National Aeronautics and

Space Administration

Mary W. Jackson NASA Headquarters

Washington, DC 20546-0001

March 24, 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 Coalition for 

Deep Space Exploration’s Standing Reception for SLS, Orion, EGS and Gateway 

Suppliers Conference on or around March 26, 2023. 

On or about March 26, 2023, the Coalition for Deep Space Exploration (Coalition), a nonprofit 

organization under 501(c)(6) of the Internal Revenue Code, will host a reception at the 

Junction Bistro, Bar, and Bakery, on Capitol Hill, Washington, DC, from 6:00-8:00 pm. The 

Coalition is registered to and does engage in lobbying activities. The event is to provide a 

venue for informal discussion for representatives from industry, the legislative branch, and 

others interested in deep space human exploration and space science. The Coalition is in 

control of planning and organizing the event and issuing invitations. 

Approximately 250 people are expected to attend the event. Attendees will have a diversity of 

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

the legislative branch, industry, and scientific organizations. The estimated cost of the event, 

including all food and beverages, is approximately $53 per person. 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). 

NASA employees, 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 individual may be, 

or may appear to be, improperly influenced in the performance of their duties. However, 

NASA employees in non-career positions who are required to sign the ethics pledge under 

Executive Order 13989, may only attend 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 Coalition, such as procurement duties, program management, or negotiating or 

administering a Space Act Agreement, should seek a separate determination from their local 

NASA ethics office as to whether they may accept the invitation. 

You are reminded of the $20 gift exception at 5 C.F.R. § 2635.204(a), which provides that you 

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 the Coalition will be distributing a CDSE pins 

and Artemis baseball caps which NASA attendees, including NASA employees in non-career 
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positions who have signed the ethics pledge, may accept. An honor basket will be provided to 

reimburse for other gifts. 

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

situation.

Adam F. Greenstone