DRAFT: Open letter to NASA | Response to final PEIS | Fails NEPA requirements | main points in open letter in more depth | Finding an inspiring future | executive summary of preprint | Low risk like house fires and smoke detectors | About me | DRAFT: Endorsements by experts | Why this needs an open letter with endorsements | DRAFT: Call to NASA to defer or withdraw PEIS| Letters | BOOK: Preprint to submit to academic publishers

Author: Robert Walker, contact email robert@robertinventor.com


NASA's current Programmatic Environmental Impact Statement is not valid under NEPA
- fails scientific integrity
- disciplines of preparers doesn't match the task
- doesn't mention consensus opposing view that the Mars meteorite argument and the other three main arguments are invalid
- doesn't mention consensus majority view that potential low risk worst case effects are global impacts on public health and environment
- narrow prescreening that omits alernatives if they fail to meet all the requiements of the mission plans

[See also Peer review paper]

[old pages: Fails NEPA requirements | NASA's legal requirements under NEPA]

Dear NASA.

I feel it's essential for NASA to maintain integrity, credibility, and to comply with NEPA requirements. I am sure Carl Sagan would have said the same if he was alive, he is one of my heroes. He cared deeply about scientific integrity and also cared deeply about biosafety, Earth's biosphere and its inhabitants.

I find many major issues with your EIS. My background is I was just finishing what was going to be my first paper on astrobiology, on planetary protection for NASA's very mission at the time that the Environmental Impact Statement process started. See my brief bio: About me. I commented on both rounds of public comments raising major issues which you have done nothing about. This means I have legal standing under NEPA and NASA are legally required to respond to the comments I made.

Most people care about human health and Earth's biosphere far more than robotic or human missions. But it's not either / or. We can do this mission safely. Indeed I have a solution too, which achieves far more science return and keeps Earth 100% safe (no appreciable risk) and plays to your strengths.

However, I don't see a solution yet in this PEIS which fails many of the most central requirements of NEPA. It is not ready to be finalized. I hope you'll agree after you read what I say that if you have finalized it you should reverse that decision.

You ae required under NEPA to ensure scientific integrity.

"Agencies shall ensure the professional integrity, including scientific integrity, of the discussions and analyses in environmental documents"
§ 1502.23
Here is a simple and clear failing. You depend on the Mars meteorite argument but it is rebutted by its main cite.

NASA:

First, potential Mars microbes would be expected to survive ejection forces and pressure (National Academies of Sciences, Engineering, and Medicine and the European Science Foundation 2019) [CITE REBUTS SENTENCE],

(NASA, 2023, Mars Sample Return FINAL PEIS 3–3),

This is your cite

National Academy of Sciences, 2019 (NASA's cite)

The microbes may NOT be able to survive impact ejection and transport through space.”

(SSB, 2019, Planetary protection classification of sample return missions from the Martian moons : 45)

This also fails another NEPA requirement to identify opposing views:

At appropriate points in the final statement, the agency shall discuss any responsible opposing view that was not adequately discussed in the draft statement and shall indicate the agency's response to the issues raised.

§ 1502.9

The PEIS doesn't mention the opposing view that the Mars meteorite argument is invalid in the very cites you use. The PEIS presents the Mars meteorite argument as a scientific consensus. The consensus is the other way around.

I'm not talking about gray area violations but clear and direct violations of NEPA rules.

This is the most important sentence in the EIS for you conclusion that environmental effects would not be significant.

We conclude also from this that nobody in your team is familiar enough with the planetary protection literature to know that the Mars meteorite argument you rely on was rebutted over 20 years ago, and nobody in your team had enough interest in the topic to read your most important cite carefully as far as page 5.

That is another NEPA failing

The disciplines of the preparers shall be appropriate to the scope and issues identified in the scoping process

§ 1507.2

For an Environmental Impact Statement for samples returned from Mars one thing we can be sure is a requirement is that the preparers need to be familiar with the literatuer on a Mars sample return mission. You didn't ensure this.

