I am writing to ask you for help to draw attention to serious flaws in NASA's final Environmental Impact Statement for their plan to return samples from Mars in the 2030s. Most serious of all, NASA bases their planetary protection strategy on four invalid arguments only previously found in a non peer reviewed op ed. by Robert Zubrin, president of the Mars society and rebutted in the planetary protection literature long ago. Their Mars meteorite argument is even rebutted by the cite they attach to their paragraph presenting the argument in the EIS and they don’t alert the reader to this discrepancy.
I feel it's essential for NASA to comply with their legal obligations under NEPA for scientific integrity, to protect Earth's environment and inhabitants, and I expect you will too.
I know this is hard to believe, that NASA would write something so failing in basic scientific integrity. I found it hard to believe myself as a long term admirer of NASA, but I hope you can give a few moments of your time to check what I said and you'll quickly find that my summary is accurate. For the very striking example of the Mars meteorite argument see (below):
I was finishing what was going to be my first paper on astrobiology, on planetary protection for NASA's mission when the Environmental Impact Statement process started. See my brief bio: About me. I commented on both rounds of public comments raising these issues which they have done nothing about. This means I have legal standing under NEPA and NASA are legally required to respond to the comments I made, but they haven't done anything to fix these issues.
If you agree that these are serious issues I'm hoping that you will endorse my comments. The immediate priority is to ask NASA to defer finalizing this EIS because of these major issues of scientific integrity, which is a requirement under NEPA. You can do that here.
They will be able to finalize it on July 8th after the end of a mandatory 30 day wait period though I'll continue to ask them to withdraw it after that date.
You can also endorse my statements to NASA based on what I already said to them in the public comments, though with more details I have learnt since then:
I do the citations in a way that's makes it easier to click through to the paper when reading online, without losing your place in the page here. I use a direct hyperlink to the online paper and add the page number if available.
The title of each section summarizes its main conclusions similarly to an abstract. You can get a good first idea by just reading the titles of sections - and looking at any graphics.
Hover your mouse over the left margin of the page to see a floating table of contents of all the section titles.
The skip to next / back links give another way to go through the open letter quickly. You can read the title of each section then read on to find more or click next The top level next lets you skip through the top lively headers like reading an abstract of the open letter.
NASA don't cite Zubrin in this EIS but it is based on the same four arguments that Zubrin used in a non peer reviewed op ed in 2000 (Zubrin, 2000, Contamination From Mars: No Threat).
NASA uses these arguments to support their approach of taking much less by way of precautions to protect Earth's biosphere and inhabitants than their previous planetary protection officers recommended. They argue that the environmental effects would not be significant and would not be global but would be restricted to the Utah Test and Training Ground where the capsule is scheduled to land from Mars with their mission plan.
Planetary protection experts argued vigorously against Robert Zubrin in the next edition of the Planetary Report (Rummel et al., 2000, Opinion: No Threat? No Way : 4 - 7).
The four arguments are:
that if there is life on Mars it already got here in meteorites
that any life on Mars wouldn't be able to survive terrestrial conditions
that Mars is uninhabitable
that any Mars life would be unable to harm humans
presented as certain or near certain.
If ready to endorse you can endorse them as invalid here:
This isn't because of any new science since the experts rebutted Zubrin's arguments. It's because NASA's engineers are focused on the task of preparing to send humans to Mars as soon as possible.
This isn’t the Planetary Protection of the past — we are doing things differently. We have a different approach and philosophy.
There’s still a lot of work to go as we start to pave the way to humans on Mars — we’ve never done that, it’s a new precedent, so we’ll need that continued support to help with managing those knowledge gaps, including management support, engineering support and of course funding support.
The rubber is hitting the road; it’s time to get it done and we need that collective agency support to do that.
By the history from the Space Studies Board, first NASA closed down the interagency panel in 2006 which could have advised them, for instance on public health, and issues with lab safety and quarantine, turning it into a planetary protection subcommittee of a science committee. NASA's engineers stopped listening to the planetary protection experts so their planetary protection subcommittee had stopped functioning by 2016 and NASA closed it down too (Space Studies Board, 2018, Review and Assessment of Planetary Protection Policy Development Process : 26)
In this EIS, NASA seem unaware that anyone rebutted these arguments, not even when they are rebutted or there are counterexamples in their own cites!
