National Aeronautics and

Space Administration

Mary W. Jackson Building NASA Headquarters

Washington, DC 20546-0001

 May 16, 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 Rocket Lab, 

TROPICS Launch Event on May 18, 2023 

On May 18, 2023, Rocket Lab will hold an event at Takoda in the Navy Yard, 1299 First 

St., SE, Washington, DC, from 5:30 p.m. to 7:30 p.m. This event is to celebrate the success 

of Rocket Lab’s first NASA TROPICS launch and to preview the second launch. Rocket 

Lab is in control of the planning, organizing, and issuing invitations for this event. 

Approximately 500 people are expected to attend the event. Attendees will have a diversity 

of views or interests and will include personnel from congressional staffers, executive 

branch officials, state and local officials, academia, industry representatives, and 

administration personnel. The estimated cost of the event, including all food and 

beverages, is approximately $20 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)(2). 

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

event because it will provide an opportunity for the invited persons to exchange ideas and 

views pertaining to NASA’s policies, programs and operations. NASA employees who do 

not have a significant role in a matter affecting the interests of Rocket Lab may accept an 

invitation for free attendance for themselves and a guest to attend 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 the reception if they reimburse the 

sponsor the fair market value of the event. An honor basket will be provided. 

In addition, NASA employees who have a significant role in any pending matter affecting 

the interests of the sponsor, such as procurement duties, program management, or 
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negotiating or administering a Space Act Agreement, should seek a separate determination 

from their local ethics counselor 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 Rocket Lab will be handing out t-shirts 

valued at $7.50. NASA employees not serving in non-career positions subject to the ethics 

pledge and their guests may accept a accept a t-shirt under the $20 rule if the employee will 

not have received more than $50 in gifts from Rocket Lab in 2023. NASA employees 

subject to the ethics pledge and their guests may only accept a t-shirt if the employee

reimburses Rocket Lab. All NASA attendees and their guests may accept a mission patch

distributed at the event. Attendees are reminded to exercise any COVID-19 precautions 

appropriate to their individual situation.

Adam F. Greenstone