National Aeronautics and Space Administration 

Reply to Attn of:

John F. Kennedy Space Center

Kennedy Space Center, FL 32899

CC

March 9, 2023

TO: All NASA Employees

FROM: CC/Chief Counsel

SUBJECT: Determination Regarding Attendance by NASA Employees at the National Space Club 

Florida Committee 2023 Debus Award Banquet, March 25, 2023

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

501(c)(3) of the Internal Revenue Code, will host the Debus Award Banquet on Saturday, March 25, 

2023, at the Kennedy Space Center Visitor Complex Debus Center. Approximately 230 guests are 

expected to attend the dinner featuring both prior and current winners, and members of the public. 

Guests include corporate executives, industry leaders, representatives of aerospace contractors and 

other organizations, elected officials, and military leaders. The value of the dinner is approximately 

$120 per person. Agency invitees have been invited to bring a guest with them to the event with 

complimentary admission. 

 

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 a program recognizing 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 Kennedy Space Center (KSC) employees whose duties do not substantially 

affect the sponsor, including NASA employees in non-career positions who are required to sign the 

ethics pledge under Executive Order 13989, 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. 

 

 

 
2

Although attendance at this event constitutes an exception to the general prohibition on acceptance of 

gifts, attendees are also 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 per occasion and no more than $50 from 

one prohibited source in a calendar year.

Daniel P. Shaver 

Agency Designee 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

DANIEL SHAVER

Digitally signed by DANIEL 

SHAVER

Date: 2023.03.09 14:49:05 -05'00'