They present them as original arguments of their own though they claim falsely, without citing any scientists who make the same argument, that the Mars meteorite argument is widely accepted in the scientific community.
NASA say that any life they return gets here better protected and faster in the meteorites that get to Earth from Mars after large impacts on Mars than in their sample tubes.
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], …”
[my comment in red in square brackets, and emphasis on central point in red]
The samples NASA 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 rare big impacts into the surface every few hundred thousand years. 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.
So their cite firmly rebuts the argument they are using it to support.
This cite says the same thing more briefly on pages 4-5 (SSB, 2019, Planetary protection classification of sample return missions from the Martian moons : 4-5). This shows that NASA's Mars Sample Return team are not familiar enough with their own cites to know what their most important cite for the most important argument they use says on pages 4-5 of its introductory Summary page.
NASA's sentence is part of a paragraph that presents the Mars meteorite argument as a consensus amongst scientists, at least to an uninformed reader who reads the passage quickly. It does that by not making a clear distinction between the transfer of Mars materials, which of course is a consensus, and the transfer of Mars organisms.
One of the reasons that the scientific community thinks the risk of pathogenic effects from the release of small amounts ( less than 1 kilogram [ 2.2 pounds ] ) of Mars samples is very low is that pieces of Mars have already traveled to Earth as meteorites. The National Academies of Sciences affirmed the consensus that Martian material travels to Earth when they developed the planetary protection guidelines for sample return from Martian moons, Phobos and Deimos (National Academies of Sciences, ..., 2019) .... (NASA, 2023, Mars Sample Return SR FINAL EIS (NASA, 2023, Mars Sample Return SR FINAL EIS : 3–3),
The National Academy of Sciences in 2019 did affirm the consensus or rather didn't question the consensus that Mars meteorites come from Mars. But it REBUTTED the Mars meteorite argument as I just showed you, and they don't alert the reader to this discrepancy anywhere in the EIS.
NASA's final PEIS implies that the 2009 report also supported the Mars meteorite argument like this:
The NRC acknowledged that since
the 1997 report, additional information has been discovered regarding the environment
of Mars and the existence of life in inhospitable Earth environments once thought to be
incompatible to life. The NRC reaffirmed the conclusion that the potential for pathogenic
effects from the release of small amounts of Mars samples is regarded as being very
low. Additionally, those life forms found in extreme environments on Earth have not
been found to have pathological effects on humans (National Research Council 2009).
One of the reasons that the scientific community thinks the risk of pathogenic effects from the release of small amounts (less than 1 kilogram [2.2 pounds]) of Mars samples is very low is that pieces of Mars have already traveled to Earth as meteorites
From the context, continuing from the previous paragraph, this gives the impression to the reader that the 2009 NRC report is part of a scientific community that uses the Mars meteorite argument to argue for harmlessness. The NRC study actually rebuts the Mars meteorite argument. It is a basic requirement of scientific integrity to alert the reader to this opposing view at this point.
The 2009 report concluded:
The potential hazards posed for Earth by viable organisms surviving in samples [are] significantly greater with a Mars sample return than if the same organisms were brought to Earth via impact-mediated ejection from Mars
...
Thus it is NOT appropriate to argue that the existence of martian meteorites on Earth negate the need to treat as potentially hazardous any samples returned from Mars by robotic spacecraft.
I drew attention to this discrepancy in one of my attachments. They do quote my comment but they don't acknowledge any discrepancy between the 2009 report and their EIS even though I quoted that very passage.
Robert Walker
"In 2009, the National Research Council examined the possibility of life transferred on meteorites said the risk is significantly greater in a sample return mission - and said they can’t rule out the possibility of large scale effects in the past due to life from Mars – NASA’s EIS instead claims microbes will survive transfer from Mars to Earth more easily in a meteorite than in a sample return mission but their sources don’t back this up
(NASA, 2023, Mars Sample Return FINAL EIS : B59-60),
This is their response:
NASA:
NASA addresses unknown risks directly in its planetary protection guidance, and in response, the MSR Program would, as stated in the PEIS (p. 1-6), “implement measures to ensure that the Mars material is fully contained (with redundant layers of containment) so that it could not be released into Earth’s biosphere.” Additionally, the PEIS details and references on pages 3-3 to 3-4 information on the unlikely risks from “life that can’t get to Earth on meteorites.
