National Aeronautics and Space Administration

Headquarters

Washington, DC 20546-0001

April 14, 2023

Reply to Attn of: General Law Practice Group

TO: Distribution

FROM: Agency Counsel for Ethics 

SUBJECT: Determination Regarding Attendance by NASA Employees at the 

38th Space Symposium and concurrent events, April 16 – 20, 2023

On April 17 – 20, 2023, the Space Foundation, a nonprofit organization under 501(c)(3) of 

the Internal Revenue Code will host the 38th Space Symposium in Colorado Springs, 

Colorado. Complementary Government registration will be covered under the authority of 

31 U.S.C. §1353, Gifts of Travel From Non-Federal Sources, using NASA Form 1167. 

Invitations to additional events may have been provided by the sponsor. The Space 

Foundation is in control of the arrangements, invitations, and seating for a majority of the 

events taking place at the Broadmoor Hotel.1 The following events will be held in 

conjunction with the Space Symposium:

1. On April 16, 2023, the Space Foundation, a nonprofit organization under 501(c)(3) of 

the Internal Revenue Code, will host a Yuri’s Night at 5:30 p.m. to 9:00 p.m. in the Space 

Foundation Discover Center in Colorado Springs, Colorado. Approximately 500 people are 

expected to attend. Attendees will have a diversity of views or interests and will include 

young professionals, students, representatives from other federal agencies, congressional 

members, representatives from industry, academia, and media. The estimated cost of the 

event, including all food and beverages, is approximately $70 per person. Attendance at this 

event will allow NASA employees and a guest to exchange information regarding various 

NASA programs.

2. On April 16, 2023, the Collins Aerospace will hold a reception from 6:00 p.m. to 

10:00 p.m. in the Golden Bee, at the Broadmoor. Approximately 200 people are invited to 

attend. This event provides an opportunity for informal discussion with people who have 

diverse views or interests and will include people from other federal agencies, congressional 

members, and representatives from industry, academia, media, and foreign governments. 

The estimated cost of the event, including all food and beverages, is approximately $35 per 

1 Certain companies which support the symposium will provide very light snacks and non-alcoholic beverages 

during morning and afternoon breaks and at some breakout lectures or discussions. This modest fare is not 

considered a gift under Federal ethics requirements. See 5 C.F.R. § 2635.203(b)(1).
2

person. Attendance at this event will allow NASA employees to exchange information

regarding various NASA programs.

3. On April 16, 2023, the United Launch Alliance will hold a reception from 7:00 p.m. 

to 8:30 p.m. in the Penrose Room, at the Broadmoor. Approximately 250 people are invited 

to attend. This event provides an opportunity for informal discussion with people who have 

diverse views or interests and will include people from other federal agencies, congressional 

members, and representatives from industry, academia, media, and foreign governments. 

The estimated cost of the event, including all food and beverages, is approximately $75 per 

person. Attendance at this event will allow NASA employees to exchange information 

regarding various NASA programs. Due to space limitations for the event, guests are not 

invited.

4. On April 17, 2023, the Space Foundation, a nonprofit organization under 501(c)(3) of 

the Internal Revenue Code, will hold a pre-ceremony speaker reception from 4:45 p.m. to 

6:00 p.m. at the Broadmoor Hotel. Approximately 125 people are expected to attend. This 

event provides an opportunity for informal discussion with people who have diverse views or 

interests and will include people from other federal agencies, congressional members, and 

representatives from industry, academia, and foreign governments. The estimated cost of the 

event, including all food and beverages, is approximately $25 per person. Attendance at this 

event will allow NASA employees who are speaking at an event during the symposium to 

exchange information regarding various NASA programs. Due to space limitations for the 

event, guests are not invited.

