 2014 after they had probed the case, they should be approached only with caution, given the limitations of the available data on the potential bidders.

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Advisors: Professor Jame Roberts, Professor Michelle Connolly | JEL Codes: L4, D44, L71

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