Kevin Minoli, EPA’s designated agency ethics official and principal deputy general counsel, had written in a March 30 memo that Pruitt’s lease of a room in a Capitol Hill condo co-owned by health-care lobbyist Vicki Hart — for $50 a night, charged only when he stayed there — did not constitute a gift because that rate for 30 consecutive days would have equated to a monthly rent of $1,500. Minoli described that as “a reasonable market value.”

But in a new memo, first reported by CNN and obtained independently by The Washington Post, Minoli emphasized that he only evaluated the terms of the lease and not activities the document did not cover…

He also clarified that he did not examine whether Pruitt’s arrangement violated the impartiality rule, which would have prohibited the administrator from having any dealings with other employees at Vicki Hart’s lobbying firm.