National Aeronautics and 

Space Administration

Mary W. Jackson Building NASA Headquarters

Washington, DC 20546-0001

March 6, 2024

Reply to Attn of: General Law Practice Group

TO: Distribution

FROM: Agency Counsel for Ethics

SUBJECT: Determination Regarding Attendance by NASA employees at the 2024 

Exploring Space Lecture Series on March 6, April 24, May 22, and June 5, 

2024

On March 6, April 24, May 22, and June 5, 2024, the National Air and Space Museum, a 

nonprofit organization under 501(c)(3) of the Internal Revenue Code, will host 

cocktails/dinner starting at 6:00 pm, at the National Air and Space Museum’s National Mall 

Building, in Washington, D.C.

1

 The Exploring Space Lecture Series is an annual series of 

four public programs presented by the National Air and Space Museum. The four lectures in 

this year’s series will spotlight the sample return missions that have helped us better 

understand the origin and evolution of the Earth and other planets. Prior to each program is a 

private dinner that includes the speaker, NASM leadership, NASM guests, and sponsor 

representatives. 

Approximately 10-12 people will attend each dinner. Attendees will have a diversity of views 

or interests and will include representatives from the legislative branch, state and local 

government officials, representatives from industry, employees of Federal agencies, and 

members from the foreign government space agencies. The estimated cost of the event, 

including all food and beverages, is $145 per person. The National Air and Space Museum is 

in control of organizing and planning of this event (Aerojet Rocketdyne and United Launch 

Alliance are only financial sponsors). Attendance at this event will allow NASA attendees to 

exchange information regarding various NASA programs. I find that the event meets 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 the 

event 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 the ethics pledge under 

Executive Order 13989, who do not have a significant role in a matter affecting the interests 

of the sponsor may accept an invitation for free attendance to the event. In those 

circumstances, I find that the Agency’s interest in attendance outweighs any concern that the 

1 To the extend that the event is supported by the National Air and Space Museum as a U.S. Government 

entity, as distinguished from the Smithsonian Trust, attendance for invited NASA employees is also authorized. 
2

individual may be, or may appear to be, improperly influenced in the performance of their 

duties.

However, NASA employees who have a significant role in any pending matter affecting the 

interests of the National Air and Space Museum, 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. 

Adam F. Greenstone