By Heath Brown

If Republican presidential candidate Mitt Romney prevails next week, Nov. 7 will start the 11-week period of the presidential transition. For Romney’s team, this work has already commenced, having named former Secretary of Health and Human Services, Mike Leavitt, to prepare for three main categories of transition work: organizing the White House; making key appointments and finalizing a policy agenda.

As important as what Romney would do during his transition is how he would do it. Unfortunately, several early indicators raise red flags that Romney might permit lobbyists to serve on his transition teams, with only limited ethical guidelines and insufficient restrictions on conflicts of interest.

Newly elected presidents have typically bound those on their transition team to an ethical pledge and limited who could donate money for the inauguration. President Obama restricted lobbyists from serving on his transition; fearing they would promote the self-interest of their clients over the public interest of the nation.

Obama may have been looking to historical precedent for his suspicious views of lobbyists. Starting long before Inauguration Day, the Bush administration Interior Department, the agency charged with overseeing public land use, was at the center of ethical scandals and criminality. Steve Griles was in charge of transition planning for the department and was later appointed to be second-in-command to Secretary Gale Norton.

Griles, a lobbyist by training with clients in the natural gas industry, maintained ties with his former firm and continued to be paid by them throughout his employment at Interior. Griles kept an eye out for his old friends, including the infamous super lobbyist Jack Abramoff; both ended up serving time in prison for their crimes.

Romney’s pre-election transition team is already stocked with many current and former lobbyists, some with ties to the Bush administration. Reports from the Associated Press suggest that Romney’s transition team is already considering whether to lift the “revolving door” restrictions ordered by Obama on lobbyists working in the federal government. So, look for a moment at those advising Romney, in particular, those who are already being considered for major appointments.

Jack Gerard, for one, is reportedly on the short list for Energy secretary. Gerard, a lawyer by training, cut his teeth on Capitol Hill and is chairman of the National Capital Area Council of the Boy Scouts.

But he is now president and CEO of the American Petroleum Institute, the chief lobbying arm of the oil industry. Gerard has given more than $75,000 in campaign contributions and his association has reported $3.4 million in lobbying expenditures in just the first two quarters of 2012. He is in line to regulate the same industry for which he now lobbies.

But Gerard is not alone. Chuck Conner, president and CEO of the National Council of Farmer Cooperatives, is under consideration for Agriculture and Marion Blakey, CEO of the Aerospace Industries Association, for Transportation.

All of these individuals are highly qualified and experienced, but are they fit for service? To be sure, lobbying itself should not be a disqualifier; many distinguished former lobbyists have served at the highest levels of government, and many of the most disreputable in government never lobbied.

But Romney must answer some difficult questions about his criteria for high-ranking appointments: Will he solicit the advice of current lobbyists regarding whom to consider for key positions in his administration? Will he appoint former lobbyists to lead agencies in which their clients have a financial interest? Will he limit the “revolving door” back into lobbying by placing restrictions on how long a former appointee has to wait before lobbying his old office?

The transition period matters because it is the very first opportunity to influence the new president. If Romney failed to adopt strict ethical guidelines for his appointees, failed to clarify his views on lobbying and failed to make the transition period transparent and open to public participation, his first day on the job would send a distressing signal to those who voted for and against him.

Heath Brown is an assistant professor of political science at Seton Hall University and the author of "Lobbying the New President: Interest in Transition."