National Aeronautics and Space Administration 

Reply to Attn of:

Lyndon B. Johnson Space Center

2101 NASA Parkway 

Houston, TX 77058-3696

AL-23-009

April 3, 2023

TO: Distribution

FROM: AL/Deputy Chief Counsel

SUBJECT: Determination Regarding Attendance by NASA Employees at the RNASA 

Awards Dinner and Stellar Awards Luncheon 

On April 28, 2023, the Rotary National Award for Space Achievement (RNASA) Foundation, 

a nonprofit organization under section 501(c)(4) of the Internal Revenue Code, will host their 

annual awards banquet at the Hyatt Regency Houston in Houston, Texas. The awards banquet 

includes the presentation of RNASA's National Space Trophy and the Stellar Awards. The 

awards banquet will begin with a reception at 6 p.m., followed by dinner and the awards 

ceremony beginning at 7 p.m. 

 

The RNASA Foundation does not employ registered lobbyists, and is a distinct organization 

from, and not controlled by, the Rotary Foundation of Rotary International. The RNASA 

trophy winner is selected by a board of advisors composed of eminent individuals from 

government, industry, and media, including former winners. The RNASA 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. 

 

The estimated value of the dinner, including all food and drinks, is approximately $300 per 

person. Approximately 720 people are expected to attend this event. At the dinner, awards 

will be presented to various individuals for accomplishments in spaceflight, engineering, 

science, management, and education. Attendees will have a diversity of views or interests and 

will include personnel from other federal agencies, Congressional members and staff, local 

officials, members of the media, academia, and industry. Attendance at this event will allow 

NASA attendees to exchange information regarding various NASA programs with attendees 

from other organizations. RNASA is in control of the invitations and arrangements, including 

seating, for the event. 

 

Additionally, the Stellar Award nominees are invited to a luncheon hosted by RNASA on the 

same day. The estimated value of the lunch, including all food and drinks, is approximately 
2

$27 per person. Approximately 120 people are expected to attend the luncheon. Attendees 

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

agencies, 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. 

 

I find that these events meet the requirements of a "widely attended gathering" as defined in 5 

C.F.R. §2635.204(g). 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 space-related industry 

and the community. Accordingly, NASA employees who do not have a significant role in a 

matter affecting the interests of RNASA - 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. 

 

NASA employees whose duties may have a significant role in any matter affecting the 

interests of RNASA, 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. Additionally, employees who receive an award 

should contact their local ethics counselor regarding acceptance of the award.

Randall T. Suratt

Distribution: 

AD/A. Sanchez 

AH/A. E. Roemer 

AJ/R. F. Blake 

AL/M. M. Ceruti 

BA/J. C. Garcia 

CA/N. D. Knight 

DA/L. E. Kearney 

EA/J. K. White 

GA/H. C. Hu 

IA/J. Skelton 

JA/J. B. Walker 

Randall Suratt Digitally signed by Randall Suratt 

Date: 2023.04.07 08:55:56 -05'00'
3

LA/S. H. Schmidt 

MA/D. W. Hartman NA/W. J. Lyles 

OA/J. R. Montalbano 

RA/J. E. Noble 

SA/D. K. Baumann 

SA/J. T. Sims 

SA/T. A. Taddeo 

UA/A. T. Hart 

VA/V. C. Feng 

VA/C. Giulietti 

XA/B. Laws 

XI/E. K. Stansbery 

XT/R. G. Glayton