5. On April 17, 2023, the Space Foundation, a nonprofit organization under 501(c)(3) of 

the Internal Revenue Code, will hold a New Generation Space Leaders Luncheon from 12:00 

p.m. to 1:30 p.m. in the Colorado Hall, at the Broadmoor Hotel. Approximately 300 people 

are expected to attend. This event provides an opportunity for informal discussion with 

people who have diverse views or interests and will include agency directors/managers from 

other federal agencies, congressional members, and representatives from industry. The 

estimated cost of the event, including all food and beverages, is approximately $78 per 

person. Attendance at this event will allow NASA employees to exchange information 

regarding various NASA programs. This event is open to young professionals 35 or younger.

6. On April 17, 2023, the Space Foundation, a nonprofit organization under 501(c)(3) of 

the Internal Revenue Code, will hold a New Generation Space Leaders: Networking

Reception from 4:30 p.m. to 5:30 p.m. at the Broadmoor Hotel. Approximately 300 people 

are expected to attend. This event provides an opportunity for informal discussion with 

people who have diverse views or interests and will include agency directors/managers from 

other federal agencies, congressional members, and representatives from industry. The 

estimated cost of the event, including all food and beverages, is approximately $25.00 per 

person. Attendance at this event will allow NASA employees to exchange information 

regarding various NASA programs. This event is open to young professionals 35 or younger 

and senior mentors.

7. On April 17, 2023, the Space Foundation, a nonprofit organization under 501(c)(3) of 

the Internal Revenue Code, will hold a Government Affairs Social from 4:45 p.m. to 6:00 
3

p.m. at the Broadmoor Hotel. Approximately 150 people are expected to attend. This event 

provides an opportunity for informal discussion with people who have diverse views or 

interests and will include agency directors/managers from other federal agencies, 

congressional members, and representatives from industry. The estimated cost of the event, 

including all food and beverages, is approximately $25.00 per person. Attendance at this 

event will allow NASA employees to exchange information regarding various NASA 

programs. Due to space limitations for the event, guests are not invited.

8. On April 17, 2023, the Space Foundation, a nonprofit organization under 501(c)(3) of 

the Internal Revenue Code, will hold the IAF: Bureau Welcome Toast from 5:00 p.m. to 5:45 

p.m. in the Summit Private Dining Room, at the Broadmoor Hotel. Approximately 18 people 

are invited to attend. This event provides an opportunity for informal discussion with people 

who have diverse views or interests and will include people from other federal agencies, 

congressional members, and representatives from industry, academia, media, and foreign 

governments. The estimated cost of the event, including all food and beverages, is 

approximately $24 per person. Attendance at this event will allow NASA employees to 

exchange information regarding various NASA programs. Due to space limitations for the 

event, guests are not invited.

9. On April 17, 2023, the Space Foundation, a nonprofit organization under 501(c)(3) of 

the Internal Revenue Code, will hold a Welcome Reception from 5:15 p.m. to 6:00 p.m. in

the International Center, at the Broadmoor Hotel. Approximately 500 people are expected to 

attend. This event provides an opportunity for informal discussion with people who have 

diverse views or interests and will include agency directors/managers from other federal 

agencies, congressional members, and representatives from industry. The estimated cost of 

the event, including all food and beverages, is approximately $16.00 per person. Attendance 

at this event will allow NASA employees to exchange information regarding various NASA

programs. 

10. On April 17, 2023, the Space Foundation, a nonprofit organization under 501(c)(3) of 

the Internal Revenue Code, will hold a Heads of Agency Reception from 7:45 p.m. to 9:15 

p.m. at the Broadmoor Hotel. Approximately 125 people are expected to attend. This event 

provides an opportunity for informal discussion with people who have diverse views or 

interests and will include agency directors/managers from other federal agencies, 

congressional members, and representatives from industry. The estimated cost of the event, 

including all food and beverages, is approximately $33 per person. Attendance at this event 

will allow NASA employees to exchange information regarding various NASA programs. 

Due to space limitations for the event, guests are not invited.

