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 | Call to NASA to defer or withdraw EIS | Letters | BOOK: Preprint to submit to academic publishers

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

Executive summary - NASA must protect Earth’s biosphere even if Mars samples hold mirror life - let’s make this an even better mission and safe for Earth!

[NOT FOR SHARING - READY SOON]

NASA and China plan to return samples from Mars next decade in the 2030s. We may get private space returning samples too. Before we do that we need a proper planetary protection policy in place and working. Sadly NASA’s EIS just isn’t fit for purpose. The reason is they closed down their interagency panel, which only operated from 2000 to 2005, and closed down the planetary protection office which operated from 1997 to 2017.

NASA now have no external or even internal peer review. Apparently there is nobody left on their team that understands basic concepts of planetary protection - not surprising as the space studies board says most don’t and need to be trained in those concepts. The work of Sagan and Lederberg are products of remarkable minds.

We have to reverse this and my open letter outlines one way we can do this that will actually improve the science return of missions to Mars and of the Perseverance mission.

There may be many other solutions. The main thing is for NASA to start talking to planetary protection experts and other agencies again. Then we can work together on a future that is good for space exploration, planetary science, NASA, planetary protection and Earth’s biosphere and human health.

NASA needs to plan in a more flexible way where we have a future that is inspiring and encourages space exploration and settlement for ALL scenarios,

For my open letter see:

My conclusion is we now have the capability of 100% planetary protection both ways.

We can protect Earth’s biosphere 100% and we can also protect Mars from terrestrial life 100%. It is our choice as a civilization if this is what we want to do. It also leads to far greater science return - because once fully developed, which may not take more than a few years of work based on HOTTECH, we can look for life in situ anywhere on Mars without the need to target only locations for past life that were so restrictive for our missions so far - and without any risk of confusing forwards contamination.

My preprint outlines how we can do this. It also has new example scenarios to help motivate space agencies to protect Earth, such as mirror life, see link below.

This is an executive summary of some of the points in that preprint.

SUMMARY OF THE MAIN POINTS

First let’s look at a summary of the main points (As posted on the last day of public comments for NASA’s draft EIS)

I recommend this draft Environmental Impact Statement is stopped, and a new one prepared after doing the necessary size limits review, and fixing whatever led to its many errors.

1. The BSL-4 recommendation in this EIS is out of date, based on science of 1999.
2. This EIS does not mention the most recent Mars Sample Return study from 2012 by the European Space Foundation which reduced the 1999 size limit from 0.2 microns to 0.05 microns to contain ultramicrobacteria and required 100% containment at that size.
3. A BSL-4 is not designed to this standard. In recent reviews of filter technology, I find NO AIR FILTERS with that capability – and no evidence anybody is working on them. Air filters for larger particles remove some of these very small particles kicked out of the airstream by jostling of air molecules by Brownian motion but can't remove all. It is an unusual requirement.
4. NASA haven't responded to my comment in May which alerted them to this omission. They still don't cite the ESF study. Also, the ESF said their limit needs to be updated periodically. An update is certainly due a decade later.
5. The EIS has an overnarrow scope in the Purpose and Need section - it requires samples to be returned unsterilized to terrestrial labs for "safety testing". This won’t work. NASA believe they reduced the most abundant biosignatures to 0.7 nanograms per gram of returned rock sample – this guarantees a positive test. There will be no way to know if tubes contain safe terrestrial life or potentially unsafe martian life.
6. This narrow scope improperly excludes the reasonable alternative of presterilizing samples before they reach Earth's biosphere - which achieves virtually the same science return and keeps Earth 100% safe. By a 1997 case in the 7th circuit this alone probably invalidates the EIS.
7. The high levels of forward contamination make astrobiology almost impossible. I recommend bonus samples of dirt, dust and atmosphere collected in a STERILE container with no terrestrial organics, brought to Mars, especially on the ESA fetch rover.
8. I recommend returning these bonus astrobiology samples to a safe orbit above GEO where they can be tested for life
9. The EIS’s reasoning for no significant environmental effects contradicts the conclusion of the NRC study from 2009 which they do cite, which says the risk of even large-scale impacts on human health or environment is likely low but not demonstrably non zero. It also warns against the meteorite argument that they use. I found multiple errors in my analysis.
10. Returned life COULD be harmful. Example, fungi kill crops, other life and sometimes immunocompromised humans. Botulism, ergot disease, tetanus, all are the results of exotoxins not adapted to the lifeforms they kill, similarly some algal blooms kill dogs and cows that eat them. BMAA misincorporated for L-serine causes protein misfolding and is a neurotoxin implicated in some cases of the disease that affected Steven Hawking - an alternative biochemistry may have many different amino acids similar enough to terrestrial amino acids to be misincorporated. Or perhaps martian life evolved from scratch from mirror chemicals as mirror life - the effect on our biosphere can't be predicted. I give many such examples in my preprint. Or it could be harmless like microbes from a terrestrial desert, or indeed beneficial. But we DON'T KNOW. So we need to find out first.
11. What matters for invasive species are the ones that can’t ‘get here, like starlings that can't cross the Atlantic rather than barn swallows. The freshwater diatom Didymo is invasive in New Zealand and can't get from one freshwater lake to another without humans. A microbe adapted to briny seeps on Mars and to spreading in dust storms shielded frbiom UV, may well not get to Earth in a meteorite, while a sealed sample tube including Martian atmosphere, at Mars atmospheric pressure, is like a mini spaceship.
12. Quarantine of humans can’t keep out a fungal disease of crops, mirror life etc.
13. So any unsterilized samples will need to be studied remotely via telerobotics which also greatly reduces forwards contamination (issues with filtering ultramicrobacteria will go both ways).
14. Astrobiologists now have tiny instruments that can go from sample preparation to life detection, even to a gene sequence[r], operated remotely on Mars. They could send hundreds of these in each 7 ton payload of the Ariane 5 to above GEO.

