National Aeronautics and

Space Administration

Mary W. Jackson Building NASA Headquarters

Washington, DC 20546-0001

March 22, 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 Satellite 

Industry Association Annual Satellite Show Events on March 21 - 23, 2022

In conjunction with the Satellite Industry Association Annual Satellite Show, on March 21, 

2022, the Satellite Industry Association (SIA), a not-for-profit organization under Section 

501(c)(6) of the Internal Revenue Service Code, will hold a dinner at The International Spy 

Museum in Washington, DC, from 6:30 p.m. to 9:30 p.m. SIA is in control of the 

planning, organizing, and issuing invitations for this event. The event will provide an 

opportunity to discuss the highlights and roles that satellite technologies play in the 

nation’s economy and national security. Approximately 200 people are expected to attend 

the event. 

On March 22, 2022, United Launch Alliance (ULA) will hold a reception at the National 

Portrait Museum in Washington, DC, from 7:00 p.m. to 9:00 p.m. ULA is in control of the 

planning, organizing, and issuing of invitations for this event. The event will provide a 

continuing opportunity to discuss the highlights and topics of the Annual Satellite Show. 

Attendees will have a diversity of views or interests and will include personnel from other 

federal agencies, members of the legislative branch, and representatives from industry. The 

estimated cost of the events, including all food and beverages, is approximately $185 per 

person for the dinner on the 21st, and $75 per person for the reception on the 22nd. 

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

various NASA programs. I find that the events meet 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 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. NASA employees —

including NASA employees in non-career positions who are required to sign an ethics 

pledge under Executive Order 13989 — who do not have a significant role in a matter 

affecting the interests of SIA may accept an invitation for free attendance to the event. 

NASA employees who do not have a significant role in a matter affecting the interests of 

ULA may also accept an invitation for free attendance to that 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.
2 

However, NASA employees who are required to sign an ethics pledge under Executive 

Order 13989 may only attend the ULA reception 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 the sponsors, 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 

either of the invitations. 

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 ULA will be distributing 

a rocket model valued at $20.00. NASA employees in non-career positions who have 

signed the ethics pledge may only accept the rocket model if they reimburse the sponsor. 

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

individual situation. 

Adam F. Greenstone for