National Aeronautics and Space Administration

Goddard Space Flight Center

Greenbelt, MD 20771

July 24, 2023

Reply to Attn of: 140

TO: Distribution

FROM: 140/Chief Counsel

SUBJECT: Widely Attended Gathering Determination Regarding Attendance at the 

Northrop Grumman NG-19 Commercial Resupply Service (CRS) Mission 

Antares Launch Activities and Reception, to Take Place No Earlier than July 31, 

2023

Northrop Grumman is scheduled to launch the NG-19 CRS Mission on an Antares launch 

vehicle at a date no earlier than August 1, 2023. In connection with this event, Northrop 

Grumman is hosting an evening reception the day before the planned launch and will be 

providing mementos to the guests and light snacks the day of the launch at the Launch 

Viewing Site. Transportation to the site will be provided by NASA. The reception is being 

held at the NASA Wallops Flight Facility (WFF) in conjunction with NASA's guest 

operations. 

Approximately 500 guests have been invited to the event. Attendees will have a diversity of 

views or interests and 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 estimated cost 

per person of the reception is $50, and the estimated cost per person of snacks provided at the 

launch site is $9; thus, the estimated cost of attendance per person for the entire event is 

approximately $59. Attendance at the reception will allow NASA employees to exchange 

information regarding various NASA and industry programs and space launch criteria. I find 

that the event meets the requirements of a “widely attended gathering” as defined in 5 CFR 

2635.204(g)(2). 

Additionally, guests at this reception will be provided with launch gift mementos worth 

approximately $16.86. NASA employees may accept this memento package pursuant to 5 

CFR 2635.204(a), as it is an unsolicited gift from a prohibited source worth $20 or less. 

However, the total value of gifts accepted from Northrop Grumman in one calendar year 

cannot exceed $50. Thus, if an employee has received gifts worth approximately $33 or more 

from Northrop Grumman in 2023, they should decline this memento package or pay the 

market value for it. 

 
2

I further determine that there is an Agency interest in having NASA personnel attend the 

event, as it will provide an opportunity for the invited guests to exchange views about NASA 

and industry programs, policies, and operations, including future planned launches and 

missions involving space launch vehicles. I therefore conclude that NASA's interest in its 

employees attending this event outweighs any concern that free attendance may, or may 

appear to, improperly influence NASA employees in the performance of their official duties. 

Accordingly, NASA employees who do not have a significant role in a matter affecting the 

interests of Northrop Grumman, including employees in non-career positions for which the 

Executive Order 13770 requires signing an ethics pledge, may accept an invitation for free 

attendance to the event for themselves and their spouses or guests. Employees should attend 

this event on their own time. 

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

interests of Northrop Grumman, such as procurement duties, program management, or 

negotiating or administering a Space Act Agreement, should seek an individual determination 

regarding participation in this even from their local ethics counselor.

Thomas Browder

Thomas Browder Date: 2023.07.24 

13:47:55 -04'00'