Let's make this an even better mission and SAFE for Earth.
Thanks!

. Comment posted December 20th

The literature survey added many more details but hasn't led to any changes in those main points.

So now, let’s go through some of these points in more detail, but as an executive summary not as an academic paper like the preprint.

I also cover new material not in the intro, especially towards the end. I talk about an alternative inspiring future for human space exploration and eventual settlement in the solar system in the situation where we find microbes on Mars such as mirror life that can never be returned to Earth and have to shelve any proposals to land humans on Mars or colonize it.

TITLES OF SECTIONS ARE LIKE MINI ABSTRACTS - THIS IS ALSO AN EXECUTIVE SUMMARY FOR THE PREPRINT

The title of each section also 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 menu of all the section titles.

I use hyperlinked inline citations in this open letter consisting of the title in brackets hyperlinked to the paper and then the page number after the title like this: (Mars Sample Return: Issues and Recommendations (1997) : pages 6 - 7)

NASA CURRENTLY ENGAGE MAINLY WITH A SMALL SECTOR THAT ASKS THEM TO DROP ALL PLANETARY PROTECTION - OTHER COMMUNITIES PRIORITIZE HUMAN HEALTH, FARMING, FISHING, ECOSYSTEMS, ENDANGERED BIRDS ETC DEPENDING ON THEIR INTERESTS - AND WEIGH RISKS DIFFERENTLY - PUBLIC OPINION CAN SHIFT QUICKLY

NASA mainly engage with

However, others have very different priorities:

And so on. How many members of Congress would prioritize a Mars sample return over even a small risk to human health or to agriculture, or plankton, and the marine food chain, or to endangered species?

Public opinion can shift very quickly. The worst case is that NASA have to divert the mission on its way back from Mars to miss Earth. And then very expensive attempts to recover it and sterilize it before returning it to Earth.

RISK IS MOST LIKELY LOW - BUT TO IGNORE THESE RISKS IS LIKE BUILDING A HOUSE WITHOUT A SMOKE DETECTOR - BUT FOR A HOUSE WITH BILLIONS OF HUMANS LIVING IN IT

Margaret Race, a biologist working on planetary protection and Mars sample return for the SETI Institute and specialist in environmental impact analysis used the analogy of a smoke detector in response to similar non-peer-reviewed suggestions by the space colonization enthusiast and leader of the Mars Society Robert Zubrin:

If he were an architect, would he suggest designing buildings without smoke detectors or fire extinguishers?

Hazardous Until Proven Otherwise, in: "Opinion: No Threat? No Way",

Hand installing smoke detector labelled “NASA” and wooden ceiling of a house labelled “Earth”

(Smoke detector graphic from The EnergySmart Academy)

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.

Also the potential for present day life in samples returned from Jezero crater is likely low. But in other areas of Mars there are sites with much higher potential for present-day life. There may also be patchy life in Jezero crater in microhabitats that would eventually be returned with enough sample return missions. So NASA’s EIS is important as a precedent.

IMPORTANCE OF ENGAGING WITH OTHER US AGENCIES LIKE THE CDC, DOA ETC AS WITH THE APOLLO INTERAGENCY COMMITTEE ON BACK CONTAMINATION - AS RECOMMENDED BY THE SPACE STUDIES BOARD IN 1997 - AND ON MANY OTHER OCCASIONS

All the previous samplre return studies have focused on the importance of engaging with other agencies early on like the EPA, CDC, NOAA, DOI, DOA etc in an interagency panel as was done for the Apollo mission. The Space Studies board recommended this in 1997.

To coordinate regulatory and other oversight responsibilities, NASA should establish a panel analogous to the Interagency Committee on Back Contamination that coordinated regulatory and oversight activities during the lunar sample-return missions. To be effective, planetary protection measures should be integrated into the engineering and design of any sample-return mission, and, for an oversight panel to be in a position to coordinate the implementation of planetary protection requirements, it should be established as soon as serious planning for a Mars sample-return mission has begun.

For the panel to be able to review and approve any plans for a Mars sample-receiving facility, the panel should be in place at least one year before the sample-receiving facility is established.

(Mars Sample Return: Issues and Recommendations (1997) : pages 6 - 7)

Though this passage doesn’t mention the NEPA process, it is clear this panel would need to approve NASA’s plans BEFORE NASA submits its EIS under NEPA.

NASA SET UP SUCH A COMMITTEE IN 2000 BUT REMOVED IT IN 2006 LEAVING ONLY INTERNAL PEER REVIEW OF ITS PLANETARY PROTECTION PLANS - WHICH IT THEN REMOVED IN 2016–7

NASA did set up the Planetary Protection Advisory Committee (PPAC) in 2000. with scientists from other US Federal agencies such as the DoA, CDC, EPA, DoI, NSC etc. It also had international representatives from other space agencies such as the European Space Agency and the Japan Aerospace Exploration Agency (Review and Assessment of Planetary Protection Policy Development Processes : page 26) supplemented by (The Goals, Rationales, and Definition of Planetary Protection: Interim Report : page 37).

