Unlike in previous administrations, however, this time the proposed rules are long shots to be finished and enacted. Because of “the very clear signals of an anti-regulatory mandate from the president,” they are less likely to be implemented than in prior eras, according to Sally Katzen, a New York University law professor and former deputy director for management at the Office of Management and Budget. Instead, they may vanish with little or no announcement or explanation. Already, they have disappeared from the main federal website that lists rules in the works.

Five federal agencies contacted by ProPublica said they are reviewing regulations but declined to address specifically the pending rules that were put on hold. A spokesman for the Health Resources and Services Administration said his agency is pursuing “efforts to reduce regulatory burden.” The White House did not respond to a request for comment.

While the media and the public focus on the Russia scandal or who has the ear of the president, the Trump administration and the Republican-controlled Congress are conducting a broad assault on regulations. Trump, making regulatory rollback a centerpiece of his administration, contends onerous rules stifle American businesses and the economy. Steve Bannon, his chief strategist, promised supporters a “deconstruction of the administrative state.” On Monday, The New York Times surveyed the sweeping efforts to roll back environmental rules, restrictions on Wall Street, and other limitations on businesses of every stripe.

Finalized rules cannot be easily rescinded. Doing so often requires some congressional action. And agencies typically must explain why they are canceling a rule. Groups that object sometimes sue to preserve the regulations.

But dozens of rules are pending and those may be easier to kill. After previous administrations’ freezes, agencies examined proposed rules and went forward with the vast majority, according to administrative law experts. This time may be different. A few days after his freeze, Trump signed another executive order on Jan. 30, ordering that agencies cut two old regulations for each new one. Given that edict, federal agencies, like the Department of Transportation or the Environmental Protection Agency, may resist finalizing pending rules.

Regulations often undergo review for years before they take effect. Typically, after a law is passed, the appropriate agency comes up with proposed rules for implementing it, and puts them out for public comment. Supporters and opponents (often corporations or their representatives) weigh in. The agency then edits the rules and sends them to the Office of Information and Regulatory Affairs, a body within the Office of Management and Budget. There, the office conducts an economic analysis to make sure the costs don’t outweigh the benefits. Finally, if the new regulations clear all the hurdles, they are published in the Federal Register. After 60 or 90 days, they become effective.

At least 25 rules were waiting on the OIRA runway for final approval in the waning days of the Obama administration. Some had gone through the entire process and merely required being sent to the Federal Register. (A separate group of regulations were at the Federal Register but had not become effective. These are on hold as well.)

Among the pending rules was a Department of Transportation initiative calling for all railroad operations to have at least two crew members. Proponents say the rule could minimize the risk of a repeat of the 2013 Canadian train accident in which a derailed, unattended locomotive became a burning missile hurtling through a small Canadian town called Lac-Mégantic, killing 47 people and spilling 6 million liters of crude oil. The railroad industry has objected to the new restriction, contending the rule is too costly and unlikely to minimize accidents.

Another rule would require that fluorescent lights in daycares and schools contain no PCBs, which can become toxic when burned. Still others cover everything from grain elevator performance to disclosures about foods that have been bioengineered.

Trump’s two-for-one edict already faces problems. It stipulates that the incremental cost of new regulations in 2017 must be zero: In other words, that discarding two regulations must save as much money as the new regulation costs. The trouble with this approach is that regulations typically entail large upfront investments, but little in the way of ongoing outlays. For instance, if the government requires retrofitting of certain plants with safer machines, that’s expensive at first. But once manufacturers have complied, the ongoing cost is minimal. Therefore, to find enough savings to offset a new regulation might mean cutting many more than two old ones.

Perhaps more significantly, scholars argue that the Trump order is against the law. “Agencies do not simply regulate for the sake of regulation — each regulation is aimed at implementing a specific provision of a statute passed by Congress,” Columbia Law School’s Michael Burger and Jessica Wentz wrote recently. Indeed, liberal groups Public Citizen, the National Resources Defense and the Communications Workers of American filed a lawsuit to block the Trump executive order, contending it is arbitrary.