This is how John Rummel, NASA’s first planetary protection officer, put it in 2002:

“Broad acceptance at both lay public and scientific levels is essential to the overall success of this research effort.”

(A draft test protocol for detecting possible biohazards in Martian samples returned to Earth: 99)

He summarizes a point there that is stressed in all the major Mars sample return studies. That broad acceptance is as essential for the success of this mission as getting the calculations right about the amount of rocket fuel you need to launch the samples into orbit from the Mars surface.

It plays to your strengths as an organization and is a way to keep Earth 100% safe (no appreciable risk) with far better science return.

 

I also address the important matter of finding out if what we have on Mars is safe for humans or not.

 

I base this on the NEPA rules themselves what they require. These rules are there for a reason. Here are some of the central requirements under NEPA rules that your EIS fails. I will go into details in a moment but to give a summary.

This is the context for my analysis which finds very major issues with your PEIS.

 

The PEIS never mentions the consensus in all the main peer reviewed studies of a Mars sample return.

It never identifies the major point of view that there is a likely low risk of large-scale harm to the environment and to human health from unsterilized samples from Mars.

This is a NEPA requirement.

At appropriate points in the draft statement, the agency shall discuss all major points of view on the environmental impacts of the alternatives including the proposed action.

§ 1502.9

This is not just a major view, it is a consensus in all the major peer reviewed studies of a Mars sample return.

The European Space Foundation in 2012 said the samples should be contained as if they were risk group 4 (high risk of individual and community spread) until they are better understood

While, based on assumptions, some aspects of the release of unsterilised Mars material can be framed in some way, with such a level of uncertainty, unknown (and therefore unexpected) consequences driven by unknown mechanisms are conceivable and by definition are hardly manageable and predictable.

In this context, confinement of the sample appears to be the best prevention method. This principle is also applied when an unknown pathogen with a high case fatality rate is isolated: it is assimilated to Risk Group 4 and contained in laboratories with the highest level of confinement until further knowledge about the pathogen allows it to be down graded to a lower risk group.

Following the same principle, a priori assignment of a Mars sample to Risk Group 4 appears to be the best measure.

.(Amman et al., 2012, Mars Sample Return backward contamination–Strategic advice and requirements : 24)

NASA's second planetary protection officer Cassie Conley similarly said

“that means we are going to contain the samples as if they were the most hazardous Earth organisms that we know about, Ebola virus.”
at 1:02 into this official NASA video

On environmental effects, the ESF report concurred with earlier reports that the risk appears to be low but is not demonstrably zero.

The Study Group also concurs with another conclusion from the NRC reports (1997, 2009) that the potential for large-scale effects on the Earth’s biosphere by a returned Mars life form appears to be low, but is not demonstrably zero.

(Mars Sample Return backward contamination–Strategic advice and requirements : 20)

There is no mention anywhere in the PEIS of the possibility of a risk of large scale harm to human health or large scale changes to Earth's biosphere.

In this way you reduce the Affected location from Global, to the Utah test and training ground where samples are returned from Mars, based on reasoning only found within the PEIS itself. And never mention the majority view that the worst case is global.

That by itself surely makes this invalid under NEPA.

In the peer reviewed literature describes the Sample Receiving Facility as a major and very complex part of a sample return mission. It takes up an eighth of the 2009 National Academy of Sciences study, over 10 out of 80 pages (SSB, 2009, Assessment of planetary protection requirements for Mars sample return missions : chapter 7 ). It is the main focus of the 2012 European Space Foundation study (Amman et al., 2012, Mars Sample Return backward contamination–Strategic advice and requirements : 24).

  1. One estimate for the timeline to build the facility is 11 years with an extra two years to train technicians (Uhran et al., 2019, Updating Planetary Protection Considerations and Policies for Mars Sample Return)
  2. The 2010 decadal review estimated the cost of the Mars sample receiving facility as $471 million in 2015 dollars (Mattingly , 2010, Mission Concept Study, Planetary Science Decadal Survey, MSR Orbiter Mission (Including Mars Returned Sample Handling)) or $659 million dollars today. Others estimate over half a billion dollars in 2015 dollars (The Plan to Bring Mars Down to Earth).
     