11. On April 17, 2023, the Space Foundation, a nonprofit organization under 501(c)(3) of 

the Internal Revenue Code, will hold a New Generation Space Leaders: Breakfast from 7:30 

p.m. to 8:30 p.m. in the Colorado Hall, at the Broadmoor Hotel. Approximately 200 people 

are expected to attend. This event provides an opportunity for informal discussion with 

people who have diverse views or interests and will include agency directors/managers from 

other federal agencies, congressional members, and representatives from industry. The 
4

estimated cost of the event, including all food and beverages, is approximately $69 per 

person. Attendance at this event will allow NASA employees to exchange information 

regarding various NASA programs. Due to space limitations for the event, guests are not 

invited.

12. On April 17, 2023, the Space Foundation, a nonprofit organization under 501(c)(3) of 

the Internal Revenue Code, will hold a Heads of Agency Reception from 7:45 p.m. to 9:15 

p.m. at the Broadmoor Hotel. Approximately 125 people are expected to attend. This event 

provides an opportunity for informal discussion with people who have diverse views or 

interests and will include agency directors/managers from other federal agencies, 

congressional members, and representatives from industry. The estimated cost of the event, 

including all food and beverages, is approximately $33 per person. Attendance at this event 

will allow NASA employees to exchange information regarding various NASA programs. 

Due to space limitations for the event, guests are not invited.

13. On April 17, 2023, the Space Foundation, a nonprofit organization under 501(c)(3) of 

the Internal Revenue Code, will hold an Opening Night Celebration - Maxar from 8:30 p.m. 

to 10:30 p.m. at the Lake Terrace Dining Room, Broadmoor Hotel. Approximately 500 

people are expected to attend. This event provides an opportunity for informal discussion 

with people who have diverse views or interests and will include agency directors/managers 

from other federal agencies, congressional members, and representatives from industry. The 

estimated cost of the event, including all food and beverages, is approximately $25 per 

person. Attendance at this event will allow NASA employees to exchange information 

regarding various NASA programs.

14. On April 17, 2023, the Voyager Space, Airbus Defense and Space, and U.S. Space & 

Defense will jointly hold a dinner at 9:00 p.m. in the Summit Dining Room, at the 

Broadmoor Hotel. Approximately 20 people are invited to attend. This event provides an 

opportunity for informal discussion with people who have diverse views or interests and will 

include people from other federal agencies, congressional members, and representatives from 

industry, academia, media, and foreign governments. The estimated cost of the event, 

including all food and beverages, is approximately $50 per person. Attendance at this event 

will allow NASA employees to exchange information regarding various NASA programs. 

Due to space limitations for the event, guests are not invited.

15. On April 18, 2023, the Voyager Space will hold a reception from 6:00 p.m. to 9:00 

p.m. at 21 2nd St., Colorado Springs, CO 80906. Approximately 120 people are invited to 

attend. This event provides an opportunity for informal discussion with people who have 

diverse views or interests and will include people from other federal agencies, congressional 

members, and representatives from industry, academia, media, and foreign governments. 

The estimated cost of the event, including all food and beverages, is approximately $35 per 

person. Attendance at this event will allow NASA employees to exchange information 

regarding various NASA programs. Due to space limitations for the event, guests are not 

invited.
5

16. On April 18, 2023, the Space Foundation, a nonprofit organization under 501(c)(3) of 

the Internal Revenue Code, will hold a Government Affairs Breakfast from 7:15 a.m. to 8:30

a.m. in the Broadmoor Hotel. Approximately 150 people are expected to attend. This event 

provides an opportunity for informal discussion with people who have diverse views or 

interests and will include people from other federal agencies, congressional members, and 

representatives from industry, academia, and foreign governments. The estimated cost of the 

event, including all food and beverages, is approximately $90 per person. Attendance at this 

event will allow NASA attendees to exchange information regarding various NASA 

programs. Due to space limitations for the event, guests are not invited.