However NASA ordered PPAC to stop meeting in 2005, removed the other agency scientists serving on it including the chair in 2006 turning it into the Planetary Protection Subcommittee (PPS). This had no oversight power and was increasingly ignored. By 2016 the PPS no longer served any purpose and in 2017 NASA formally disbanded it (Review and Assessment of Planetary Protection Policy Development Processes : page 26).

Then in 2017, NASA also closed down the planetary protection office which had some measure of independence and an advisory role for planetary protection. NASA’s planetary protection officer is now a member of NASA's Office of Safety and Mission Assurance (With planetary protection office up for grabs, scientists rail against limits to Mars exploration)

In 2018 the Space Study Board again recommended you reestablish such a committee.

Finding: The development and implementation of planetary protection policy at NASA has benefited in the past from a formally constituted independent advisory process and body. As this report is written, both the advisory body and process are in a state of suspension.

Recommendation 3.6: NASA should reestablish an independent and appropriate advisory body and process to help guide formulation and implementation of planetary protection adequate to serve the best interests of the public, the NASA program, and the variety of new entrants that may become active in deep space operations in the years ahead.

The advisory body and process should involve a formal Federal Advisory Committe Act committee and interagency coordination, as well as ad hoc advisory committees, if and as circumstances dictate. ….

The roles of the advisory body include the following:

  • Serve as a sounding board and source of input to assist in development of planetary protection requirements for new missions and U.S. input to the deliberations of COSPAR’s Panel on Planetary Protection;
  • Provide advice on opportunities, needs, and priorities for investments in planetary protection research and technology development; and
  • Act as a peer review forum to facilitate the effectiveness of NASA’s planetary protection activities.

(Assessment of planetary protection requirements for Mars sample return missions : Pages 67–8)

This was not done. Your mission plans have no peer review even internally from independent advisory planetary protection experts within NASA, and the effects of this deficiency show up throughout this EIS.

NASA HAS REMOVED ALL THE EXPERTISE AND OVERSIGHT THAT WAS NEEDED TO MAKE A SCIENTIFICALLY CREDIBLE ENVIRONMENTAL IMPACT STATEMENT - ALSO NEEDED TO ENSURE THAT SAMPLES RETURNED FROM MARS WILL BE CLEAN ENOUGH OF TERRESTRIAL LIFE TO BE USEFUL

This has consequences. By removing oversight from experts in planetary protection, NASA lost the expertise it needed to provide a scientifically credible EIS for planetary protection for a Mars sample return.

NASA has also lost a vital part of its team which would have helped ensure the samples you return would be of some value for making a start on the search for past and present-day life. The Space Studies Board put it like this:

A typical committee consists of only two or three individuals with direct experience of the issue to be addressed, with the balance of the membership being drawn from experts in related disciplines such as planetary science, environmental microbiology, and aerospace engineering. This approach has not compromised the quality of the resulting advice, but it does prolong the completion of the study, with additional time being required to educate those committee members unfamiliar with basic planetary protection concepts.

(Review and Assessment of Planetary Protection Policy Development Processes : Page 77)

Planetary protection is a specialist discipline of its own and even highly qualified experts in other areas of science may not be well grounded in the most basic concepts of planetary protection, as the Space Studies Board found out with each one of their many planetary protection reports.

I didn’t recognize any authors of papers on planetary protection for a Mars sample return amongst the authors listed as contributing to the EIS or the work of the sterilization working group. None of the major authors are there for sure.

NASA’S NEW FOCUS - THE PLANETARY PROTECTION OFFICER AS AN ENABLER TO GET HUMANS TO MARS AS QUICKLY AND SMOOTHLY AS POSSIBLE AND PIONEER OF A NEW WAY OF DOING PLANETARY PROTECTION FOCUSED ON THIS GOAL, UNLIKE THE PLANETARY PROTECTION OF THE PAST

NASA’s current planetary protection officer has no papers listed on a Mars sample return, planetary protection of Earth or the larger issues to do with planetary protection. His published research is focused on methods of implementing current minimum requirements for forward protection of Mars as you’d expect from the shift to NASA's Office of Safety and Mission Assurance. His main relevant research interest is ”Microbial detection in conjunction with contamination issues or life detection”

Research Interests

  • Microbial detection in conjunction with contamination issues or life detection
  • Microbial resistance of space environments, such as UV radiation
  • Development of new products and/or applications for molecular biology
  • Microbial Ecology of extreme environments

(James “Nick” Benardini III) (James Benardini list of publications on Google Scholar)

He sees his main role as enabling humans to get to Mars quickly. He wants other stakeholders to change as NASA change and become part of NASA’s new approach and philosophy for planetary protection.

Nick Bernadini: I think one of the key things we need from other stakeholders is open mindedness and a willingness to change as we change. This isn’t the Planetary Protection of the past — we are doing things differently. We have a different approach and philosophy. Just because we did it this way five years ago doesn’t mean it’s how we’re doing it now. People are still building up that trust to the new way Planetary Protection is doing things, so continued openness and willingness to help understand new ways of business and so on will be key.”

“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.

(SMA Leadership Profile: Nick Benardini)

Since NASA closed down the interagency panel that let other agencies comment on their proposals, this is now a one-way process.

NASA provides the leadership working out its plans in isolation. Once it’s decided what to do, other agencies have to adapt and change to NASA’s new way of doing things without any feedback to NASA about their views on the matter.