  3. The main designs looked at use a BSL-4 but with the challenge that the samples need to be kept free of terrestrial contamination requiring a clean room inside a BSL-4, a BSL-4 inside a clean room or a novel double wall construction, all of which are new technology (Carrier et al., 2019, Science-Driven Contamination Control Issues Associated with the Receiving and Initial Processing of the MSR Samples : Figure 4).
  4. However, the European Space Foundation study set a requirement to contain 100% of all particles of 0.05 microns and upwards.

    "The release of a single unsterilized particle larger than 0.05 μm is not acceptable under any circumstances"
    (Ammann et al., 2012, Mars Sample Return backward contamination–Strategic advice and requirements : 48).


    A BSL-4 can't achieve this using HEPA filters. The Euro-CARES design uses an ULPA filter but this is not able to achieve 100% containment at any size. Due to an unfortunate typo it looks at designs that can achieve 1 in a million containment at 0.1 microns and upwards instead of 100% containment at 0.05 microns upward and 1 in a million chance of a single particle released in the lifetime of the facility from 0.01 microns upwards (Hutzler et al., 2017, EURO-CARES Extraterrestrial Sample Curation Facility: Architecture as an enabler of science : 5)

The PEIS itself is not peer reviewed. NASA themselves confirm this as is also clear from many basic failings of scientific integrity.

NEPA does not require a “peer” review prior to release. The purpose of releasing the Draft PEIS is to allow the public, agencies, and other interested parties to review the document and provide substantive comments on the alternatives and/or analyses presented
(NASA, 2023, Mars Sample Return FINAL EIS :B-71)

NASA uses their own reasoning in the PEIS to conclude that environmental impacts would not be significant.

The relatively low probability of an inadvertent reentry combined with the assessment that samples are unlikely to pose a risk of significant ecological impact or other significant harmful effects support the judgement that the potential environmental impacts would not be significant.

(NASA, 2023, Mars Sample Return FINAL PEIS :3-16)

NASA themselves confirm this is a conclusion they reach from the arguments within the Environmental Impact Statement itself:

The sentence cited in this comment ... is a NASA conclusion based on the analyses presented in the PEIS

—the reference is the PEIS itself. Based on the credible scientific evidence cited in the PEIS (samples are unlikely to pose a risk of significant ecological impact), it is reasonable to conclude that there would be no significant impacts from the Proposed Action.

The term “unlikely” accounts for the fact that the risk is not zero.
(NASA, 2023, MSR FINAL EIS :B-68)
 

So - this is not only not a major view. It is not a minor view from the peer reviewed literature either.

This is only your own view derived from arguments within the PEIS itself.

Also the final step in your reasoning there is not a valid deduction.

Your premise is

samples are unlikely to pose a risk of significant ecological impact

Your conclusion is

it is reasonable to conclude that there would be no significant impacts

It is not reasonable to deduce "no significant impacts" from a low risk of significant impacts.

The worst case significant impacts here are global. A low risk of a global impact is still a risk of a global impact.

The analogy of a house fire may help. You can't deduce from a low risk of a house fire that a house fire would be localized to one room or that it would not be significant.

The PEIS also relies on submitted final Environmental Impact Statements for other biosafety level 4 laboratories to conclude that "the risk to the public [from lab leaks] is negligible":

While not completely analogous, the results of previous NEPA analyses for BSL-4 facilities have concluded that the hazards associated with the operation of BSL-4 facilities are expected to be minimal.