But there’s little legal recourse for resurrecting proposed rules, which might be shelved without any public notice. If agencies do so, it’s unclear if they have to explain why. Liberal interest groups argue that ditching pending rules without a legitimate justification might not stand up to a court challenge, though they concede it’s uncharted territory. They say rules that have undergone public comments and other scrutiny may also be protected under the prohibitions against arbitrary regulatory decisions.

“We believe it is illegal to kill a final rule without good reason, not just that Donald Trump doesn’t like rules,” said Rena Steinzor, a law professor at the University of Maryland and former president of Center for Progressive Reform, a think tank. “That’s not good enough.”

While President Trump has not moved to fill many jobs that require Senate confirmation, he has quietly installed hundreds of officials to serve as his eyes and ears at every major federal agency, from the Pentagon to the Department of Interior.

Storm Clouds Encoach the White House. Image Courtesy Tim Evanson

Unlike appointees exposed to the scrutiny of the Senate, members of these so-called “beachhead teams” have operated largely in the shadows, with the White House declining to publicly reveal their identities.

While some names have previously dribbled out in the press, we are publishing a list of more than 400 hires, providing the most complete accounting so far of who Trump has brought into the federal government.

The White House said in January that around 520 staffers were being hired for the beachhead teams.

The list we obtained includes obscure campaign staffers, contributors to Breitbart and others who have embraced conspiracy theories, as well as dozens of Washington insiders who could be reasonably characterized as part of the “swamp” Trump pledged to drain.

The list is striking for how many former lobbyists it contains: We found at least 36, spanning industries from health insurance and pharmaceuticals to construction, energy and finance. Many of them lobbied in the same areas that are regulated by the agencies they have now joined.

That figure is almost certainly an undercount since we only included those who formally registered as lobbyists, a process increasingly avoided by many in Washington.

During the campaign, Trump said he would have “no problem” banning lobbyists from his administration. But they have nonetheless ended up in senior roles, aided by Trump’s weakening of Obama-era ethics rules that modestly limited lobbyists’ role in government.

The White House didn’t respond to requests for comment.

There are many former congressional staffers, several top officials from the George W. Bush administration, and even a handful of holdovers from the Obama administration. The list also includes at least eight staffers drawn from the Heritage Foundation, a conservative think tank that forged close ties to the new administration during the transition.

Much about the role of the beachhead teams at various federal agencies is unclear. But close observers of the early weeks of the Trump administration believe they have taken on considerable influence in the absence of high-level political appointees.

“If the public and Senate is in the dark about a team created without a Senate confirmation process, no one will be permitted to shed light on who is hopelessly conflicted or who is obviously unqualified — and who is both,” said Jeff Hauser, director of the Revolving Door Project at the Center for Economic and Policy Research.

The beachhead team members are temporary employees serving for stints of four to eight months, but many are expected to move into permanent jobs. The Trump administration’s model is based on plans developed but never used by the unsuccessful presidential campaign of Mitt Romney.

“The beachhead teams involve people with considerable authority over the federal government,” said Max Stier, the CEO of the Partnership for Public Service, a nonpartisan group that advises presidential candidates on smooth transitions. “We need clarity about what they’re doing and what their role is going to be.”

The Obama administration also hired temporary staffers after the inauguration. But Trump has brought in many more, Stier said.

The new list of names was provided to us by the Office of Personnel Management, the government’s human resources agency. We received additional names from other federal agencies in response to Freedom of Information Act requests. At least a few people on the list have changed agencies or left the administration, including, for example, the young Department of Housing and Urban Development staffer who was fired after his anti-Trump writings during the campaign came to light.

Here is a run-down of some of the Trump hires.

The Breitbart wing

Andrew Breitbart | Image : Gage Skidmore

Curtis Ellis was a columnist for WorldNetDaily, a website best known for its enthusiastic embrace of the false notion that President Obama was born outside the United States. A column headlined the “The Radical Left’s Ethnic Cleansing of America” won Ellis an admiring interview with Steve Bannon, now Trump’s top aide. He is a longtime critic of trade deals such as the Trans-Pacific Partnership.

Ellis was hired Jan. 20 as a special assistant to the secretary at the Labor Department. Asked about his role in a brief phone interview Tuesday, he said: “Nothing I can tell you.”

Jon Perdue, a self-described guerrilla warfare expert and fellow at a little-known security think tank, wrote a book called “The War of All the People: The Nexus of Latin American Radicalism and Middle Eastern Terrorism.” He is also a onetime contributor to Breitbart.

