National Aeronautics and
Space Administration

Mary W. Jackson Building NASA Headquarters
Washington, DC 20546-0001

October 7, 2021
Reply to Attn of: General Law Practice Group
TOs Distribution
FROM: Agency Counsel for Ethics

SUBJECT: Determination Regarding Attendance by NASA Employees at the Lucy Launch
Mission Events, October 12 & 13, 2021

Southwest Research Institution (SwRI) and Lockheed Martin (LM), will host the Peer Awards
Dinner at the Cocoa Beach DoubleTree Hotel in Cocoa Beach, Florida on October 12, 2021; and
SwRI and United Launch Alliance (ULA) will host the Pre-Launch Dinner at the Kennedy Space
Center (KSC) Visitor Complex Saturn V Facility on October 13, 2021. These events will
recognize the contributions of Lucy Mission personnel and celebrate their mission work.
Approximately 200 guests will attend the Peer Awards dinner and approximately 800 people will
attend the pre-launch dinner. Attendees will include representatives from industry, academia, as
well as from state government. The approximate value of the Peer Awards dinner is $145 a
person; and the pre-launch dinner is $130 a person.

In accordance with 5 C.F.R. § 2635.204(g), Gifts of Free Attendance at Widely Attended
Gatherings, I find this event meets the requirements of a widely attended gathering, and | further
determine that there is an agency interest in having NASA personnel attend this event because
their participation will further agency programs and operations. Specifically, this event allows
NASA employees to honor and show support for a program recognizing important contributions
to U.S. aerospace efforts. This event also provides a forum for the attendees to disseminate
information on NASA’s ongoing activities and to discuss matters of interest to NASA with a
diverse group of fellow attendees. Because of these benefits to NASA, and having considered
the factors enumerated in 5 CFR § 2635.204(g)(4), I also find that the Agency’s interest in the
invited NASA employees’ attendance outweighs the concern that such employees may be, or
may appear to be, improperly influenced in the performance of official duties.

However, NASA employees whose duties may substantially affect any of the event sponsors,
such as by way of contracting duties, should seek an individual determination pursuant to 5
C.F.R. § 2635.204(g)(3)(i), regarding participation in this event from their local ethics counselor.
Moreover, NASA employees who are in non-career positions in which Executive Order 13989
requires signing an ethics pledge may only accept the meals if they reimburse the sponsor the
value of the event and any gift items accepted for themselves and their guest.

Accordingly, I have determined that NASA invitees may accept their invitations for
complimentary attendance at these events in accordance with the ethics rules. NASA attendees


are reminded to exercise any COVID-19 precautions and obtain any administrative approvals
related to COVID safety appropriate to their individual situation.

Attendees are reminded of the $20 gift exception at 5 C.F.R. § 2635.204(a), which provides that
employees may accept gifts valued at no more than $20 per occasion (and no more than $50
from one source in a calendar year). We understand that SwRI will be distributing a lanyard
($2.34). NASA attendees including employees in non-career positions who have signed the
ethics pledge may accept the gift of lanyard.

BLL

Adam F. Greenstone