advises the Department of Education on scientific research and investments. Commentary Unitary executive theory Yoo suggested that since the primary task of the President during a time of war is protecting U.S. citizens, the President has inherent authority to subordinate independent government agencies, and plenary power to use force abroad. Yoo contends that the Congressional check on Presidential war-making power comes from its power of the purse. He says that the President, and not the Congress or courts, has sole authority to interpret international treaties such as the Geneva Conventions "because treaty interpretation is a key feature of the conduct of foreign affairs". His positions on executive power are controversial because the theory can be interpreted as holding that the President's war powers afford him executive privileges which exceed the bounds which other scholars associate with the President's war powers. His positions on the unitary executive are controversial as well because they are seen as an excuse to advance a conservative deregulatory agenda; the unitary executive theory says that every president is able to roll back any regulation passed by previous presidents, and it came to prominence in the Reagan administration as a "legal strategy that could enable the administration to gain control of the independent regulatory agencies that were seen as impeding the...agenda of deregulating business." Following his tenure as an appointee of the George W. Bush administration, Yoo criticized certain views on the separation of powers doctrine as allegedly being historically inaccurate and problematic for the global war on terrorism. For instance, he wrote, "We are used to a peacetime system in which Congress enacts the laws, the president enforces them, and the courts interpret them. In wartime, the gravity shifts to the executive branch." In 1998 Yoo criticized what he characterized as an imperial use of executive power by the Clinton administration. In an opinion piece in the WSJ, he argued that the Clinton administration misused the privilege to protect the personal, rather than official, activities of the President, such as in the Monica Lewinsky affair. At the time, Yoo also criticized President Clinton for contemplating defiance of a judicial order. He suggested that Presidents could act in conflict with the Supreme Court, but that such measures were justified only during emergencies. In 2000 Yoo strongly criticized what he viewed as the Clinton administration's use of powers of what he termed the "Imperial Presidency". He said it