National Aeronautics and

Space Administration

George C. Marshall Space Flight Center

Marshall Space Flight Center, AL 35812

October 23, 2023 

Reply to Attn of: LS01 (AMM) 

MEMORANDUM FOR RECORD

FROM: Pamela A. Bourque/LS01

SUBJECT: Approval for NASA Employees to Attend the 

Annual Dr. Wernher von Braun Memorial Dinner 

In accordance with 5 C.F.R. § 2635.204(g)(2) and (3), I make the following determination: 

Several NASA employees have been invited to attend the Dr. Wernher von Braun Memorial 

Dinner. This Dinner is sponsored by The National Space Club. It is scheduled for October 

25, 2023, at the Von Braun Center. The evening begins with a reception at 5:30 p.m. and 

dinner at 7:00 p.m. 

The National Space Club (NSC) was founded on October 4, 1957, to stimulate the exchange 

of ideas and information about rocketry and astronautics, and to promote recognition of U.S. 

achievements in space. The NSC is a non-profit organization under Section 501(c)(3) of the 

IRS code and does not employee lobbyists. The NSC has both individual and corporate 

members. 

This event will be a widely-attended gathering of NSC members, NASA and military 

employees, aerospace and defense industry contractors, federal, state and local government 

officials and staff, academia, as well as other community leaders. The event is valued at 

$200 per person and approximately 1200 people are expected to attend. I find that the event 

meets the requirements of a “widely attended gathering” as defined in 5 C.F.R. § 

2635.204(g)(2). A space themed novelty gift valued at $15 will also be provided to each 

guest. 

I have determined that free attendance of NASA employees at the event is in the interest of 

the agency because it will further agency programs and operations. Their attendance at the 

event will help to raise NASA’s profile with state and local business and governmental 

leaders, will contribute to community relations, and will support NASA’s statutory mandate 

to disseminate information about its programs. 

Given the purpose of the event, NASA’s interest in it, the broad attendance anticipated, and 

the reasonable market value of the event, I have determined that the value to the agency in 

having these employees attend this event outweighs any concern that free attendance may or 

may appear to improperly influence them in the performance of their duties. Accordingly, 
these NASA employees may accept free attendance to the event. They may also accept 

invitations for an accompanying spouse or guest. The employees can also accept the space 

themed gift item valued at $15. 

NASA employees whose duties may substantially affect the National Space Club are not 

covered in this determination and should seek a specific determination from this office 

pursuant to 5 CFR § 2635.204(g)(3)(i) regarding their participation in this event. 

Note that NASA employees supporting active procurements should use care to avoid sitting 

at corporate tables of entities listed as interested parties in those procurements.

Questions about this determination may be addressed to Annette Metcalf Coffel at 

256-544-0025. 

Pamela A. Bourque 

Acting Chief Counsel