[ These next two sentences refer to the analyses by the National Emerging Infectious Diseases Laboratories, and the . National Bio and Agro-Defense Facility for their approved BSL-4 EIS's - NASA hasn't shared any separate biosafety lab analysis for samples returned from Mars with the final PEIS]

Analyses performed in support of recent NEPA documents [by other agencies for previous BSL-4s] conclude that the risk from accidental release of material from a BSL-4 even under accident conditions that include the failure of protective boundaries (e.g., reduced effectiveness of ventilation filtration systems) are minute and can be described as zero (NIH/DHHS 2005).

An alternative release path resulting from the contamination of workers leading to direct contact with others (members of the public) was also analyzed [Not by NASA]. Qualitative risk assessments for this mode of transmission [for the two previous EIS's for ordinary BSL-4 labs] have shown that the risk to the public [from lab leaks] is negligible (NIH/DHHS 2005, DHS 2008).

Should the Proposed Action be chosen, Tier II NEPA analyses of the proposed SRF11 would include analysis similar to those performed for existing BSL-4 facilities.

(NASA, 2023, Mars Sample Return FINAL PEIS  :3-14)

Cites:
NIH/DHHS. (2005). Final Environmental Impact Statement National Emerging Infectious Diseases Laboratories, Boston, Massachusetts. Bethesda, MD: National Institutes of Health, U.S. Department of Health and Human Services.
DHS. (2008). National Bio and Agro-Defense Facility Final Environmental Impact Statement. Washington D.C.: U.S. Department of Homeland Security

[My comments in RED]


They also conclude that any pathogens could be contained as easily as any human pathogens so they don't need a separate analysis for a Mars Receiving Facility but just plan to use a standard BSL-4. There is no analysis or design for a Mars Receiving Facility. NASA defer this to tier 2.

An alternative release path resulting from the contamination of workers leading to direct contact with others (members of the public) was also analyzed [Not by NASA]. Qualitative risk assessments for this mode of transmission [for the two previous EIS's for ordinary BSL-4 labs] have shown that the risk to the public [from lab leaks] is negligible (NIH/DHHS 2005, DHS 2008).

Should the Proposed Action be chosen, Tier II NEPA analyses of the proposed SRF11 would include analysis similar to those performed for existing BSL-4 facilities.

(NASA, 2023, Mars Sample Return FINAL PEIS  :3-14)

NASA confirmed to me that the conclusion that potential environmental impacts would not be significant is based on their own arguments in the EIS. They also confirmed that their PEIS is not peer reviewed. See below:

Given this background it was not appropriate to restrict the Affected Location in advance to the Utah Test and Training Range (UTTR), based on non peer reviewed reasons first given in the PEIS itself.

It fails basic scientific integrity, a NEPA requirement

"Agencies shall ensure the professional integrity, including scientific integrity, of the discussions and analyses in environmental documents"
§ 1502.23

For instance you depend on the Mars meteorite argument but it is rebutted by its main cite.

NASA:

The natural delivery of Mars materials [i.e. martian meteorites that reach Earth ] can provide better protection and faster transit than the current MSR mission concept

First, potential Mars microbes would be expected to survive ejection forces and pressure (National Academies of Sciences, Engineering, and Medicine and the European Science Foundation 2019) [CITE REBUTS SENTENCE], …”

(NASA, 2023, Mars Sample Return FINAL PEIS 3–3),

[my comment in red in square brackets, and emphasis on central point in red]

The samples you will return are sealed in a sample tube with a small amount of Martian atmosphere at Martian atmospheric pressure, like a miniature spaceship for a microbe. The meteorites are ejected into space from big impacts into the surface. This is what your 2019 National Academy of Sciences cite says:

National Academy of Sciences, 2019 (NASA's cite)

The reasoning regarding natural flux does NOT apply directly to samples returned from the Mars surface . The material will be gently sampled and returned directly to Earth.

The sample may well come from an environment that mechanically cannot become a Mars meteorite. The microbes may NOT be able to survive impact ejection and transport through space.”

...

Finding: The committee finds that the content of this report and, specifically, the recommendations in it do NOT apply to future sample return missions from Mars itself.