Pages 3-3 to 3-4 are the ones quoted here - they do NOT mention the possibility of "life that can't get to Earth on meteorites".
Incidentally this passage also misrepresents what the 2009 report said about life in extreme environments.
Additionally, those life forms found in extreme environments on Earth have not been found to have pathological effects on humans (National Research Council 2009).
[The NRC didn't come to that conclusion about extremophiles either, they drew attention to shared virulence genes between an extremophile and closely related human pathogens]
The 2009 NRC review adds a counter example of hydrothermal vent organisms which are evolutionarily close to human pathogens
“However, it is worth noting in this context that interesting evolutionary connections between alpha proteobacteria and human pathogens have recently been demonstrated for natural hydrothermal environments on Earth
… it follows that, since the potential risks of pathogenesis cannot be reduced to zero, a conservative approach to planetary protection will be essential, with rigorous requirements for sample containment and testing protocols of life forms that are pathogenic to humans’
These organisms don’t harm us, but their close relatives can. Helicobacter can cause stomach ulcers and Campylobacter can cause acute gastrointestinal disease in humans (Cornelius et al., 2012. Epsilonproteobacteria in humans) These pathogens harm us through virulence genes they share with the hydrothermal vent organisms. The same adaptations that help them survive in their ecological niches in hydrothermal vents also help them survive in humans
Although they are nonpathogenic, both deep-sea vent epsilon-Proteobacteria share many virulence genes with pathogenic epsilon-Proteobacteria, [they give a list of virulence genes, and other capabilities that enhance virulence]
… these provide ecological advantages for hydrothermal vent epsilon-Proteobacteria who thrive in their deep-sea habitat and are essential for both the efficient colonization and persistent infections of their pathogenic relatives.
“… It follows that, since the potential risks of pathogenesis cannot be reduced to zero, a conservative approach to planetary protection will be essential, with rigorous requirements for sample containment and testing protocols of life forms that are pathogenic to humans’
Actually we know where the most recent rocks to leave Mars came from, Zunil crater. It's hundreds of thousands of years old, and our best estimate with cratering counts is 700,000 years ago, half a million years before modern humans first evolved.
The rocks were also ejected from well below the surface, in the Martian cryosphere where the temperature is an ultracold -73 C (200 K) and the presence of life is very unlikely (unless the impactor that formed Zunil crater hit a local geological hot spot on Mars - these occur rarely with none known on present day Mars).
NASA's own iMost team which they assembled to advise them on the experiments to do with the returned samples said in 2017 that we cannot predict whether life on Mars shares a common ancestor with life on Earth:
“We cannot predict with any accuracy life's form and characteristics, whether it would be viable …,or whether it shares a common ancestor with life on Earth.”
NASA's EIS is in two tiers. This Environmental Impact Statement is Tier 1 which should be the tier with widest environmental impact. It is restricted to environmental effects to the Utah Test and Training Ground where the sample return capsule lands.
I draw attention to that in my letter to NASA which I hope some of you can endorse:
Text on graphic:
Affected location: Utah Test and Training Range (UTTR), Utah Global
Dear NASA,
All major Mars sample return studies say there's a likely low risk of large-scale harm to human health from the samples. The most recent study by the European Space Foundation says they should be assigned risk group 4, high risk of individual and community spread.
All major studies also agree on a likely low risk of large-scale harm to the environment. It wasn't appropriate to restrict the zone to a local zone in advance based on original non peer reviewed arguments only presented in the EIS itself. Your main Mars meteorite argument is rebutted by its own main cite, and many issues raised by the public have not yet been addressed.
This EIS is NOT ready to be finalized. Please defer or withdraw, and do consider the suggested reasonable alternatives that play to your strengths as an organization. Thanks!
This limited scope for the Environmental Impact Statement makes it essential to NASA's team to show that there are no global effects or they would have to say the scope is global and restart the process.
That is where these four arguments come in.
In the EIS, they don't discuss any potential for global effects on the environment or human health and instead argue to a conclusion that environmental effects of the release of unsterilized Mars samples would not be significant and effects on public health would be negligible.
That's all based on these four arguments.
To a reader not familiar with planetary protection, NASA seem to assert a consensus amongst scientists that the meteorite argument especially is valid.