17. On April 18, 2023, the Space Foundation, a nonprofit organization under 501(c)(3) of 

the Internal Revenue Code, will hold an Acquisition Luncheon from 12:15 p.m. to 1:45 p.m. 

in the Colorado Hall. Approximately 600 people are expected to attend. This event provides 

an opportunity for informal discussion with people who have diverse views or interests and 

will include people from other federal agencies, congressional members, and representatives 

from industry, academia, and foreign governments. The estimated cost of the event, 

including all food and beverages, is approximately $125 per person. Attendance at this event 

will allow NASA attendees to exchange information regarding various NASA programs. 

18. On April 18, 2023, the Space Foundation, a nonprofit organization under 501(c)(3) of 

the Internal Revenue Code, will hold a Senior Executives’ Forum Luncheon from 12:15 p.m. 

to 1:45 p.m. in the Broadmoor Hotel. Approximately 70 people are expected to attend. This 

event provides an opportunity for informal discussion with people who have diverse views or 

interests and will include people from other federal agencies, congressional members, and 

representatives from industry, academia, and foreign governments. The estimated cost of the 

event, including all food and beverages, is approximately $72 per person. Attendance at this 

event will allow NASA employees to exchange information regarding various NASA 

programs. Due to space limitations for the event, guests are not invited.

19. On April 18, 2023, the Space Foundation, a nonprofit organization under 501(c)(3) of 

the Internal Revenue Code, will hold a Salon Luncheon: Secure World Foundation & United 

Kingdom Space Agency from 12:15 p.m. to 1:45 p.m. in the Broadmoor Hotel. 

Approximately 100 people are invited to attend. This event provides an opportunity for 

informal discussion with people who have diverse views or interests and will include people 

from other federal agencies, congressional members, and representatives from industry, 

academia, media, and foreign governments. The estimated cost of the event, including all 

food and beverages, is approximately $65 per person. Attendance at this event will allow 

NASA employees to exchange information regarding various NASA programs. Due to space 

limitations for the event, guests are not invited.

20. On April 18, 2023, the Space Foundation, a nonprofit organization under 501(c)(3) of 

the Internal Revenue Code, will hold an International Military Leaders Reception from 5:00 

p.m. to 6:15 p.m. at the Broadmoor Hotel. Approximately 150 people are expected to

attend. This event provides an opportunity for informal discussion with people who have 

diverse views or interests and will include people from other federal agencies, congressional 

members, and representatives from industry, and foreign governments. The estimated cost of 

the event, including all food and beverages, is approximately $37 per person. Attendance at 
6

this event will allow NASA attendees to exchange information regarding various NASA 

programs. Due to space limitations for the event, guests are not invited. 

21. On April 18, 2023, the Space Foundation, a nonprofit organization under 501(c)(3) of 

the Internal Revenue Code, will hold a Corporate Member Appreciation Reception from 5:15

p.m. to 7:15 p.m. at the Broadmoor Hotel. Approximately 125 people are expected to 

attend. This event provides an opportunity for informal discussion with people who have 

diverse views or interests and will include people from other federal agencies, congressional 

members, and representatives from industry, and foreign governments. The estimated cost of 

the event, including all food and beverages, is approximately $40 per person. Attendance at 

this event will allow NASA attendees to exchange information regarding various NASA 

programs. Due to space limitations for the event, guests are not invited. 

22. On April 18, 2023, the International Institute of Space Law and Sherman & Howard 

LLC will hold a reception and dinner from 6:00 p.m. to 9:00 p.m. on the Garden of the Gods 

Resort & Club at Colorado Springs, Colorado. Approximately 35 people are expected to 

attend. This event provides an opportunity for informal discussion with people who have 

diverse views or interests and will include people from other federal agencies, representatives 

from foreign government, speakers from the Law Forum, and personnel from industry. The 

estimated cost of the event, including all food and beverages, is approximately $100 per 

person. Attendance at this event will allow NASA employees and a guest to exchange 

information regarding various NASA programs.

