National Aeronautics and Space Administration

John F. Kennedy Space Center

Kennedy Space Center, FL 32899

Reply to Attn of: CC

TO: Distribution

FROM: CC/Acting Chief Counsel

SUBJECT: Determination Regarding Attendance by NASA Employees for the NG-20 

Commercial Resupply Service (CRS) Mission Viewing and Reception at Kennedy 

Space Center, Florida, January 29, 2024

Northrop Grumman Corporation will host a Launch Viewing and Reception of the NG-20 CRS 

Mission no earlier than Monday, January 29, 2024, at Kennedy Space Center and Cocoa Beach, 

Florida, from 6:00 p.m. to 8:00 p.m. Approximately 500 guests are expected to attend the event, 

serving food and refreshments. This event is by invitation only. Guests include Members of 

Congress, Congressional staff, NASA personnel, state and local officials, academia, U.S. and 

International industry representatives, and personnel from other federal agencies involved in 

space launch activities. The value of the refreshments is approximately $115 per person. 

 

In accordance with 5 C.F.R. § 2635.204(g), Gifts of Free Attendance at Widely Attended 

Gatherings, I find this event meets the requirements of a widely attended gathering, and I further 

determine that there is an Agency interest in having NASA personnel attend this event because 

their participation will further Agency programs and operations. Specifically, this event allows 

NASA employees to honor and show support for employees who have participated in the launch, 

and to recognize important contributions to U.S. aerospace efforts. This event also provides a 

forum for the attendees to disseminate information on NASA's ongoing activities and to discuss 

matters of interest to NASA with a diverse group of fellow attendees. Because of these benefits 

to NASA and having considered the factors enumerated in 5 CFR § 2635.204(g)(4), I also find 

that the Agency's interest in the invited NASA employees' attendance outweighs the concern that 

such employees may be, or may appear to be, improperly influenced in the performance of 

official duties. 

 

Accordingly, NASA employees whose duties do not substantially affect the sponsor may accept 

an invitation for complimentary attendance at these events. NASA employees whose duties may 

substantially affect the sponsor, such as by way of procurement duties or administration of Space 

Act agreements, should seek an individual determination regarding participation in this event 

from the KSC Office of the General Counsel. However, NASA employees in non-career 

 

 
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positions who are required to sign the ethics pledge under Executive Order 13989 may only 

attend the reception if they reimburse the sponsor the fair market value of the event. An honor 

basket will be provided. 

 

You 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 for each occasion (and no more than 

$50 from one source in a calendar year). We understand that Northrop Grumman will be offering 

a gift bag valued at approximately $17. NASA employees in non-career positions who have 

signed the ethics pledge may only accept a gift item if they reimburse the sponsor.

Thomas M. Browder III 

Agency Designee

Thomas Browder Date: 2024.01.23 

16:01:20 -05'00'