(SSB, 2019, Planetary protection classification of sample return missions from the Martian moons : 45)

Also on pages 4-5:

The main differences between MSR and Phobos/Deimos sample return missions are as follows:

.

  • MSR sampling sites will be specifically selected to maximize sampling of evidence of extinct or extant life, whereas materials deposited on the martian moons originates from randomly distributed crater impact sites.
  • Martian material present in a Phobos/Deimos sample would have undergone several physical sterilization processes (e.g., excavation by impact, collision with Phobos, and exposure to radiation), before it is actually sampled. Material collected on the surface of Mars will not have undergone such processes.
  • MSR material might come from sites that mechanically cannot survive ejection from Mars and thus any putative life-forms would de facto not be able to survive impact ejection and transport to space. Such mechanical limitations do not apply for material collected on [Mars] Phobos.

.

Therefore, the committee finds that the content of this report and, specifically, the recommendations presented in it do not apply to future sample return missions from Mars itself

(SSB, 2019, Planetary protection classification of sample return missions from the Martian moons : 4-5)

This also fails another NEPA requirement to identify opposing views:

At appropriate points in the final statement, the agency shall discuss any responsible opposing view that was not adequately discussed in the draft statement and shall indicate the agency's response to the issues raised.

§ 1502.9

The PEIS doesn't mention the opposing view that the Mars meteorite argument is invalid in the very cites you use.

The PEIS presents the Mars meteorite argument as a scientific consensus. The consensus is the other way around.

I have only been able to find this argument in two non peer reviewed sources, the PEIS itself and a non peer reviewed op ed. by the president of the Mars Society Robert Zubrin.



I have only been able to find this argument in two non peer reviewed sources, the PEIS itself and a non peer reviewed op ed. by the president of the Mars Society Robert Zubrin.


It is the same for the other three arguments you use to argue to a conclusion that any environmental effects would not be significant and health effects would be negligible.

All four of these arguments are found only in NASA's EIS, your biological safety report and that non peer reviewed op ed by Robert Zubrin, none of which are peer reviewed.

They are disproved in many peer reviewed articles on planetary protection.

This also shows your team didn't read carefully as far as page 5 of the most important cite for the most important sentence on planetary protection.

This also shows you didn't have any one on your team familiar with the literature on planetary protection.

This is a requirement under NEPA.

 

All four of your main planetary protection arguments fail scientific integrity.

For instance you argue that Mars has been uninhabitable for millions of years.

NASA's final PEIS says:

Existing credible evidence suggests that conditions on Mars have not been amenable to supporting life as we know it for millions of years (… National Research Council 2022).
(NASA, 2023, Mars Sample Return final PEIS : 1–6)

 

NASA's own iMOST team recommended tests for life in the very samples they plan to return from Jezero crater:

Your biological safety group says

Invasive species or pathogens have been successful on Earth because they were adapted to similar environmental niches in their original and dispersed ecosystems (Bleuven and Landry 2016). There are many described extremophiles that may survive in environments that are extreme to human or animal life (e.g. extremes of temperature or pressure) but do not survive under conditions in our normal habitat (Merino et al. 2019).

Thus, it is plausible that any Martian microbe, after it arrives on Earth, would not be viable on Earth due to a lack of its required Martian nutritional and environmental conditions
. Indeed, the Martian environment is inhospitable to Earth life, but conversely, the Earth environment is likely to be just as inhospitable to Martian life. Based on these factors, a very low qualitative probability of biological risk can be assumed.

(Craven et al., 2021, Biological safety: 6)

Their only cite, Merino et al, has only one example that's a plausible Mars analogue in temperature range and it is a counterexample: Planococcus Halocryophilus: (Merino et al., 2022, Living at the extremes: extremophiles and the limits of life in a planetary context: table 3) Optimal growth at 25°C and up to 37°C.