Perdue was featured on CNBC’s reality series “Make Me a Millionaire Inventor” for his invention, the Packbow, which Perdue came up with while studying “collapsed societies, and what people who lived in those societies came up with to either defend themselves or to survive.” It’s a bow and arrow that doubles as a compass, tent pole, walking stick, spearfishing rig, and water purification tablet receptacle.

Perdue was hired as a special assistant at the Treasury Department. The agency didn’t immediately respond to a request for comment.

John Jaggers ran the Trump campaign in Maryland and Virginia, where he made headlines for endorsing the conspiracy theory that Hillary Clinton was “very, very sick and they’re covering it up.” As he put it last August: “The woman who seeks to be the first female president of the United States wears a wool coat at every single thing. Have you ever stopped to wonder why? It’s a big deal, folks.”

Jaggers was hired Jan. 20 as senior adviser at the General Services Administration, which oversees tens of billions of dollars of government procurement every year. But records show he left the job on March 3. He declined to comment.

Tom Price, President-elect Donald Trump’s choice for Secretary of Health and Human Services : Image Wikipedia

Swamp denizens, including health care lobbyists hired by HHS Secretary Tom Price

Alexandra Campau, hired at the department of Health and Human Services, was formerly a lobbyist in Washington for the law firm Cozen O’Connor. According to disclosure records, her firm’s clients included a licensee of insurance giant Blue Cross Blue Shield, and Fresenius Medical Care, a German company that specializes in medical supplies for renal dialysis.

Timothy Clark, a senior adviser to HHS Secretary Tom Price, ran his own political consulting firm in California. His past clients included PhRMA, the powerful trade group that represents the pharmaceutical industry.

Keagan Lenihan, also a senior adviser to Price, was a director of government relations at McKesson Specialty Health, a firm that supports independent health providers. Disclosure records show Lenihan directly lobbied HHS. For Lenihan, the new post represents a return trip through the revolving door between government and the private sector, and a reunion with an old boss. Before registering as a lobbyist, she was a senior legislative assistant for Price, when the now-HHS secretary was in Congress.

Asked about the three HHS staffers, an agency spokeswoman said: “We are not confirming or commenting on personnel at this time.”

Justin Mikolay, hired at the Department of Defense, was previously a registered lobbyist for Palantir. His title at the tech firm was “evangelist.” Mikolay lobbied for the “procurement/deployment of the Palantir Government software platform” throughout intelligence and defense agencies, according to disclosure records.

Mikolay was a speechwriter to Secretary of Defense Leon Panetta between 2011 and 2013, according to his LinkedIn profile. Mikolay also previously served as a speechwriter for current Secretary of Defense James Mattis. He declined to comment.

Chad Wolf, a Bush-era Transportation Security Administration official turned lobbyist, is currently serving as an adviser to the TSA at the Department of Homeland Security. His clients have included defense and homeland security contractors.

Reached Tuesday, Wolf declined to comment. George Rogers, CEO of Wolf’s lobbying firm, Wexler Walker, told ProPublica that Wolf is currently on unpaid leave.

As we’ve previously reported, lobbyists for the construction industry trade association and financial services firm TransAmerica are on the team at the Department of Labor.

Trump campaign vets — including very young ones

The list also includes what appear to be dozens of former Trump campaign staffers, including several who graduated from college last year. One, Danny Tiso at the Department of Labor, graduated from high school in 2015, according to his LinkedIn profile. He worked for the Trump campaign in New Hampshire.

Seth Harris, who was on the first Obama-Biden transition team and later became a top Labor Department official, said it’s not uncommon to bring in campaign staff to agencies — “as long as there are senior political people to direct the junior people.”

“This is how you incorporate the people who are your strongest supporters into the government,” he said. “There are plenty of junior jobs in the government that these people can do — public-affairs jobs, special assistant jobs.”

Reporting was contributed by Robert Faturechi, Jesse Eisinger, Alison Gregor, Jessica Huseman, Lauren Kirchner, Alec MacGillis, Clifford Michel, T. Christian Miller, Charles Ornstein, Andrew Revkin, Marcelo Rochabrun, Lisa Song and Annie Waldman.