Reply to Attn of

National Aeronautics and
Space Administration
Lyndon B. Johnson Space Center

2101 NASA Parkway
Houston, Texas 77058-3696

November 13, 2019
AL-19-070

TO: Distribution
FROM: AL/Chief Counsel

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

On Tuesday, November 19, 2019, the SpaceCom Networking Reception, sponsored by
National Trade Productions, Inc. (NTP), will be held at George R. Brown Convention Center
in Houston, Texas. NTP produces and manages proprietary events, as well as trade shows
for their clients across diverse market segments. NTP has actively organized and planned
SpaceCom and various events connected with SpaceCom. 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
networking reception follows the SpaceCom Entrepreneur Summit Workshop and the GSA
Commercial Spaceport Summit, which are held the day before SpaceCom. The reception
includes food and beverages. Invitees from NASA are members of the Agency Partnerships
Office Roundtable

Reception invitees other than NASA employees will include students, educators, members of
the Global Spaceport Alliance, and attendees of the SpaceCom Entrepreneur Summit. This
event is by invitation only and approximately 100 people are expected to attend. The
approximate value per attendee is $17.00 per person for food and beverages. There is an
Agency interest in having NASA personnel attend this reception because permits attendees to
meet in an informal setting and share ideas and viewpoints pertaining to NASA’s policies,
programs, and operation. It also provides attendees the opportunity 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-19-070 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 NTP are authorized to
attend and to accept any food and beverages offered in conjunction with this event.

However, NASA employees who have a significant role in any pending sensitive matter that
will substantially affect the interests of NTP, such as procurement duties, program
management, or negotiating a Space Act Agreement, and NASA employees who have
non-career political appointments, should seek a separate determination from their local
ethics counselor as to whether they may accept the invitation.

Distribution:
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