Zinke won confirmation on March 1, 2017, but state records and the foundation’s 2018 annual report listed him as continuing to serve as a foundation officer months after that. Zinke later said the foundation’s report was in error.

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In his ethics pledge, the interior secretary said: “I will not participate personally and substantially in any particular matter involving specific parties in which I know this entity is a party or represents a party, unless I am first authorized to participate.”

Neither the Interior Department nor Zinke attorney Stephen M. Ryan responded to requests for comment.

Zinke’s involvement in a land development deal involving the park, backed by David J. Lesar, chairman of the oil services firm Halliburton, is under scrutiny from the Justice Department and the Interior Department’s Office of Inspector General. The business and retail project, known as 95 Karrow, involves the construction of a parking lot on the foundation’s land and would lie near land owned by Zinke and his wife, Lola.

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Don Fox, a former acting director and general counsel at the Office of Government Ethics, said in a phone interview that the fact that Zinke continued to conduct foundation business after agreeing to stop raised questions about his overall conduct.

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“In the whole panoply of ethics violations, is this a major one? No,” Fox said, but adding that most Cabinet members adhere strictly to the terms of their ethics pledges. “The thing, I think, is the totally callous disregard for the standards and norms that previous administration officials have complied with, because it’s such a very easy thing to comply with.”

Before boarding Air Force One at Joint Base Andrews on Monday, President Trump praised Zinke’s record but told reporters he was scrutinizing his conduct.

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“I’m going to look at any reports. I’ll take a look. Certainly, I would not be happy with that at all. But I will take a look," Trump said. "But he has done a very good job as secretary.”

The discussion between Zinke and Taylor focused on two local planning questions — whether Taylor and others could set up a disc-golf park on the site and whether part of it would be converted into a parking lot. In an Aug. 10, 2017, email, Taylor asked whether he and his friends could set up a course to ensure the park — which includes a sledding hill — “gets used more in the non-winter months.”

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The park, which is primarily on land that BNSF Railway donated to the Zinkes' foundation over the past decade, is open to the public but largely undeveloped. The state highway used it as a staging site for a couple of years, Taylor said in a phone interview, and it includes a small pond that is also used for skating. It is gated and inaccessible by car, though residents can walk into the park easily.

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“It’s basically a passive recreation area,” Taylor said, noting that residents walk their dogs, go running and occasionally hold picnics there.

In his Aug. 13 reply to Taylor, Zinke said that it would be fine to erect a disc-golf course for his and his friends' personal use and that he was pursuing the construction of a parking lot.

“Dave, U and your friends are always welcome to use the park,” Zinke wrote, providing him with the access code to its gate so that they could enter with vehicles. “I would rather keep it to friends until a master plan is developed.”

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In an another exchange with Taylor, on June 21, 2018, Zinke criticized the initial Politico report that raised questions about his involvement in the 95 Karrow development. “Only fake news would make a mountain out of a sledding hill for kids,” the secretary wrote. “As usual, the park is just trying to help whitefish on what appears to be a good project.”

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But Chris Saeger, who directs the liberal advocacy group Western Values Project, said in an email that the correspondence shows that Zinke was misusing his nonprofit.

“Ryan Zinke broke his promise to the citizens of Whitefish to build this park for the public,” said Saeger, whose group is based in Whitefish. “Making it available only to his friends while shutting out the rest of us says everything about his approach to managing public lands.”

Taylor said the disc-golf course has yet to be set up, though the city has long identified it as a priority in its parks and recreation plan. “There’s no other real activities happening there,” aside from sledding and people passing through, he said.