National Aeronautics and 

Space Administration 

Mary W. Jackson Building NASA Headquarters 

Washington, DC 20546-0001 

August 9, 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 RNASA 

Awards Dinner and Stellar Awards Luncheon on September 3, 2021 

On September 3, 2021, the Rotary National Award for Space Achievement (RNASA) 

Foundation, a nonprofit organization under section 50l(c)(4) of the Internal Revenue Code, 

1 will 

host an awards dinner at the Hyatt Regency Houston in Houston, Texas, at 6:00 p.m. 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. RN ASA is in control of all the 

arrangements and invitations for the event. 

Approximately 800 people are expected to attend this event. Attendees will have a diversity of 

views or interests and will include personnel from other federal agencies, members from the 

legislative branch, members of the media, academia, industry, and representatives from 

international partner organizations. 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 invited to tour Johnson Space Center followed by 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 200 people are expected to 

attend the luncheon. Attendees will have a diversity of views or interests and will include 

personnel from other federal agencies, the media, academia, 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. 

1 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 of36 

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 

RN ASA 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. 
I find that these event meets 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 ofRNASA-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 RN ASA, 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 for free attendance. 

4-=;_.,~cise any COVID-19 precautions appropriate to their situation. 

Adam F. Greenstone