23. On April 18, 2023, Leidos will hold a reception from 7:15 p.m. to 9:15 p.m. in the 

Robert Trent Jones Room, Golf Club, at the Broadmoor Hotel. Approximately 250 people 

are expected to attend. This event provides an opportunity for informal discussion with 

people who have diverse views or interests and will include people from other federal 

agencies, congressional members, and representatives from industry, academia, and foreign 

governments. The estimated cost of the event, including all food and beverages, is 

approximately $50 per person. Attendance at this event will allow NASA employees and a 

guest (attending the symposium) to exchange information regarding various NASA 

programs. 

24. On April 18, 2023, the Space Foundation, a nonprofit organization under 501(c)(3) of 

the Internal Revenue Code, will hold a Corporate Partnership Dinner from 7:30 p.m. to 9:00

p.m. in the International Center at the Broadmoor Hotel. Approximately 1,000 people are 

invited to attend. This event provides an opportunity for informal discussion with people 

who have diverse views or interests and will include people from other federal agencies, 

congressional members, and representatives from industry, and foreign governments. The 

estimated cost of the event, including all food and beverages, is approximately $225 per 

person. Attendance at this event will allow NASA employees and a guest to exchange 

information regarding various NASA programs. 

25. On April 19, 2023, the Space Foundation will host a Satellite Forum Breakfast at 7:15 

a.m. to 8:30 a.m. in the Broadmoor Hotel. Approximately 400 people are expected to attend. 

This event provides an opportunity for informal discussion with people who have diverse 

views or interests and will include people from other federal agencies, congressional 
7

members, and representatives from industry, academia, media, and foreign governments. 

The estimated cost of the event, including all food and beverages, is approximately $90 per 

person. Attendance at this event will allow NASA employees and a guest to exchange 

information regarding various NASA program

26. On April 19, 2023, the Space Foundation, a nonprofit organization under 501(c)(3) of 

the Internal Revenue Code, will hold an astronaut reunion breakfast from 7:30 a.m. to 8:45 

a.m. in the Broadmoor Hotel. Approximately 30 people are expected to attend. This event 

provides an opportunity for informal discussion with people who have diverse views or 

interests and will include representatives from industry and members of the public. The 

estimated cost of the event, including all food and beverages, is approximately $46 per 

person. Attendance at this event will allow NASA employees to exchange information 

regarding the NASA astronaut program. Due to space limitations for the event, guests are 

not invited.

27. On April 19, 2023, the Space Foundation, a nonprofit organization under 501(c)(3) of 

the Internal Revenue Code, will hold an Exhibitor Breakfast from 7:30 a.m. to 9:00 a.m. in 

the Broadmoor Hotel. Approximately 200 people are expected to attend. This event 

provides an opportunity for informal discussion with people who have diverse views or 

interests and will include representatives from industry and members of the public. The 

estimated cost of the event, including all food and beverages, is approximately $69 per 

person. Attendance at this event will allow NASA employees to exchange information 

regarding the NASA astronaut program. Due to space limitations for the event, guests are 

not invited.

28. On April 19, 2023, the Aerospace Industries Association (AIA), a nonprofit 

organization under 501(c)(6) of the Internal Revenue Code, will hold a Space Policy 

Networking Lunch from 12:15 p.m. to 1:45 p.m. in the Robert Trent Jones Room at the 

Broadmoor Hotel. Approximately 125 people are expected to attend. This event provides an 

opportunity for informal discussion with people who have diverse views or interests and will 

include people from other federal agencies, congressional members, and representatives from 

industry, academia, and foreign governments. The estimated cost of the event, including all 

food and beverages, is approximately $40 per person. Attendance at this event will allow 

NASA employees and a guest to exchange information regarding various NASA programs. 

