National Aeronautics and Space Administration

Headquarters

Washington, DC 20546-0001

July 29, 2021

Reply to Attn of: General Law Practice Group

TO: Distribution

FROM: Agency Counsel for Ethics

SUBJECT: Determination Regarding Attendance by NASA employees at the Goddard 

Memorial Awards Dinner on September 17, 2021

On September 17, 2021, the National Space Club and Foundation (the Club), a nonprofit 

organization under 501(c)(3) of the Internal Revenue Code, will host a gala reception and 

dinner at the Washington Hilton in Washington, D.C. The event will start with a general 

reception at 6:30 p.m. where the awardees are introduced and meet senior level attendees, 

followed by dinner starting at 7:30 p.m. At the dinner, awards will be presented to various 

individuals, including local students, for accomplishments in spaceflight, engineering, 

science, management and education. The premiere award, the Robert H. Goddard Memorial 

Trophy, will be presented to "an individual, group or program deemed to have made the most 

significant contribution to space activity in the previous year." This year the award will be 

presented to The NASA & SpaceX Crew Demo-2 Team.

Approximately 2,500 people are expected to attend the event. Attendees will have a diversity 

of views or interests and will include members from the legislative branch, academia, industry 

representatives, employees of other Federal agencies, media, and members of the public. The 

estimated value of the reception and dinner, including all food and beverages, is $300 per 

person. The National Space Club is in control of the planning and seating for both the 

reception and dinner.

There will be an earlier awardee recognition reception hosted by the Club for the awardees, 

heads of agencies, senior academia representatives and senior industry representatives which 

approximately 150 people will attend from 6:00 to 7:00 p.m. There will not be separate food 

or beverage service at the awardee recognition reception-invitees will obtain food and 

beverage from the general reception area. The awardee recognition reception will give the 

awardees the opportunity to meet senior leaders from different sectors.

Attendance at these events will allow NASA attendees to exchange information regarding 

various NASA programs. There is also an Agency interest in having NASA personnel attend 

these events because it will provide an opportunity for the invited persons to exchange ideas 

and views pertaining to NASA's policies, programs and operations. I find that both the 

plenary reception and dinner and the awardee recognition reception meet the requirements of 

a "widely attended gathering" as defined in 5 C.F.R. §2635.204(g).
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Accordingly, NASA employees-. including NASA employees in non-career positions who 

are required to sign the ethics pledge under Executive Order 13989-who do not have a 

significant role in a matter affecting the interests of the National Space Club and 

Foundation-may accept an invitation for free attendance for themselves and a guest to these 

events. In those circumstances, I find that the Agency's interest in attendance outweighs any 

concern that the individual may be, or may appear to be, improperly influenced in the 

performance of their duties.

However, NASA employees who have a significant role in any pending matter affecting the 

interests of the National Space Club and Foundation, such as procurement duties, program 

management, or negotiating or administering a Space Act Agreement, should seek a separate 

determination from their local NASA ethics office as to whether they may accept the 

invitation. Also, NASA employees who receive an invitation from an entity other than the 

National Space Club and Foundation should seek a separate determination from their local 

NASA ethics office.

This widely attended gathering determination does not cover the receptions in hospitality 

suites that may occur both before and after the Goddard Memorial Awards Dinner. These 

suites will be hosted by corporate sponsors. NASA employees not subject to the ethics pledge 

of Executive Order 13989 who are invited, may receive refreshments provided in these suites 

under the exception to the gift rules that allows acceptance of gifts (including refreshments 

and tangible gift items) with an aggregate value of $20 or less per event, though not to exceed

$50 from the ame source in the same year. However, non-career NASA employees subject 

to the ethics pledge required by Executive Order 13989 must provide reimbursement for.the 

fair market value of any refreshments they or their guests consume in the hospitality suites. 

We understand that honor baskets to do so will be provided. Attendees are reminded to 

exercise any COVID-19 precautions appropriate to their individual situation.

Adam F. Greenstone