National Aeronautics and Space Administration 

Reply to Attn of:

Lyndon B. Johnson Space Center

2101 NASA Parkway 

Houston, TX 77058-3696

AL-22-016

April 1, 2022

TO: Distribution

FROM: AL/Deputy Chief Counsel

SUBJECT: Determination Regarding Attendance by NASA Employees at the RNASA 

Awards Dinner and Stellar Awards Luncheon on April 29, 2022

On April 29, 2022, the Rotary National Award for Space Achievement (RNASA) Foundation, 

a nonprofit organization under section 501(c)(4) of the Internal Revenue Code, will host an 

awards dinner at the Hyatt Regency Houston in Houston, Texas, at 6:00 pm. The RNASA 

Foundation does not employ registered lobbyists, and is a distinct organization from, and not 

controlled by, the Rotary Foundation of Rotary International. Its operations are conducted by 

a committee of 22 individuals, over three-quarters of whom are not NASA employees, and 

the trophy winner is selected by a board of advisors composed of eminent individuals from 

government, industry, and media, including former winners. The RNASA Foundation was 

founded by the Space Center Rotary Club of Houston, Texas, in 1985 to recognize 

achievements in space and create greater public awareness of the benefits of space 

exploration. 

 

The estimated value of the dinner, including all food and drinks, is approximately $300 per 

person. At the dinner, awards will be presented to various individuals for accomplishments in 

spaceflight, engineering, science, management, and education. RNASA is in control of all the 

arrangements and invitations for the event. 

 

Approximately 650 people are expected to attend this event. Attendees will have a diversity 

of views or interests and will include personnel from other federal agencies, Congressional 

members and staff, members of the media, academia, and industry. Attendance at this event 

will allow NASA attendees to exchange information regarding various NASA programs with 

attendees from other organizations. 

 

Additionally, the Stellar Award nominees are to a luncheon hosted by RNASA on the same 

day. The estimated value of the lunch, including all food and drinks, is approximately $27 

per person. Approximately 120 people are expected to attend the luncheon. Attendees will 

have a diversity of views or interests and will include personnel from other federal agencies 
2

and industry. The Stellar Award nominees will receive a pen, book, and certificate for a total 

value of $20. The winner of the Stellar Award will receive a trophy valued at $180. 

 

I find that these events meet the requirements of a "widely attended gathering" as defined in 5 

C.F.R. §2635.204(g). I further determine that there is 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. 

Accordingly, NASA employees who do not have a significant role in a matter affecting the 

interests of RNASA - including NASA employees who are non-career employees subject to 

Executive Order 13989 - may accept an invitation for free attendance for themselves and a 

guest to the event. 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 whose duties have a significant role in any matter affecting the 

interests of RNASA, such as procurement duties, program management, or negotiating a 

Space Act Agreement, should seek a separate determination from their local ethics counselor 

as to whether they may accept the invitation.

Randall T. Suratt

Distribution: 

AA/V. E. Wyche 

AA/S. A. Koerner 

AA/D. M. Shafer 

AD/A. Sanchez 

AH/A. E. Roemer 

AJ/D. H. Urbanski 

BA/J. C. Garcia 

CA/N. D. Knight 

EA/J. K. White 

GA/H. C. Hu 

IA/A. M. Moore 

JA/J. B. Walker 

LA/S. H. Schmidt 

MA/D. W. Hartman 

NA/W. J. Lyles 

OA/J. R. Montalbano 

RA/J. E. Noble 

SA/J. T. Sims 

Randall Suratt Digitally signed by Randall Suratt 

Date: 2022.04.01 11:09:13 -05'00'
3

SA2/D. K. Baumann 

UA/A. T. Hart 

VA/V. C. Feng 

XA/J. A. McCullough