To do that, as we saw, they
blur the distinction between transfer of rocks from Mars, which is a consensus, and transfer of living organisms from Mars which may never have happened even if there is life on Mars.
don't mention any sources that rebut their Mars meteorite argument, even though both of their National Academy of Sciences cites in this paragraph rebut it firmly.
Presumably NASA aren't familiar enough with their own sources to know that they rebut this sentence, the most important sentence in the EIS from the point of view of planetary protection.
Yet they don't provide any cite to anyone who says the argument is valid.
Of course, as you'll know, there can be scenarios with abundant life on Mars that is unable to get to Earth in meteorites because it can't withstand the shock of ejection or the extreme dehydration of space. It could also be life that needs the surface conditions on Mars and can't get into the rocks below the surface that are ejected to Earth
NASA confirmed to me in a comment reply that their conclusion that environmental impacts would not be significant is sourced to the (non peer reviewed) Environmental Impact Statement itself and they have no other source to cite for this conclusion.
They also use a form of reasoning that isn't logically justified. They argue from a low risk of significant environmental effects to a judgement that the effects would not be significant (NASA, 2023, MSR FINAL EIS : B-68) - and so to local effects only.
This is like arguing from a low risk of a house fire to a conclusion that house fires aren't significant and can't spread far beyond the room they start in.
These are the relevant statements in NASA's draft EIS:
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 themselves confirm that this is a conclusion they reach from the arguments within the Environmental Impact Statement itself:
The sentence cited in this comment (“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.”) 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)
It 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 with the EIS for samples returned from Mars]
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.
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 orange]
NASA's Environmental Impact Statement is NOT peer reviewed as NASA's team confirmed in a reply to me. Our public comments are the only peer review it got.
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)
[Confirms that it had no peer review or they would have replied saying it was peer reviewed]
As I expect you'll agree, if the Mars meteorite argument is valid, If all species on Mars get here on meteorites, it's not clear why NASA are containing the samples at all.
While if we have a possibility of an invasive species from Mars, though the effects could be minor, there is no way to rule out large scale effects in the worst case.
The idea that by reducing the risk you make the risk no longer global and so can restrict the location to the Utah Test and Training Ground isn't logically coherent.
I'm not able to liaise with former NASA employees like NASA's first planetary protection officer John Rummel on this as it is an Environmental Impact Statement by NASA. But John Rummel in his brief email to me did say
I encourage you, however, to respond to NASA’s draft, highlighting the weaknesses that you have found. Somebody will listen – of that I am convinced – but I no longer work for NASA on this or any other project.
As a planetary protection expert, I wonder if you feel willing to endorse my statement to NASA that the same arguments are invalid in NASA's final PEIS?
To endorse, just give me a list of whatever statements you want to endorse in those sections or all of them if you want to endorse them all, and I'll add your name to them. Or use the check boxes and email form on that page to send me a list of the ones you endorse.
If you feel you can add a personal text message or video message to endorse too that's a great help. It would show these are experts who have given the matter enough attention to write a message or record a video, and not just signatures.
It will be a great help if there's anything you can endorse right away.
Or simpler to just endorse right away that the EIS is not ready to be finalized, and needs to be deferred or withdrawn. I already shared the page, here it is again.
We have until 8th July for the mandatory wait period until NASA finalizes this EIS. But if they do finalize it in this form I'll continue asking for endorsements to try to get attention and try to get them to withdraw it as failing basic scientific credibility and numerous other issues.
Do say if you spot anything there clumsily expressed or mistakes however minor or major, thanks!
My aim is to ask NASA to delay finalizing this EIS or withdraw it as failing scientific integrity. It's become clear that I have to go wider than the Mars sample return team, and need to get endorsements as a way to try to get their attention.
That's because it's become clear from their responses to public comments that there is
nobody on their team familiar with planetary protection (didn't read thoroughly as far as page 5 of the summary section of the main cite of their most important sentence in the EIS),
nobody familiar with basic public health (to explain why they never mention the ESF recommendation for 100% containment of all particles of 0.05 microns and upwards, they told me a HEPA filter can fulfill this requirement (NASA, 2023, MSR FINAL EIS : B-62) - the specification of a HEPA filter is 1 in 4000 containment at 0.3 microns)
(another example would be that any expert in public health would know of many examples, such as tetanus, of pathogens that didn't co-evolve with humans)
nobody familiar with risk assurance For instance they don't have an overall target probability for loss of containment for the mission and don't see a need to set one at a mission level
One of NASA's own experts on risk assurance, Chester Everline, commented on the last day of public comments saying he didn't find a target level of risk and seriously recommended not returning the samples if they can't establish the Mars meteorite argument.