This may work short term with NASA’s dealings with the private space community and SpaceX. But it’s not going to work long-term with the broader scientific community and the public.

IF THERE IS LIFE ON MARS IT MAY BE AS HARMLESS FOR EARTH AS DANDELIONS IN THE USA - MOST INTRODUCED SPECIES ARE - BUT SOME INTRODUCED SPECIES ARE HARMFUL LIKE THE AFRICAN LAND SNAIL - WE NEED TO KNOW NOT GUESS

Many introduced species are harmless, an example would be the dandelion in the USA, it doesn’t harm American ecosystems, it just adds to the biodiversity.

“Although they may be tough to control in a traditional lawn, they are only listed as an invasive species in Alaska and Oregon. In most areas of the country there is a very low risk to pushing out native species and they provide no real damage to the ecosystem. In fact, they are an excellent food source for many of the native bees, insects and other wildlife.”

(Native, Non-Native, Invasive - and Dandelions! )

Text on graphic: If Mars has native microbial life, it may well be harmless to Earth like dandelions in most of the USA:

… no real damage to the ecosystem. In fact, they are an excellent food source for many of the native bees, insects and other wildlife.”

But they could be pests for agriculture like the Giant African Snail - or harmful to humans or the environment - we need to know, not guess.

(Dandelion - Dent-de-lion ou pissenlit)

(Snail in Ubud, Bali, 2010)

Microbes from Mars COULD be just as harmless as the dandelion, or at most a minor nuisance, indeed maybe most or even all would be. But as we’ll see, in some worst case scenarios, we could find microbes on Mars just as invasive and destructive of agricultural crops or ecosystems as the African snail and other invasive species on Earth.

AMERICA’S CURRENT ROLE AS A WORLD LEADER IN PLANETARY PROTECTION AND MARS EXPLORATION

UNDER NASA’S LEADERSHIP WE HAD MANY GEOLOGICAL SURPRISES ON MARS - WE NEEED TO BE PREPARED FOR ASTROBIOLOGICAL SURPRISES LIKE MIRROR LIFE THAT MAY NOT BE SAFE TO RETURN TO EARTH

NASA’s current planetary protection policy is based on an assumption that we will prove that there is either no life on Mars or that if there is any life on Mars it is harmless or even beneficial for Earth. But WE DON’T KNOW THIS. We need to look with clear eyes at the worst case scenario for humans on Mars.

We can’t assume the end result of this process is we prove Mars is safe for humans to visit and return.

It is fine to plan for

However we also need a contingency plan for other possibilities. I

Mars has had many geological surprises for us.

Mars may have astrobiological surprises for us too.

WE NEED TO BE PREPARED FOR BIOLOGICAL SURPRISES AS EXTRAORDINARY AS THE CO2 GEYSERS FOR GEOLOGY AND NOT RESTRICT OURSELVES TO HOPES AND PLANS THAT WILL WORK ONLY IF WE FIND FAMILIAR LIFE ON MARS

Text on graphic: Artist’s impression of CO2 geysers on Mars, one of many geological surprises.

Mars could have astrobiological surprises too.

What if Mars has independently evolved mirror life?

Artist’s impression by Ron Miller of the martial CO₂ geysers that form in spring in the polar regions (PIA08660: Sand-Laden Jets (Artist's Concept), JPL).

One example of what we might find is mirror life. Astrobiologists agree mirror life, all the chemicals of life flipped in a mirror and DNA and RNA spiralling the opposite direction - would work in the same way as ordinary life.

What we discover on Mars would not be terrestrial life flipped exactly but it may be life that evolved from the mirror chemicals in early Mars to a lifeform as complex as terrestrial life and using an analogue of DNA but with all the chemicals flipped as in a mirror. This would be an astonishing discovery for science and of great public interest but would mean we can never return microbial life safely from Mars unsterilized.

Why would we assume that Mars is uninteresting astrobiologically when we have had so many astonishing surprises by way of geology?

In this way - it’s good to prepare for harmless and familiar life on Mars, we also have to prepare for the possibility of future discoveries of exotic life and harmful life.

IF WE DISCOVER LIFE ON MARS THAT CAN NEVER BE RETURNED TO EARTH, IT WILL GREATLY ENHANCE PUBLIC INTEREST IN SPACE EXPLORATION

My preprint covers this too, how we can go forward. I find that this can invigorate and enhance space exploration and be a major motivation for space settlement of the moons of Mars, orbital missions around Mars and eventually further afield to the asteroid belt and Jupiter’s moon Callisto.

I count myself as a space enthusiast myself with a long-term interest in space exploration, space settlement and a keen reader of science fiction by the likes of Asimov through to Andy Weir. So this is an important part of the preprint for me personally too.

Since enabling human exploration of Mars is such a strong focus of NASA’s planetary protection policy today, I will conclude this open letter by presenting an alternative vision which is just as positive and inspiring for human space settlement and colonization enthusiasts like myself, with zero risk to Earth’s biosphere.

There is no shortcut to Carl Sagan’s “vigorous program of unmanned Martian exobiology”.

Carl Sagan: Because of the danger of back-contamination of Earth, I firmly believe that manned landings on Mars should be postponed until the beginning ofhd the next century, after a vigorous program of unmanned Martian exobiology and terrestrial epidemiology.

(, The Cosmic Connection – an Extraterrestrial Perspective )

This hasn’t happened. We haven’t sent anything to Mars to search for life since the Viking missions in the 1970s.

