NATIONAL AERONAUTICS AND SPACE 

ADMINISTRATION

Mary W. Jackson Building NASA Headquarters

Washington, DC 20546-0001

May 2, 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 

H2M Summit 2023 and surrounding events on May 16-18, 2023 

On May 16-18, 2023, the Explore Mars, Inc., a nonprofit organization under 501(c)(3) of 

the Internal Revenue Code, will host the Human to Mars Summit 2023 at the National 

Academy of Sciences Building in Washington, DC, from 8 a.m. to 6 p.m. Explore Mars is

in control of the plans and invitations for the Summit program events unless otherwise 

indicated. The purpose of the event is to bring experts from around the world together to 

provide a forum for discussions on the technical, scientific, and policy challenges of 

sending humans to Mars in the upcoming decades. Attendees will include representatives 

from the legislative branch, industry, government agencies, media, entertainment 

community, non-profit organizations, STEM educators, and academia. An award will be 

given to the Technical Director, Wade Holler, Explore Mars.

Approximately 400 – 500 people are expected to attend the event. The program will 

include three breakfasts, three coffee break snacks, one lunch, and one reception. 

May 16th: Breakfast estimated cost of the breakfast $15.00 per person each day. Coffee 

and snacks estimated cost of the coffee break and snacks $15.00 per person each day. The 

program will include a light reception (paid separately, not included with registration) 

estimated cost is $45 per person. 

May 17th: Breakfast estimated cost of the breakfast $15.00 per person each day. Coffee 

and snacks estimated cost of the coffee break and snacks $15.00 per person each day. The 

program will include a lunch (paid separately, not included with registration) estimated cost 

is $65 per person. 

May 18th: Breakfast estimated cost of the breakfast $15.00 per person each day. Coffee 

and snacks estimated cost of the coffee break and snacks $15.00 per person each day. 
2

Attendance at these events will allow NASA attendees to exchange information regarding 

various NASA program.

I find that these events meet the requirements of a “widely attended gathering” as defined 

in 5 C.F.R. § 2635.204(g). I further determine that there is an Agency interest in having 

NASA personnel attend these events because it will provide an opportunity for the invited 

persons to exchange ideas and views pertaining to NASA’s policies, programs and 

operations. Accordingly, NASA employees—including non-career employees subject to

Executive Order 13989—who do not have a significant role in a matter affecting the 

interests of Explore Mars may accept an invitation for free attendance to the events where 

complimentary invitations have been issued. 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 who have a significant role in any pending matter affecting 

the interests of Explore Mars, such as procurement duties, program management, or 

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 of free 

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

appropriate to their individual situation.

Adam F. Greenstone