NASA replied explaining they don't have a target probability for the mission. NASA told him that NASA recommends but doesn't require an overall target. They haven't set one and they don't have an overall target probability for containment for Earth Entry System release and landing either.
But NASA haven't updated the confusing passage he drew their attention to, to clarify this for the reader
I've got legal status as someone who commented on their mission plan in a timely fashion under NEPA so they are legally required to respond to any significant issues I raised and to consider the reasonable alternative I suggested and they aren't complying with that requirement.
So if they understood NEPA law they would realize they do have to act. But I think I'm talking to engineers, scientists and mission planners who have little interest in law either. They are just going to keep going blindly with the aim to get back to their engineering and go on with the mission plan as soon as possible.
But this is not going to work long term. As I'm sure you'll know, ALL the major Mars sample return studies stressed the importance of engaging with the public and listening to their concerns and responding to them meaningfully. As John Rummel put it, NASA's first planetary protection officer:
“Broad acceptance at both lay public and scientific levels is essential to the overall success of this research effort.”
I think one way to put it that an engineer might understand, is that this broad acceptance is as essential for this mission as ensuring that they have enough rocket fuel to get their samples back to Earth.
But they haven't set up any way to engage with the public and there is no dialog going on here.
So - it's clear there is nobody there I can talk to, on NASA's team and I can't resolve this by talking to them (they didn't reply to my email and anyway I now know from their replies to public comments and the EIS itself that there is nobody left on their team who knows enough about planetary protection to have a meaningful conversation with me on the topic).
This is a systemic issue, NASA did the same for Apollo. That was before NEPA and they set up their internal interagency panel so they could override any decisions any of the other agencies made (Meltzer, 2012, When Biospheres Collide : 193).
So the only solution I can think of is to do an open letter, and ask for endorsements and to take this to a wider audience.
My aim isn't to stop NASA's mission, I'm a long term admirer of NASA and very interested in both humans in space and astrobiology myself.
Carl Sagan is one of my heroes and I have the same focus as him in this respect. Enthusiastic about space science. Keen on space exploration, including both robotic and human exploration. Watched the Apollo landings in amazement in the 1960s. Marveled at the Voyager “grand tour” of the solar system. But I also greatly value Earth’s biosphere and its inhabitants.
For me, the value of Earth's biosphere and its inhabitants is essentially infinite.
“I, myself, would love to be involved in the first manned expedition to Mars. But an exhaustive program of unmanned biological exploration of Mars is necessary first.
“The likelihood that such pathogens exist is probably small, but we cannot take even a small risk with a billion lives.”
Even with a wider audience and understanding of this issue, from this EIS and from their recent history, I don't think NASA can hope to produce a competent biosafety plan based on containing the materials in their own facilities even if it was possible.
That would be like asking the CDC to oversee a mission to Mars from mission control without any help from NASA employees.
Meanwhile from the recent history, such as closing down and not listening to the interagency panel, NASA clearly can't be expected to work well with the CDC or NIH in day to day running of a biosafety laboratory or design decisions about how it needs to be constructed to contain the samples.
So far, NASA haven't considered lab leaks or quarantine, postponing it to Tier 2, but if they ever do give it serious thought, they will encounter the same very difficult issues the Apollo team did.
There seems no solution to the issue of quarantine for lab leaks of a laboratory run by human technicians. This is an issue raised early on by Carl Sagan who talked about the "vexing question of the latency period" for Leprosy.
There is also the vexing question of the latency period. If we expose terrestrial organisms to Martian pathogens, how long must we wait before we can be convinced that the pathogen-host relationship is understood? For example, the latency period for leprosy is more than a decade.
We now know that leprosy can take 20 years or more to show symptoms (WHO, 2019, Leprosy, Key facts,)
We can add many things to that. Carl Sagan could equally have used lifelong symptomless spreaders like Typhoid Mary, and there is no way to keep out mirror life or fungal diseases with quarantine.
So - it seems the only way to go with a ground based facility would be a fully telerobotic laboratory but that would be expensive (likely well over half a billion dollars) and also not within NASA's field of competence.