JOHN RUMMEL (FORMER NASA PLANETARY PROTECTION OFFICER): “WE DO NOT KNOW EVERYTHING WE WANT TO KNOW ABOUT MARS … WE DO NEED TO BE CAREFUL”

John Rummel, NASA planetary protection officer from 1986–1993, puts it like this as interviewed by Scientific American in 2022 after the first round of public comments on your proposals:

“In the first place, we don’t know everything we want to know about Mars. That’s why we want the samples.

We keep finding Earth organisms doing new things that are quite interesting from the standpoint of potential life elsewhere. So why don’t we think we need to be careful? The answer is that we do need to be careful, as repeatedly emphasized by the National [Academies]....

People have to have some kind of respect for the unknown. If you have that respect, then you can do a credible job, and the public is well-served by your caution.”

(Controversy Grows Over whether Mars Samples Endanger Earth)

(Curriculum Vitae John D. Rummel) [for his dates as NASA planetary protection officer]

CASSIE CONLEY (FORMER NASA PLANETARY PROTECTION OFFICER): WE ARE GOING TO CONTAIN THE SAMPLES AS IF THEY WERE THE MOST HAZARDOUS EARTH ORGANISMS WE KNOW ABOUT

Cassie Conley, former NASA planetary protection officer from 2006 - 2018:

“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

(Dr. Catharine Conley) [for her dates as NASA planetary protection officer]

Of course, we won’t find Ebola on Mars, it’s just an example to show how deadly the worst case could be. But in the worst case, we may find diseases of humans that are just as deadly. There are many illustrative examples in the planetary protection literature.

DISEASES NOT ADAPTED TO HUMANS LIKE TETANUS STILL KILL THOUSANDS OF UNVACCINATED NEWBORNS EVERY YEAR

The planetary protection literature mentions several diseases not adapted to humans or any higher life such as:

As a result of following up on the Candida example given by the sterilization working group, I’ve added another illustrative example

I cover these examples and more in my open letter to the CDC which I plan to send to them to help raise awareness in other US agencies.

. Open letter to CDC (draft) - MIDEDIT (PLEASE DON’T SHARE WIDELY, READY SOON)

As we’ll see later, the CDC are one of numerous agencies that the sample return studies say need to look at the plans once one agrees that there is a possibility of impact on human health in worst case scenarios (Assessment of planetary protection requirements for Mars sample return missions : Pages 67–8).

But so far NASA are not liaising with the CDC to make sure their Sample Receiving Facility protocols are adequate for alien life from anoner planet - at least they say nothing about doing so in the EIS.

MANY CANDIDATE TERRESTRIAL MICROBES COULD LIVE ON MARS WITH A SOURCE OF SALTY OR FRESH WATER - SUGGESTING SIMILAR MARS ANALOGUES COULD LIVE IN EARTH’S OCEANS OR SOILS

We now have many terrestrial organisms that do well in Mars simulation chambers including lichens, mosses, fungi, various bacteria, and algae. See: (Habitability of Mars: How Welcoming Are the Surface and Subsurface to Life on the Red Planet?)

This includes Chroococcidiopsis, a highly resilient blue-green algae which does well in Mars simulation conditions (Protection and Damage Repair Mechanisms Contributed To the Survival of Chroococcidiopsis sp. Exposed To a Mars-Like Near Space Environment).

This algae can be found almost everywhere on Earth from tropical reservoirs and oceans to cold dry deserts and even in complete darkness in gabbro 10 -750 meters below the Atlantic sea bed using an alternative metabolic pathway with hydrogen as a source of energy (Recycling and metabolic flexibility dictate life in the lower oceanic crust). Gabbro and basalt are amongst the most common rocks on both Mars and Earth.

Chroococcidiopsis is a pioneer “prime producer” that doesn’t depend on any other life and can find all its requirements in seawater, or rocks such as basalt, so long as it also has access to water and a source of energy such as sunlight. Strains of chroococcidiopsis do well in both hot deserts and very cold Mars analogue deserts in Antarctica (Ancient origins determine global biogeography of hot and cold desert cyanobacteria ), and also in warm wet conditions up to human body temperature, for instance in the upper throat behind the nose (Nasopharyngeal Microbiota as an early severity biomarker in COVID-19 hospitalised patients)

If Mars has an analogue of Chroococcidiopsis, a photosynthetic lifeform that lives in basalt and uses sunlight as an energy source it may already be adapted to survive on Earth and to proliferate and spread widely as it evolves to terrestrial habitats.

NEPA REQUIRES AGENCIES TO ENSURE SCIENTIFIC INTEGRITY - BUT PUBLIC COMMENTS ARE THE ONLY MECHANISM THEY REQUIRE TO ENSURE THIS - I’M ASKING FOR A RESPONSE TO HELP ENSURE NASA MAINTAINS SCIENTIFIC INTEGRITY IN THIS REPORT

As John Rummel said, we need respect for the unknown. NEPA requires agencies to ensure scientific integrity of the discussions and analyses in the EIS.

Agencies shall ensure the professional integrity, including scientific integrity, of the discussions and analyses in environmental impact statements
§ 1502.23 [Links directly to the legal text]

However, they have no mechanism to ensure scientific integrity except public comments. I commented on your first round of public comments on May 16. The draft EIS didn’t mention many serious issues I raised with your plans. I commented on the second round on November 28th, December 5th, December 13th and December 20th. These raise very serious issues with the scientific integrity of the EIS.