29. On April 19, 2023, the Space Foundation, a nonprofit organization under 501(c)(3) of 

the Internal Revenue Code, will hold a Space Warfighters Luncheon from 12:15 p.m. to 1:45 

p.m. in the Colorado Hall at the Broadmoor Hotel. Approximately 700 people are invited to 

attend. This event provides an opportunity for informal discussion with people who have 

diverse views or interests and will include people from other federal agencies, congressional 

members, and representatives from industry, academia, media, and foreign governments. 

The estimated cost of the event, including all food and beverages, is approximately $125 per 

person. Attendance at this event will allow NASA employees to exchange information 

regarding various NASA programs. 

30. On April 19, 2023, the Space Foundation, a nonprofit organization under 501(c)(3) of 

the Internal Revenue Code, will hold a Salon Luncheon: Deloitte (Groundbreakers in 
8

Aerospace) from 12:15 p.m. to 1:45 p.m. in the Broadmoor Hotel. Approximately 100

people are invited to attend. This event provides an opportunity for informal discussion with 

people who have diverse views or interests and will include people from other federal 

agencies, congressional members, and representatives from industry, academia, media, and

foreign governments. The estimated cost of the event, including all food and beverages, is 

approximately $85 per person. Attendance at this event will allow NASA employees to 

exchange information regarding various NASA programs. Due to space limitations for the 

event, guests are not invited.

31. On April 19, 2023, the Space Foundation, a nonprofit organization under 501(c)(3) of 

the Internal Revenue Code, will hold an International Space Collaboration Luncheon from 

12:15 p.m. to 1:45 p.m. in the Broadmoor Main: Ballroom. Approximately 200 people are 

invited to attend. This event provides an opportunity for informal discussion with people 

who have diverse views or interests and will include people from other federal agencies, 

congressional members, and representatives from industry, academia, media, and foreign 

governments. The estimated cost of the event, including all food and beverages, is 

approximately $125 per person. Attendance at this event will allow NASA employees to 

exchange information regarding various NASA programs. 

32. On April 19, 2023, the Space Foundation, a nonprofit organization under 501(c)(3) of 

the Internal Revenue Code, will hold a Swigert Society and Innovators Council Reception 

from 5:00 p.m. to 6:30 p.m. in the Broadmoor Hotel. Approximately 60 people are invited to 

attend. This event provides an opportunity for informal discussion with people who have 

diverse views or interests and will include people from other federal agencies, congressional 

members, and representatives from industry, academia, media, and foreign governments. 

The estimated cost of the event, including all food and beverages, is approximately $20 per 

person. Attendance at this event will allow NASA employees to exchange information 

regarding various NASA programs. Due to space limitations for the event, guests are not 

invited.

33. On April 19, 2023, the Blue Origin will hold a reception from 5:00 p.m. to 7:00 p.m. 

in the Everest Cottage. Approximately 200 people are invited to attend. This event provides 

for informal discussion with people who have diverse views or interests and will include 

people from other federal agencies, congressional members, and representatives from 

industry, academia, media, and foreign governments. The estimated cost of the event, 

including all food and beverages, is approximately $75 per person. Attendance at this event 

will allow NASA employees and a guest to exchange information regarding various NASA 

programs. Due to space limitations for the event, guests are not invited.

34. On April 19, 2023, L3Harris Technologies, Inc. will hold a reception from 5:30 p.m. 

to 7:00 p.m. in the Lake Terrace Dining Room at the Broadmoor Hotel. Approximately 400 

people are invited to attend. This event provides for informal discussion with people who 

have diverse views or interests and will include people from other federal agencies, 

congressional members, and representatives from industry, academia, media, and foreign 

governments. The estimated cost of the event, including all food and beverages, is 

approximately $18 per person. Attendance at this event will allow NASA employees and a 

guest to exchange information regarding various NASA programs.
9

35. On April 19, 2023, the ASRC Federal Holding Company, LLC will hold a 

Indoor/Outdoor Reception at 5:30 p.m. to 8:30 p.m. in the Bennett Cottage at the Broadmoor 

Hotel. Approximately 2,000 people are invited to attend. This event provides for informal 

discussion with people who have diverse views or interests and will include people from 

other federal agencies, congressional members, and representatives from industry, academia, 

media, and foreign governments. The estimated cost of the event, including all food and 

beverages, is approximately $28 per person. Attendance at this event will allow NASA 

employees and a guest to exchange information regarding various NASA programs.