This microbe showed metabolic activity down to -25°C, the lowest temperature tested ((Bacterial growth at− 15°C …) and may grow at ultra low temperatures too slowly to test in the laboratory). isolated from Canadian permafrost with ambient temperature around -16°C . (Merino et. al., 2019, Bacterial growth at− 15 C; molecular insights from the permafrost bacterium Planococcus halocryophilus Or1)

The Biological Safety Report look at ten examples of human diseases (Ebola, HIV, influenza, Escherichia coli strain 0157:H, Candiasis yeast, Kaposi's sarcoma, malaria, yellow fever, and schistosomiasis).

They find that all these diseases needed to evolve in an Earth host. They either co-evolved with humans or jumped to humans from birds or mammals, or in the case of malaria, yellow fever and schistosomiasis, evolved in a more complex relationship between humans and snails or mosquitoes (with common ancestor between snails or mosquitoes and humans 600 to 1,200 million years ago).

Biased on these examples they conclude that we have near zero risk from Martian microbes

Since any putative Martian microorganism would not have experienced long-term evolutionary contact with humans (or other Earth host), the presence of a direct pathogen on Mars is likely to have a near-zero probability.”

(Biological safety : 6)


This passage has no cites to the planetary protection literature. They don't say that anyone else has used this argument before. The only previous occurrence of this argument I know of is the non peer reviewed op ed by Robert Zubrin

Warmflash et al looks at various counterexamples (Warmflash et al, 2007, Assessing the Biohazard Potential of Putative Martian Organisms for Exploration Class Human Space Missions : 14 - 15)

The Clostridia genus is anaerobic so doesn't need oxygen. They also look at diseases of crops that can harm humans when they eat them

We now have an example of a Mars analogue black yeast (fungus) that does well in Mars simulation chambers

Warmflash et al conclude:

While, based on the terrestrial examples, invasive capabilities will likely be rare among putative Martian microorganisms (32), we cannot be sure that they will be non-existent, nor can we depend on the following a priori conclusion, as expressed by a popular Mars colonization enthusiast, that there is no evidence for the existence of macroscopic Martian fauna and flora. Without indigenous hosts, the existence of Martian pathogens is impossible (50). In fact, not even all infectious human pathogens - let alone non-infectious pathogens - on Earth require a multicellular, macroscopic host in order to evolve harmful capabilities.

(Warmflash et al, 2007, Assessing the Biohazard Potential of Putative Martian Organisms for Exploration Class Human Space Missions : 14 - 15)

But the biological safety report show no awareness of these examples.

Indeed, the Biological Safety Report gives no cites to the planetary protection literature for this paragraph discussing human diseases although it has of course been one of the main topics of discussion for decades. Also they don't cite any previous cite to any paper arguing that microbes that haven't co-evolved with Earth hosts can't harm us.

I raised the very serious issue that a HEPA filter can't contain 100% of microbes at 0.05 microns and upwards as required with the ESF size limit.

This is a size limit in a recommendation for containment set by the European Space Foundation (ESF) which as far as I can tell in my literature search so far can't be achieved by any current or proposed air filter technology.

So HEPA filters can't comply with the ESF recommendation.

NASA just say they don't concur that it's an issue

NASA is aware of the ESF Mars Sample Return backward contamination study. NASA does not concur that 0.05-micron (50 nm) particles cannot be managed; standard High Efficiency Particulate Air (HEPA) filters like those used in biosafety facilities are tested for effectiveness at or near the Most Penetrating Particle Size (MPPS), which is typically 0.12 micron. (Perry et al, 2016, (Submicron and nanoparticulate matter removal by HEPA- rated media filters and packed beds of granular materials).“Particles both larger and smaller than the MPPS (including bacterial spores and viruses) are removed with greater efficiency.”
(NASA, 2023, MSR FINAL EIS :B-62)

That is not an acceptable response to such a serious issue.

You set the scope of the project to local to the Utah test and training range from the start. But that's based on your own non peer reviewed reasoning based on those four invalid arguments. The major views are that the potential impacts are global.