I emailed your point of contact Dr Alvin L,. Smith II on 18th December. I got no response.

MY PRELIMINARY SURVEY OF THE RECENT LITERATURE - THE LAST SAMPLE RETURN REVIEW WAS COMPLETED IN 2009 JUST BEFORE THE ANNOUNCEMENT OF THE PHOENIX LANDER LEG DROPLETS - IT’S GENERALLY AGREED NOW THAT THE PHOENIX LANDER TEAM OBSERVED DROPLETS OF COLD SALTY WATER

Since my unanswered email to you on 18th December, I’ve been working on a preliminary survey of the recent literature. This builds on research for a paper about planetary protection for NASA’s Mars sample return mission which was almost ready to send to academic journals at the time of my public comments last year.

The last thorough review is the NRC study, published in March 2009, just before the Phoenix team first published their observations of possible droplets of salty water on the Phoenix lander’s legs, later confirmed in simulation experiments as likely the first direct confirmation of (very cold) surface salty water on Mars. These are the droplets they simulated, coloured in green.

Possible droplets on the legs of the Phoenix lander – they appeared to merge and sometimes fall off. In this sequence of frames, the rightmost of the two droplets grows and seems to do so by taking up the water from its companion to the left, which shrinks - highlighted in green in this black-and-white photo from Mars (Liquid Water from Ice and Salt on Mars).

When Nilton Renno’s team successfully simulated these droplets in a Mars simulation chamber in 2014 he put it like this:

This is a small amount of liquid water. But for a bacteria, that would be a huge swimming pool – a little droplet of water is a huge amount of water for a bacteria. So, a small amount of water is enough for you to be able to create conditions for Mars to be habitable today. And we believe this is possible in the shallow subsurface, and even the surface of the Mars polar region for a few hours per day during the spring.

(How liquid water forms on Mars)(transcript from 1:48 onwards)

This discovery lead to many more indirectly detected or proposed salty brines on Mars, some of which may be habitable to Martian life.

MY LITERATURE SURVEY IDENTIFIED MANY TOPICS TO COVER IN DEPTH IN AN UPDATED MARS SAMPLE RETURN REVIEW BEFORE ANY AGENCY CAN DO A THOROUGH ENVIRONMENTAL IMPACT STATEMENT

The science has moved forward so much in the 14 years since 2009, including many proposed martian microhabitats, the surprising resilience of terrestrial microbes in Mars simulation chambers, new experiments in the transport of microbes and fragments of microbial biofilms in Martian winds, and new discoveries about terrestrial microbes living in Mars analogue cold dry deserts.

My preliminary literature survey identified many areas for review in an update of the 2009 study. I also added new illustrative backward contamination scenarios such as mirror life, to help focus attention of space agencies on the need to protect Earth.

See:

Almost none of this literature is mentioned in the EIS. One of the conclusions of my preprint is that NASA needs to commission another planetary protection back contamination review before it is feasible to do a thorough EIS for an unsterilized Mars sample return. If space agencies are serious about protecting Earth, they need to take account of the many new developments as a result of 14 years of research since 2009.

It would be possible to return samples sterilized before they reach Earth without such a review.

This open letter is another attempt to contact you with the main outlines of my preliminary literature survey in place.

YOU DON’T SUPPLY CREDIBLE EVIDENCE THAT MARS HAS BEEN UNINHABITABLE FOR MILLIONS OF YEARS - Could be used mistakenly to drop all precautions to protect Earth

This is one of three arguments in the EIS of central importance as precedent because others could use it to reason in good faith, but mistakenly, that we already know there is no life on Mars and so, that it is safe to drop all precautions to protect Earth’s biosphere from Mars samples.

You say

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).

(Mars Sample Return DRAFT EIS : 1–6)

EVEN YOUR OWN MOST RECENT CITATION FOR “EXISTING CREDIBLE EVIDENCE” IS THE OPPOSITE OF EVIDENCE, IT DESCRIBES SEARCHES FOR CURRENT HABITATS ON MARS!

Your most recent citation for “existing credible evidence” is about a search for current habitats on Mars!

“The exploration of … Mars … will help establish whether localised habitable regions currently exist within these seemingly uninhabitable world”.

(Origins, Worlds, and Life: A Decadal Strategy for Planetary Science and Astrobiology : page 393 [Click on the X to close the splash to go straight to page 393])

This is a screenshot of that page (for video presentation).

NASA’s most recent citation for “Existing credible evidence suggests that conditions on Mars have not been amenable to supporting life as we know it for millions of years” is about a search for CURRENTLY HABITABLE ENVIRONMENTS on a seemingly uninhabitable world.

ONE OF NASA’S MAIN GOALS FOR MARS EXPLORATION IS TO SEARCH FOR PRESENT DAY LIFE (SECOND HALF OF GOAL 1)

But one of your own science goals has the search for present-day life and habitats as the second part of Goal 1 in your 2020 update of the Mars exploration program science goals!

Goal 1: Determine if Mars ever supported or still supports, life,

(MEPAG Science Goals, Objectives, Investigations, and Priorities : page 9)

ONE OF THE MAIN GOALS FOR THESE VERY SAMPLES IS TO SEARCH FOR PRESENT DAY LIFE, OBJECTIVE 2.3

It is also objective 2.3 for the Mars samples, to test to see if there is any evidence for present-day life - in the very samples Perseverance is caching and that you plan to return with this mission in the 2030s.