36. On April 19, 2023, the Lockheed Martin Company will hold a Marsh Reception from 

7:00 p.m. to 10:00 p.m. in the Colorado Hall, at the Broadmoor Hotel. Approximately 875

people are invited to attend. This event provides for informal discussion with people who 

have diverse views or interests and will include people from other federal agencies, 

congressional members, and representatives from industry, academia, media, and foreign 

governments. The estimated cost of the event, including all food and beverages, is 

approximately $50 per person. Attendance at this event will allow NASA employees and a 

guest to exchange information regarding various NASA programs. 

37. On April 19, 2023, the Air and Space Force Association, a nonprofit organization 

under 501(c)(3) of the Internal Revenue Code, will hold a dinner/reception starting at 6:00 

p.m. in Broadmoor’s Fish House, in Colorado Springs. Approximately 25 people are expected to 

attend. This event provides an opportunity for informal discussion with people who have 

diverse views or interests and will include directors/managers from other federal agencies, 

congressional members, and representatives from industry, and foreign governments. The 

estimated cost of the event, including all food and beverages, is approximately $125 per 

person. Attendance at this event will allow NASA employees to exchange information 

regarding various NASA programs. Due to space limitations for the event, guests are not 

invited.

38. On April 19, 2023, the Boeing Company will hold a Casual Night Under the Stars 

event at 7:00 p.m. to 9:00 p.m. at the Broadmoor Estate House, Colorado Springs. 

Approximately 600 people are expected to attend. This event provides an opportunity for 

informal discussion with people who have diverse views or interests and will include people 

from other federal agencies, congressional members, and representatives from industry, 

academia, media, and foreign governments. The estimated cost of the event, including all 

food and beverages, is approximately $75 per person. Attendance at this event will allow 

NASA employees and a guest to exchange information regarding various NASA programs.

39. On April 20, 2023, the Space Foundation, a nonprofit organization under 501(c)(3) of 

the Internal Revenue Code, will hold a Women’s Global Gathering Luncheon from 12:15

p.m. to 1:45 p.m. in the Colorado Hall at the Broadmoor Hotel. Approximately 450 people 

are expected to attend. This event provides an opportunity for informal discussion with 

people who have diverse views or interests and will include people from other federal 

agencies, congressional members, and representatives from industry, academia, media, and 

foreign governments. The estimated cost of the event, including all food and beverages, is 

approximately $125 per person. Attendance at this event will allow NASA employees to 

exchange information regarding various NASA programs. 
10

40. On April 20, 2023, the Space Foundation, a nonprofit organization under 501(c)(3) of 

the Internal Revenue Code, will hold a Space Technology Hall of Fame Private Induction 

Ceremony from 4:00 p.m. to 5:30 p.m. at the Broadmoor Hotel. Approximately 50 people 

are invited to attend. This event provides an opportunity for informal discussion with people 

who have diverse views or interests and will include people from other federal agencies, 

congressional members, and representatives from industry, academia, media, and foreign 

governments. The estimated cost of the event, including all food and beverages, is 

approximately $20 per person. Attendance at this event will allow NASA employees and a 

guest to exchange information regarding various NASA programs. Due to space limitations 

for the event, guests are not invited. 

41. On April 20, 2023, the Space Foundation, a nonprofit organization under 501(c)(3) of 

the Internal Revenue Code, will hold a Space Technology Hall of Fame Dinner from 7:00

p.m. to 9:00 p.m. in the International Center at the Broadmoor Hotel. Approximately 700

people are invited to attend. This event provides an opportunity for informal discussion with 

people who have diverse views or interests and will include people from other federal 

agencies, congressional members, and representatives from industry, academia, media, and 

foreign governments. The estimated cost of the event, including all food and beverages, is 

approximately $225 per person. Attendance at this event will allow NASA employees and a 

guest to exchange information regarding various NASA programs.