The European Space Foundation in 2012 said the samples should be contained as if they were risk group 4 (high risk of individual and community spread) until they are better understood

While, based on assumptions, some aspects of the release of unsterilised Mars material can be framed in some way, with such a level of uncertainty, unknown (and therefore unexpected) consequences driven by unknown mechanisms are conceivable and by definition are hardly manageable and predictable.

In this context, confinement of the sample appears to be the best prevention method. This principle is also applied when an unknown pathogen with a high case fatality rate is isolated: it is assimilated to Risk Group 4 and contained in laboratories with the highest level of confinement until further knowledge about the pathogen allows it to be down graded to a lower risk group.

Following the same principle, a priori assignment of a Mars sample to Risk Group 4 appears to be the best measure.

.(Amman et al., 2012, Mars Sample Return backward contamination–Strategic advice and requirements : 24

NASA's second planetary protection officer Cassie Conley similarly said

“that means we are going to contain the samples as if they were the most hazardous Earth organisms that we know about, Ebola virus.”
at 1:02 into this official NASA video

On environmental effects, the ESF report concurred with earlier reports that the risk appears to be low but is not demonstrably zero.

The Study Group also concurs with another conclusion from the NRC reports (1997, 2009) that the potential for large-scale effects on the Earth’s biosphere by a returned Mars life form appears to be low, but is not demonstrably zero.

(Mars Sample Return backward contamination–Strategic advice and requirements : 20)

Once we accept that we do not know that pathogens from Mars are harmless to humans or the biosphere then there's the issue of lab leaks and quarantine. This is an issue that goes back to the Apollo era and has never been resolved.

We can't contain many terrestrial pathogens. You can't contain a fungus with quarantine. Typhoid Mary was a life-long symptomless carrier of typhoid. Many people carry fungi with no symptoms. Leprosy has a latency period of two decades.

How would you contain life based on mirror organics with quarantine in ANY lab run by human technicians? You can't.

It's also clear you didn't have members of the team with the appropriate disciplines.

The disciplines of the preparers shall be appropriate to the scope and issues identified in the scoping process

§ 1507.2

You also improperly prescreened three reasonable alternatives submitted by the public.

That isn't permitted under NEPA.

An agency also has to look at alternatives that don't meet the applicants listed goals but better meet the policies and requirements set forth in NEPA and the agency's statutory authority and goals

(CEQ, 2022, National Environmental Policy Act Implementing Regulations Revisions - a rule by the CEQ on 4/20/2022)

In this passage, the SSAP means [Sample Safety Assessment Protocol], a protocol to test the samples for the presence of Martian life. In this protocol, if none is found they can be released form the labs, if Martian life is found the samples are never released because the effects can't be predicted from unknown novel life.

Given the needs above, Mars sample processing and analysis cannot be sufficiently conducted in situ, and any alternative associated with sample analysis under the MSR Campaign must be able to accommodate the processes and associated equipment required to conduct the level of analysis required to meet MSR Campaign objectives, including a comprehensive SSAP [Sample Safety Assessment Protocol]

[i.e. any alternative must be able to complete the sample safety assessment protocol to prove that it is safe to release unsterilized samples to the labs].

Additionally, given the constraints described above, there is no instrument or suite of tests that Perseverance can use on Mars or that the MSR Campaign could bring to Mars, to definitively determine if the samples collected are of sufficiently low risk so as to alter the "Restricted Earth Return" mission planetary protection designation and being treated as if they are potentially hazardous.
[excludes in situ searches because they can't be used to prove that the samples can be returned to Earth with no restrictions]

(NASA, 2023, Mars Sample Return FINAL PEIS : 2-25)

This improperly removes from consideration all three of those reasonable alternatives

No safety testing is needed for samples returned sterilized or unsterilized samples studied on Mars or unsterilized samples studied above GEO because there is no risk from such samples.

 

Based on this Programmatic Environmental Impact Statement (PEIS) it is clear

So - NASA are not an organization that could run a biosafety lab suitable to protect Earth or to devise a biosafety plan for Earth.