2.3 Modern biosignatures: Assess the possibility that any lifeforms detected are still alive or were recently alive.

(Planning implications related to sterilization-sensitive science investigations associated with Mars Sample Return (MSR) : table 2)

This table is based on the conclusions of the iMOST team (International MSR Objectives and Samples Team). [MSR = Mars Sample Return]

THE IMOST TEAM SAID THAT THE PROBABLY OF DISCOVERING PRESENT DAY LIFE IN THE SAMPLES IS LIKELY VERY LOW, BUT ITS DISCOVERY WOULD BE SO PROFOUND THAT WE NEED TO SEARCH FOR IT IN THE RETURNED SAMPLES

The objectives described by iMOST are now NASA official policy for the returned samles - the iMOST conclusions were adopted in the final report the Mars Sample Return Science Planning Group in 2022.

The scientific objectives of MSR are comprehensively described by iMOST

(Final Report of the Mars Sample Return Science Planning Group 2 (MSPG2) : page S-21)

The iMOST team say the probability of discovering present-day life at the Martian surface is considered to be low, but it would be such a profound discovery we need to look for it.

The probability of discovering extant life at the Martian surface (including by means of MSR) is generally considered to be low. However, its discovery would be so profound that it would shake the pillars of science. It would yield insight into the very fundamentals of life such as what are the basic universal properties of living systems … and how life evolves

(The potential science and engineering value of samples delivered to Earth by Mars sample return: International MSR Objectives and Samples Team (iMOST) : Page 86)

IMOST FIND PRESENT-DAY LIFE ON MARS PLAUSIBLE BECAUSE OF THE MANY NEW DISCOVERIES AND PROPOSALS FOR POTENTIAL HABITATS ON MARS AND NEWLY DISCOVERED CAPABILITIES OF TERRESTRIAL LIFE

The iMOST team find present-day life on Mars plausible, because of (pages 86–7)

They conclude that native life on Mars may be able to adapt and evolve to the local conditions. See (iMOST : page 87)

NASA PLAN TO DO MANY TESTS TO TRY TO FIND PRESENT-DAY LIFE IN THE RETURNED SAMPLES INCLUDING TESTS FOR MICROBIAL RESPIRATION AND TO TESTS TO TRY TO GET ANY MARTIAN LIFE TO GROW IN CULTURE MEDIA

To search for present day life they will

(iMOST : page 91)

NASA would then use a similar strategy to the Viking labeled release. Add some of the samples to a growth medium and see if there is any sign of microbes that use the organics and produce evolved gases like CO2 or methane. They would do that by replacing some of the carbon with Carbon 13, nitrogen with Nitrogen 15 and hydrogen with deuterium so they can keep track of what happens with the atoms in the growth medium.

(iMOST : page 92)

This would be a major advance over Viking which couldn’t even detect if the evolved gas was methane or carbon dioxide, or something else.

Then finally they would attempt to get any Martian life to replicate. If they do succeed in this, they would study the cells and look also for any structures they might be using to move around (this would include the flagella, long filaments that which terrestrial microbes often use to swim).

They conclude:

Success in cultivating organisms from Martian samples would be the ultimate proof of extant life. On Earth we can only culture a few percent of all environmental microorganisms because it is difficult to predict and reproduce conditions amenable to growth. We expect that Martian organisms would be no less recalcitrant. Therefore, it is critical that growth experiments be conducted under conditions present at the sample site.

(iMOST : page 93)

So, though the iMOST team think the chance of present day life is likely low, they recommended that NASA do extensive tests to try to find present-day Martian life in the samples.

WAS THERE A LACK OF COMMUNICATION BETWEEN THE LIFE DETECTION TEAM FOCUSING ON PRESENT-DAY LIFE ON MARS AS THEIR BEST CASE, AND ENGINEERS AND MISSION PLANNERS FOCUSING ON AN UNINHABITABLE MARS AS A WAY THE MISSION COULD BE ACCOMPLISHED MOST EASILY? WHATEVER THE CAUSE WE NEED TO FIX THIS FOR FUTURE EIS’S

So - going back to NASA’s sentence in the EIS:

Existing credible evidence suggests that conditions on Mars have not been amenable to supporting life as we know it for millions of years

(Mars Sample Return DRAFT EIS : 1–6)

A more accurate statement would be

The probability of discovering extant life at the Martian surface is generally considered to be low, but there is enough of a chance of life in the Perseverance samples that NASA plans to test for living organisms in it.

(iMOST : page 86)

NASA’s draft EIS does refer to the iMOST team objectives (Mars Sample Return DRAFT EIS : 1–11) saying:

The science potential of samples delivered from Mars was most recently re-evaluated by the international MSR Samples and Objectives Team (iMOST), which was active from 2017 to 2018

However, it doesn’t mention the interest in searching for present day life.

Why doesn’t your draft EIS mention that NASA plans to test the returned samples to see if there is any present-day Martian life in them?

It could be a simple lack of communication between the engineering team and the life detection scientists. Such things happen, like the mix-up that led to the loss of the Mars Climate Orbiter which crashed into Mars in 1999 (In Depth | Mars Climate Orbiter – NASA Solar System Exploration).

Or maybe it is optimism about their respective goals.

For scientists devising experiments to look for life, the most interesting outcome by far is present-day life. The iMOST authors recommend NASA to test for present-day life even if it may be unlikely, because it would be such a major discovery.

