National Aeronautics and 

Space Administration

Mary W. Jackson Building NASA Headquarters

Washington, DC 20546-0001

June 6, 2022

Reply to Attn of: General Law Practice Group

TO: Distribution

FROM: Agency Counsel for Ethics

SUBJECT: Determination Regarding Attendance by NASA employees at the Advanced 

Space and Rocket Lab Capstone Launch Event on June 8, 2022

On June 8, 2022, Advanced Space LLC and Rocket Lab USA, Inc., will host a reception at 

Café Berlin in Washington, DC, from 6:00 p.m. – 8:00 p.m. The event will provide a forum 

for informal discussion on the challenges of a successful Capstone Mission launch.

Approximately 110 people have been invited to attend. Attendees will have a diversity of 

views or interests and will include representatives from the legislative branch, state and local 

government officials, representatives from industry, employees of Federal agencies, and the 

media. The estimated cost of the event, including all food and beverages, is $23 per person. 

Advance Space and Rocket Lab are in control of the organizing, planning and invitations for 

this event. Attendance at this event will allow NASA attendees to exchange information 

regarding various NASA programs. I find that the event meets the requirements of a “widely 

attended gathering” as defined in 5 C.F.R. § 2635.204(g)(2). 

I further determine that there is an Agency interest in having NASA personnel attend the 

event because it will provide an opportunity for the invited persons to exchange ideas and 

views pertaining to NASA’s policies, programs and operations. NASA employees who do 

not have a significant role in a matter affecting the interests of the sponsor may accept an 

invitation for free attendance 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 in noncareer positions who are required to sign the ethics pledge under Executive Order 13989, may 

only attend the event if they reimburse the sponsor the value of the event.

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

the interests of Advanced Space and Rocket Lab, such as procurement duties, program 

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

determination from their local ethics counselor as to whether they may accept the invitation.

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 Advanced Space and Rocket Lab 
2 

will have a mission patch ($5.00), mission sticker ($0.45), and a T-shirt ($16.00) available on 

a table for guests to pick up. NASA non-career employees subject to the ethics pledge of 

Executive Order 13989 may not accept gift items from lobbyists or registered lobbying 

organizations under the $20 exception. An honor basket will be available for payment. 

Attendees are reminded to exercise any COVID-19 precautions appropriate to their individual 

situation.

for Adam F. Greenstone