Documents provided to Congress fail to show Scott Pruitt got federally required waivers to fly first class -- and if he did, then his office has twice declined to hand them over to fellow Republicans asking for the verification.
Instead, in response to two requests for the waivers, the Environmental Protection Agency provided investigators with only two memos, according to the House Oversight Committee.
CNN separately obtained the memos, which state that people have recognized Pruitt and the occasional "lashing out from passengers" could "endanger his life" if he continues to fly in coach.
The limited nature of the two memos, along with a past claim by his spokesman, suggests the EPA administrator violated federal rules by failing to obtain a justification for the upgrades before each trip.
The EPA has previously defended Pruitt's travel and security arrangements, but did not respond to questions from CNN before the publication of this story about the memos or whether Pruitt obtained the required waivers.
After publication, EPA spokesman Jahan Wilcox said, "We are working diligently with (House Oversight) Chairman (Trey) Gowdy and are in full cooperation in providing the Committee with the necessary documents, travel vouchers, receipts and witnesses to his inquiries."
Pruitt had been asked twice -- in February and April -- by Gowdy, a fellow Republican, to provide any waivers exempting him from regulations requiring federal employees to typically fly in standard coach seats.
The two memos were part of 1,700 pages of documents turned over at the request of South Carolina's Gowdy. The documents include vouchers for all of Pruitt's official travel since he was confirmed and for EPA, vouchers for staff who went on international trips to Italy and Morocco, emails regarding Pruitt's lease of a room from a lobbyist's wife, and EPA correspondence between that lobbyist and other employees of his firm.
In addition, Gowdy's office was able to review travel vouchers for members of Pruitt's security detail, according to his office.
The flights are among several alleged ethical transgressions or questionable spending practices that have landed Pruitt in the spotlight of multiple investigative bodies, including Gowdy's committee, the EPA inspector general, and the Government Accountability Office.
Gowdy's request for the waivers was prompted by a Politico article from February in which Wilcox said Pruitt was granted a "blanket waiver" to travel in first class for security reasons.
The next day, Wilcox's story changed. Politico reported that federal regulations specifically prohibit "blanket authorization, and Wilcox changed his statement, saying a waiver was submitted "for every trip."
While the EPA has not provided detailed waivers, it has handed over more than 1,700 pages of documents in response to multiple requests relating to Pruitt's travel habits, unprecedented security, and sweetheart condo deal from an energy lobbyist, according to Gowdy's office.
But one memo indicates there was only one request for a waiver. It's dated May 1, 2017, and is a request from the acting security chief that Pruitt "be strategically seated in business and or first class seating when on official travel."
"We have observed and (sic) increased awareness and at times lashing out from passengers which occurs while the Administrator is seated in coach with PSD (Protective Services Detail) not easily accessible to him due to uncontrolled full flights," the memo reads.
"Therefore, we believe that the continued use of coach seats for the Administrator would endanger his life," the memo continues.
The second memo is a response from Acting Controller Jeanne Conklin, whose office oversees compliance with spending regulations.
Conklin wrote she "determined your request complies with criteria" for allowing first or business class seats, and pointed the Administrator's office to a specific paragraph of government travel regulations.
That paragraph states upgraded travel is allowed if "use of coach-class accommodations would endanger your life or Government property."
That regulation also requires the justification for upgraded seats be prepared for each trip.
"Blanket authorization of other than coach-class transportation accommodations is prohibited and shall be authorized on an individual trip-by-trip basis, unless the traveler has an up-to-date documented disability or special need," the regulation reads.
Update: This story has been updated to add the statement EPA gave to CNN after initial publication.