National Aeronautics and Space Administration

John F. Kennedy Space Center

Kennedy Space Center, FL 32899

October 4, 2023

Reply to Attn of: CC

TO: All NASA Civil Servants

FROM: CC/Chief Counsel

SUBJECT: National Space Club Florida Committee Celebrate Space Awards Banquet, 

October 13, 2023

National Space Club Florida Committee (NSCFL), a nonprofit organization under section 

501(c)(3) of the Internal Revenue Code, will host a Celebrate Space Awards Banquet event at 

the Radisson Resort at the Port - Convention Center on Friday, October 13, 2023. This event 

is hosted by NSCFL, which helps further its mission to provide information on space 

activities, promote space leadership, stimulate advancement of space applications, sponsor 

educational activities, and provide recognition for contributions to advancements in aerospace 

science, operations, research, and education. Approximately 250 guests, including all 

aerospace companies, elected officials, industry leaders, Air Force, and NASA employees. 

Tickets to the banquet, valued at $70 for each attendee, are being offered to NASA KSC 

personnel at no cost. NASA invitees have been invited to bring a guest. 

 

I find that the Celebrate Space Banquet meets the requirements of a widely attended 

gathering, as defined in 5 C.F.R. § 2635.204(g). Consequently, I conclude that NASA's 

interest in its employees and a guest attending this event outweighs any concern that such free 

attendance may, or may appear to, improperly influence any NASA personnel in the 

performance of their official duties. 

 

Attendance at the Celebrate Space Banquet event will allow NASA representatives to 

establish an Agency presence at an event recognizing achievements by people in aerospace 

science and research careers. Attendance will also allow NASA personnel an opportunity to 

discuss matters of interest with a diverse group of other guests. Through attendance, 

employees will be able to disseminate information on NASA's ongoing activities and to 

demonstrate support for the contributions of the American space industry. 

 

Accordingly, NASA employees whose duties do not substantially affect any of the sponsors, 

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

under Executive Order 13770, may accept an invitation for complimentary attendance at this 
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event. NASA employees whose duties may substantially affect any of the sponsors, 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 Office of the General 

Counsel. 

 

In addition, some NASA contractors may be providing sponsorship for this event and 

purchasing tables at which NSCFL may seat other attendees. To avoid the appearance of a 

conflict of interest, NASA employees who attend the event should avoid sitting at a table 

sponsored by a contractor with whom they are closely and currently involved or can 

reasonably expect to be involved within the next few months, (e.g., by way of source 

selection, contract administration, or partnership agreement duties).

Daniel P. Shaver 

Agency Designee 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

DANIEL SHAVER

Digitally signed by DANIEL 

SHAVER

Date: 2023.10.04 12:22:23 -04'00'