I have a solution that plays to your strengths. Sadly you prescreened it out of consideration and labelled the attachment that described it as "non substantive". So you never got to read it properly. It is based on your own Europa lander proposal from 2016 to land a miniature life detection lab to search for life in situ on Jupiter's moon Europa. You missed this as a possibility in your PEIS due to using a cite 15 years out of date for in situ instruments. The technology has moved on hugely with incredible shrinking instruments. We now DO have the capability for a life detection lab above GEO in a Mars simulation chamber that could do better life detection than we could do on Earth due to the ability to make it far cleaner and use "lab on a chip" microfluidics able to detect a single amino acid in a gram of sample.

Due to reliance on 15 years out of date literature you missed this alternative in your own work.

It is returned to an orbit above GEO in a safe inclined plane, in what would be Earth's ring plane if it had a ring system. No humans ever go near it. Anything returned to Earth is sterilized.

To make best use of this capability we need samples returned in CLEAN containers. I suggest samples of dirt, atmosphere and dust, a sample of salt (top priority for astrobiology) and a pebble from a recently excavated crater.

Recent research suggests that recognizable organics are reduced 1000 fold in 70 million years from 100 to 0.1 ppb. The youngest exposure age measured by Curiosity is 80 million years.

The surface organics likely consists almost entirely of formate, oxalate and benzoate - two chain carbon groupings or benzene rings, mixed with some more recent infall from space and any products of present day life. Likely there is no detectable signal of past life noticeable above your 8.,1 pp b and up to 0.7 ppb per biosignature of forwards contamination.

By crater impact statistics there is a near certainty of a crater younger than 100,000 years within reach of Perseverance excavated to a depth of 2 to 5 meters. Any organics from a crater like that would be far more interesting to astrobiology.

So I propose that Perseverance locates such a crater and studies it, looks for interesting organics and samples it. Then the ESA Fetch Lander would arrange its landing ellipse to include that crater. Then the Marscopters need to boost their signal to be able to communicate with the ESA fetch lander from the crater, and they would fly out to it, stage by stage taking a week or two to get there, pick up a small pebble or a few pebbles from a stratum identified as interesting by Perseverance and return it to the lander in a clean self-closing container.

They would use a similar method to find a sample of salts from somewhere near the landing site of the ESA fetch lander.

I hope you find this idea inspiring. .

You will not be able to come to any conclusion with the Perseverance samples. They have too much terrestrial contamination and will simply go to hold and critical review until we get more information from Mars by other methods.

Also in a mission searching for evidence of the past, your mission is not looking in the places most likely to have life if any. For instance rare spores in the dust, or micropores in salts or in some way making use of the ultra cold surface and near surface brines that Curiosity found and Perseverance can't detect. Martian biofilms might be able to retain the ultracold water through to the warmer daytime periods when temperatures can go above 15 C.

Carl Sagan thought in terms of perhaps 60 landers before we know it's safe to send humans to Mars. We could do it far faster with far more landers using mainly cubesat sized probes, cavebotsl, moles etc. But they need to be 100% sterile to send so many landers to very vulnerable areas of Mars with potential for terrestrial life to proliferate there.

We have the technology to do it. I believe there is a reasonable chance the technology already exists for a 100% sterile Marscopter using silicon on insulator chips (0.35 microns and functions at 300 C) and other components. It needs to be heated to 300 C for a few minutes, maybe an hour or two to be sure, then it's sterilized probably using a small onboard heater.

 


DRAFT: Open letter to NASA | Response to final PEIS | Fails NEPA requirements | main points in open letter in more depth | Finding an inspiring future | executive summary of preprint | Low risk like house fires and smoke detectors | About me | DRAFT: Endorsements by experts | Why this needs an open letter with endorsements | DRAFT: Call to NASA to defer or withdraw PEIS| Letters | BOOK: Preprint to submit to academic publishers

Author: Robert Walker, contact email robert@robertinventor.com