No humans ever go anywhere near it and anything returned to the Earth's biosphere is thoroughly sterilized.
Those bonus samples are needed because with nobody left on their team with an understanding of planetary protection, NASA has permitted a level of contamination with terrestrial life that makes the Perseverance samples almost certainly of no interest to astrobiology past or present. See:
In my proposal, the bonus samples would be returned to a very excellent Mars simulation chamber, rather like BIOMEX on the outside of the ISS but able to replicate Martian gravity, and daily and seasonal cycles.
Text on graphic: Bonus samples in STERILE containers returned to satellite perhaps 50,000 or 100,000 km above GEO in what would be Earth’s ring plane if it had a ring system.
NOT for safety testing
Returned for astrobiological study – nexus of expanding off-planet astrobiology lab.
Minimal forward contamination.
Humans nowhere near this.
Centrifuge to replicate martian gravity.
Many instruments placed in centrifuge along with the dust and operated remotely from Earth.
Chiral labelled release.
SETG from sample acquisition through to DNA sequence all automated in 2 units, each can be held in palm of hand.
Astrobionibbler microfluidics can detect a single amino acid in a gram of sample
I'm sure a university would be delighted to design and build a Mars simulation chamber to fly to above GEO at its own expense, like the Michigan Mars simulation chamber. The cost to NASA would likely be minimal, mainly the cost of the shell of the satellite, solar panels and so on and launch costs. See:
There are numerous exquisitely sensitive life detection instruments now, that we can send there with the amazing shrinking of technology.You can endorse those here
They prescreened all alternatives suggested by the public with narrow requirements that can only be satisfied by a near clone of their own mission plan. This is not permitted under NEPA.
In a valid EIS, NASA should consider all reasonable alternatives so please feel free to endorse any or all of these that you consider to be reasonable, on the basis of your expertise.
NASA say several times that no outcome in science and engineering can be predicted with 100% certainty in response to people who ask for more rigorous planetary protection or suggest safer alternatives like sterilizing all samples returned to Earth. They use this response even to Chester Everline who suggests not returning the samples at all and to search in situ,.
No outcome in science and engineering processes can be predicted with 100% certainty.
That of course is nonsense as if they don't return the samples at all there is no risk to Earth's biosphere or inhabitants. If they sterilize all samples returned to Earth with a sufficiently high level of sterilization there is no appreciable risk either.
NASA prescreened all three of the alternatives suggested by the public out of consideration because they had no way to prove the samples are safe.
For my example, though with the bonus samples in clean containers my solution could do a far better job of "safety testing" than they could do with their samples with so much terrestrial contamination at 8.1 ppb per gram, I argue there is no way for any sample return mission to do safety testing to a reasonable level of assurance at current level of understanding when there could be a single microbe from some distant location blown in the wind in the samples, especially since martian life might be pre-adapted with extra protection for transport in the dust and perhaps get to Jezero crater and still be viable in dust storms from as far away as the polar regions, such as Richardson crater.
If they looked more closely at the issue of terrestrial contamination, their prescreening criteria here would likely exclude their own mission plan!
The level of terrestrial contamination they permitted seemed acceptable according to the study they use which is from 2014, for a preliminary survey looking just at the levels of organics needed to detect the more abundant organics in Martian meteorites but don't take account of modern research into rapid degradation of organics in the presence of oxidants.
They prescreened all three alternatives out of consideration because they don't search for life in terrestrial laboratories.
They based that prescreening requirement on an out of date study from 2008.
NASA labelled my attachment describing the alternative in detail as "nonsubstantive" without reading it - so they never saw my long list of modern in situ instruments that we could send to such a laboratory - including several from NASA's own plan from 2016 to search for life in situ on Jupiter's moon Callisto.
They had such narrow prescreening that it was just about impossible for any alternative to get through the prescreening unless it was a near clone of their mission.
Prescreening like that is very much against NEPA requirements. They shouldn't do it.
Legally this EIS fails numerous requirements of NEPA. I think it's unlikely they consulted a NEPA lawyer, or if they did, they ignored what he or she suggested.
