Reply to Attn of

National Aeronautics and
Space Administration

Lyndon B. Johnson Space Center
2101 NASA Road 1
Houston, Texas 77058-3696

November 7, 2019
AL-19-069

TO; Distribution
FROM: AL/Chief Counsel

SUBJECT: Widely Attended Gathering Determination Regarding Attendance at the Space
Commerce Conference and Exposition (SpaceCom) VIP Reception

On Wednesday, November 20, 2019, the SpaceCom VIP reception will be held at Partnership
Tower, in Houston, Texas. SpaceCom is a two-day event designed to be a catalyst for
innovation and growth in the commercial development of space. It is engineered to fuel
business innovation across the aerospace, medical, energy, transportation, maritime,
communications and advanced manufacturing industries. The VIP reception will be held on
the first day of SpaceCom. The reception includes food, alcoholic beverages, and brief
welcoming remarks from the sponsors. The sponsors of the reception are Winstead P.C., the
Greater Houston Partnership, HoustonFirst, BWX Technologies, the Italian Trade Agency —
Houston, and the Bay Area Houston Economic Partnership. Invitees from NASA are
members of the SpaceCom Advisory Board, speakers, presenters and senior NASA
managers.

Reception invitees other than NASA employees will include industry leadership, researchers,
technologists, members from academia, and federal, state and local government officials.
This event is by invitation only and approximately 250 people are expected to attend. The
approximate value per attendee is $50.00 per person for food and alcoholic beverages. The
reception permits attendees to meet in an informal setting and share ideas and viewpoints on
a variety of NASA topics. It also provides the opportunity for NASA attendees to discuss
common issues and solutions across disparate industries and NASA goals and objectives
related to the commercialization of space.

This event is of interest to NASA and will serve as a forum for facilitating the widest
practicable dissemination of information concerning the Agency and its activities. This event
will further agency programs or operations including promoting community relations and
providing the opportunity for the exchange of views and information between leaders within
the agency and leaders within the community. I find that this event meets the requirements
of a “widely attended gathering" as defined in 5 C.F.R. §2635.204(g)(2).


AL-19-069 2

It is my determination that it is in the Agency’s interest for NASA invitees to attend the
reception. Their attendance outweighs any concern that the acceptance of any benefits may,
or may appear to, improperly influence them in the performance of their official duties.

Accordingly, NASA invitees whose duties do not substantially affect Winstead P.C., the
Greater Houston Partnership, HoustonFirst, BWX Technologies, the Italian Trade Agency —
Houston, and the Bay Area Houston Economic Partnership are authorized to attend and to
accept any food and alcoholic beverages offered in conjunction with this event.

Those NASA employees whose duties may substantially affect Winstead P.C., the Greater
Houston Partnership, HoustonFirst, BWX Technologies, the Italian Trade Agency — Houston,
and the Bay Area Houston Economic Partnership, or who are in non-career positions for
which Executive Order 13490 of January 21, 2009 requires signing an ethics pledge, are not
covered by this determination and should see an individualized ethics determination from the
Office of Chief Counsel regarding participation in this event pursuant to 5 C.F.R.
§2635.204(g)(2).

Theodore U. Ro

Distribution:
AAIM. S. Geyer
AA/V.E. Wyche
AA/D. M. Shafer
AD/D. A. Conder
AH/A. H. Roemer
AJ/D. H. Urbanski
BA/D. L. Johnson
CA/S. A. Koerner
EA/K. N. Window
GAM. A. Kirasich
IA/A. M. Moore
JA/J. B. Walker
LA/S. H. Schmidt
NA/W. R. DeLoach
OAKK. A. Shireman
RAR. M. Cort
SAIC. A. Koerner
VAJ/J. S. Stich
XA/J. A. McCullough

ce:
W-JS/L. M. Atkinson
WRIC. R. Lamb