42. On April 20, 2023, the Space Foundation, a nonprofit organization under 501(c)(3) of 

the Internal Revenue Code, will hold a Celebration of New Generation Space Leaders from 

9:00 p.m. to 12:00 a.m. at Colorado Hall at the Broadmoor Hotel. Approximately 350 people 

are invited to attend. This event provides an opportunity for informal discussion with people

who have diverse views or interests and will include people from other federal agencies, 

congressional members, and representatives from industry, academia, media, and foreign 

governments. The estimated cost of the event, including all food and beverages, is 

approximately $47 per person. Attendance at this event will allow NASA employees and a 

guest to exchange information regarding various NASA programs.

I find that these 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. Accordingly, NASA employees who do not have a significant role in a matter 

affecting the interests of the organization hosting the particular event as specified herein may 

accept an invitation for free attendance to that event, including NASA employees in noncareer positions who are required to sign the ethics pledge under Executive Order 13989,

except as noted below. 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.3

2 When the gift of free attendance is from a foreign government, as in the case of the New Zealand, French, 

Japan and Canadian Government Receptions, acceptance of the gift is authorized by the Foreign Gifts and 

Decorations Act. 3 In addition, employees may accept free attendance at events at which they are speaking pursuant to 5 C.F.R. 

2635.203(b)(8)(i).
11

However, NASA employees in non-career positions who are required to sign the ethics 

pledge under Executive Order 13989 may only attend the reception events held by Collins 

Aerospace (April 16), ULA (April 16), Voyage Space & Airbus (April 17), Voyage Space 

(April 18), Leidos (April 18), Blue Origin (April 19), AIA (April 19), L3Harris Reception 

(April 19), ASRC Federal Fireside Reception (April 19), Boeing Casual Night Under the 

Stars Night (April 19), and Lockheed Martin Marsh Reception (April 19), if they reimburse 

the sponsor the fair market value of the event as these events are by invitation only and not 

covered by the registration fee and/or another exception. Additionally, a guest of NASA 

employees may attend the events to which they have been invited, e.g., the opening and 

closing ceremonies (April 17 and April 20), Corporate Partnership Dinner (April 18),

Astronaut Reunion (April 19), Satellite Forum Breakfast (April 19), Australian Reception 

(April 6), ASRC Federal Reception (April 19), and the Space Technology Hall of Fame 

Dinner (April 20). Also, NASA employees who have a significant role in any pending 

matter affecting the interests of any of the hosts of any event they wish to attend, 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.

4

 

This widely attended gathering determination does not cover the receptions in hospitality 

suites that may occur during the 38th Space Symposium. These suites will be hosted by 

corporate sponsors. Most NASA employees who are invited may receive refreshments 

provided in these suites under the exception to the gift rules that allows acceptance of gifts 

(including refreshments and tangible gift items) with an aggregate value of $20 or less per 

event. However, non-career NASA employees subject to the Ethics Pledge required by 

Executive Order 13989 must provide reimbursement for the fair market value of any 

refreshments they or their guests consume in the hospitality suites. We understand that honor 

baskets to do so will be provided. 

Attendees are also reminded of the $20 gift exception at 5 C.F.R. § 2635.204(a), at 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). 

If employees have any questions on any individual event listed, please contact your local 

NASA ethics official. Attendees are reminded to exercise any COVID-19 precautions 

appropriate to their individual situation.

Adam F. Greenstone

4 NASA employees who are attending the 38th Space Symposium pursuant to a registration fee NASA has paid 

for or through sponsored travel approval pursuant to 31 U.S.C. §1353 may attend any of the events hosted by 

the Space Foundation as provided by those approvals.