NASA prescreened all three of those reasonable alternatives out improperly because it has no way to prove the samples are safe (I argue there is no way for any sample return mission to do that at current level of understanding when there could be a single microbe from some distant location blown in the wind in the samples)
They also prescreened it out of consideration because it doesn't search for life in terrestrial laboratories. They based that on an out of date study from 2008, and because they labelled my attachment describing the alternative in detail as "nonsubstantive" without reading it - so they never saw my long list of modern in situ instruments that we could send to such a laboratory - including several from NASA's own plan from 2016 to search for life in situ on Jupiter's moon Callisto.
Prescreening like that is very much against NEPA requirements. They shouldn't do it.
But we do have a reasonable solution that plays to their strengths.
So I'm hoping to divert them away from their current path to consider my reasonable solution, which they are actually legally required to do.
Not as the only solution. But one they are legally required to look at, and hopefully would lead them to consider other solutions provided by others. But they are only legally required to listen to mine, and Chester Everline's solution to defer the sample return and the solution of several in the comments to sterilize all samples returned to Earth. So that's the situation.
We now have the capability to specify components such as computer chips that actually function at 300°C. We have specifications for a complete Venus lander probe that can function for months at 500°C. Amino acids and bases break apart and vaporize at 300°C within minutes. Based on this it seems possible to achieve 100% sterile landers on Mars, a suggestion first made in 2018 by the Venus surface lander team. The Marscopter seems a good place to start as it is relatively simple in terms of technology and most, perhaps all of its components could perhaps be replaced by commercially available components that can function at 300°C. Especially with the objective to just survive heating to 300°C for a few minutes without damage, this seems within reach in the near future. The marscopter could heat itself up briefly with an internal heater after it separates from the rover or lander that brings it to Mars which would mean it could go up close to sensitive areas such as RSL's.
Then we could later do in situ cube sat sized probes dispersed over the surface of Mars to biologically interesting but sensitive areas - and then advance to 100% sterile complete rovers, cavebots, moles etc.
In this way we could do a rapid survey of Mars with no risk of forward contamination and far more complete than anything Carl Sagan could have envisioned.
So that's the proposal I made to NASA in my public comments. This would allow them to do the safety testing they want to do before sending humans to Mars.
We then achieve 100% planetary protection both ways. 100% protection of Mars and 100% protection of Earth using technology that didn't exist a decade or two ago.
With rapid development of 100% sterile landers on Mars to prepare for a rapid biological survey in the near future by specifying components that can withstand a few minutes of heating to 300°C before they reach Mars based on modern chips able to run at 300°C (silicon on insulator), other high temperature equipment such as video cameras and sensors placed near jet engines, and in electric cars, and NASA's own HOTTECH program to develop landers for Venus able to function for months even at 500°C
We can't assume that Mars is safe for humans as needed for NASA's end goal to land human astronauts on Mars and I feel it is important to make this clear to NASA.
Though this may be unlikely we have no way at present to know how easy or otherwise it is for independent life to evolve on Mars. If the probability is high we could have close to 50% probability of life evolved from mirror organics there, or even higher if the surface is not connected enough and life evolved independently several times, with the mirror life co-existing with ordinary life.
To help draw attention of space agencies to these issues I presented a vivid scenario to NASA of mirror life. However they don't respond to this in the public comments. There is no mention of the word "mirror" in the document. So they likely dismissed this as "nonsubstantive"
If you feel you can endorse any of this that would be a great help, or anything else on the page.
As I'm sure you'll know but sadly NASA doesn't, as is clear throughout this EIS, whenever talking about this we need to be especially careful not to present it in a scary way to vulnerable people. That's what I do with my time full time now that I'm retired, help vulnerable easily scared people with fact checking of the stories that scare them over the internet.
The way you present things is so important. I use Margaret Race's wonderful smoke detectors / house fire / fire extinguishers analogy (Rummel et al., 2000, Opinion: No Threat? No Way : 5) W from her reply to Zubrin's op ed. a lot - and it is really useful to explain what it's all about especially to anyone easily scared.
This is my graphic for it.
Hand installing smoke detector labeled “NASA” and wooden ceiling of a house labeled“Earth”
I am doing all this to get NASA to install a smoke detector but one that I think is exceptionally important despite the low risk, because Earth’s biosphere is a “house” with billions of people in it.
For more about how this is about a likely very low risk but a very low risk of high consequence for the worst case scenarios, like house fires and smoke detectors see:
Do feel free to share this letter with anyone else. If there is anyone else you can think of who would be good to contact to ask for endorsements do say.
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