I understand the difference, but you said the big three tags are limited to conservation organizations by statute. The charity probably does great things, but it doesn't sound like a conversation organization to me.
All of them, moose included, are for conservation organizations. The Elk & Deer statutes differently only in that you can have a lottery as well as an auction.
Here are the questions from the application that I wonder what the answers were. C particularly.
c) details of the organization's previous involvement in the conservation of the species hunted under the license;
(d) details of the organization's previous experience in auctions or lotteries;
No those groups should not be ineligible. Conflicts of interest are never white or black, just varying shades of gray. To your point on this being relatively small in $, a national organization has a lot more to lose by playing fast and loose. Looking at this as MOGEI vs DU, the choice should have been clear. DU is a national org with a broader membership base. They plow the money into wetlands conservation and utilize PR money to double the amount. I can’t wait to see how MOGEI uses it.
It seems that FWP lets them keep the 10% to pay for the expenses of the auction. I’m fine with that, I guess, although DU utilized the money much better. I also wouldn’t pretend like there is some hard firewall between these orgs (firewall are always ephemeral). I would bet that the auction is marketed by blasting an email to every email listed on a MOGA member customer list. Hell, it would be my first suggestion. Anyone who ever paid for an outfitter is in the target demographic. No one is going to pay $50k and DIY on the tag, so we are back to our conflict of interest.
Here's the link to all of the proposals, it's under the Select Organizations to Auction:
https://fwp.mt.gov/aboutfwp/commission/august-2023-meeting
Attached is the PDF from the MOGA EI that shows the conservation work they are using to justify the license. Their plan is to put on a Moose symposium with the proceeds (education). So I think they did fit all of the criteria in there, personally.
I'm a huge fan of DU, personally. Their MT folks and their regional staff have been awesome partners in conservation and at the legislature. I still remember when Don Thomas was let go due the scrap with James Cox Kennedy over bridge access and how lots of folks dropped them for that. Yet they're likely doing more for wetland conservation in the private sector than anyone out there, which 110% benefits moose.
There are firewalls and the penalty for not ensuring proper management is anything from stiff fines to dissolution of your entities. Most non-profits have yearly audits to ensure compliance, especially those who get involved on the political end of things. As far as who gets targeted, I would imagine everyone who has purchased a license over the last years is going to get targeted. Those lists can be had from the agency (or they used to), and there are tons of other lists you can purchase, rent, borrow or steal. It happens all the time across the spectrum.
The 10% is statutory. 90% must be returned to the state, 10% can be kept to pay for services rendered to sell and there is a report due with accounting to ensure compliance. We've seen HT members pick up a Gov's goat tag and do a DIY hunt w/HT members. So I don't know that every license sold will be using an outfitter, but I can imagine the vast majority are. Regardless, that's happening with the Sheep, elk, deer, goat, moose, whatever. Auction tags cater to those who can afford an outfitter. That's how it's always been since these things were first introduced in 86.
I'm not justifying the license going to MOGAEI - or anyone that got one awarded, just trying to get the facts out there. From my reading, the MOGA EI does qualify. If there is a need to change that ARM rule, then I think there's a lot that could be done.