For engineers and mission planners preparing protocols to protect Earth, the less the risk, the lower the cost of the mission. So, it is natural for optimistic planners to find it more plausible that Mars has been uninhabitable for millions of years, as this will likely reduce the cost of the mission and make mission planning simpler.

LOOKING TO THE FUTURE WE NEED MORE FUNDING FOR PLANETARY PROTECTION - THOUGH FOR THIS MISSION WE’LL FIND THERE IS A WIN WIN WIN SOLUTION TO CONSIDER THAT SAVES ON COSTS, INCREASES SCIENCE RETURN AND KEEPS EARTH 100% SAFE

Whatever the reason, if we take the protection of Earth seriously it is important to look carefully at worst-case as well as best-case scenarios. If we do that, just look clearly at the data as it is, we can get surprises. We may find a “win win win” solution that optimizes all our goals at once.

I end this open letter with exactly such a proposal (with bonus samples) as mentioned in the intro to this open letter

We need to look at costs not just to NASA but to the Earth for the worst-case scenario where Earth’s biosphere or human health is harmed. Perhaps this needs extra legislation to mandate NASA to spend extra if necessary to protect Earth? It’s understandable that NASA mission planners are motivated above all by the need to reduce cost for their missions. But I’d argue that in this case - AND in the forwards direction - the world is better saved by a space agency that has extra funding to ensure it does planetary protection properly. It seems perverse for NASA to have strong financial incentives to skimp on planetary protection.

My conclusions were that it seems that this mission can likely be made 100% safe at no extra cost with more science return. However, in the larger picture we may need more funding for planetary protection.

The Viking mission cost an extra 10% in order to protect Mars from terrestrial contamination (Cost of Planetary Protection Implementation : page 3) (Review and Assessment of Planetary Protection Policy Development Processes : page 35) which seems an appropriate figure, for missions that need it.

No mission since then has allocated anything like 10% of its funding to protect against forward contamination. Typical planetary protection costs range from 0.4% to 1.1% (Cost of Planetary Protection Implementation : page 3). We surely need a % at least as large available to protect against backwards contamination IF IT IS NEEDED. It could be an extra ring-fenced budget at 10% per mission that can be drawn on as needed for planetary protection.

That is a matter for public debate.

Meanwhile, as a matter of scientific integrity, it seems important to find a way to guard against similar mishaps in future environmental impact statements for Mars sample return missions and an EIS will need to look at reasonable alternatives that keep Earth 100% safe. If any proposals that would be safer for Earth’s biosphere are rejected for reasons of cost, this needs to be explained to the public.

WE NEED TO GET THIS RIGHT - ESPECIALLY BECAUSE OF NASA’S (USUALLY DESERVED) REPUTATION FOR SCIENTIFIC INTEGRITY - CHINA, SPACEX OR ANOTHER ENTITY COULD USE YOUR EIS IN GOOD FAITH TO DROP ALL PRECAUTIONS

This is one of three arguments in the EIS of central importance as precedent. Though you don’t use it this, way, another country or private space might use the statement in your EIS to argue in good faith, but mistakenly, that Mars is as uninhabitable as the Moon. They might then see no need to take any precautions to protect Earth.

This is of especial importance because of the high regard NASA enjoys internationally for scientific integrity and rigour – normally a well-deserved reputation.

So you need to get this right. WE DO NOT KNOW THAT MARS IS UNINHABITABLE at this moment in time, and your own citation and your own mission objectives for the samples returned from Mars contradicts your conclusion.

NASA NEED TO BE VERY SURE THAT MICROBES FROM MARS CAN GET HERE WITH BETTER PROTECTION AND FASTER TRANSIT IN A METEORITE - Could be used mistakenly to drop all precautions to protect Earth

This is the second of your main arguments that others could use to drop protection of Earth’s biosphere. Other space agencies and private space could use your reasoning to argue in good faith, but mistakenly, that we know any life in their samples got here already. So NASA needs to be very sure to get this right.

You say in the EIS that any life in Jezero crater will get here better protected and faster in a meteorite than in a sample tube.

The natural delivery of Mars materials can provide better protection and faster transit than the current MSR mission concept. …. 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),

(MSR FINAL EIS 3–3)

MOST TERRESTRIAL MICROBES COULDN’T GET FROM MARS TO EARTH - AND THE SURFACE DUST, DIRT, SALT AND BRINES MECHANICALLY COULDN’T GET INTO A METEORITE

It is not credible that most microbes could get here better protected and faster in a meteorite. To get here in a meteorite a microbe has to get into it first. Large meteorites hit Mars every few hundred thousand years and the ejected rocks we have from Mars come from at least 3 meters below the surface.

Mileikowsky et al., authors of a seminal paper on modern lithopanspermia (transfer of microbes between planets inside rocks), say most microorganisms known wouldn’t be able to travel through space:

Whereas this harsh environment sets a definite barrier for most microorganisms known, some have developed survival strategies, by transforming into a dry state, the so-called anhydrobiosis ..., or by producing spores, the dormant state of certain bacteria

Concomitantly with their resistance to the adverse effects of drying, microorganisms in anhydrobiosis or spore stage are resistant to the effects of freezing to very low temperatures, elevated temperatures for brief periods, and the effects of ionizing. These characteristics make spores and anhydrobiotic bacteria especially prepared for coping with the extreme conditions of space

(Natural transfer of viable microbes in space: 1. From Mars to Earth and Earth to Mars : page 401)

For unrelated life, we can’t assume any of it ever got here. The iMOST team said:

We cannot predict with any accuracy life's form and characteristics, … or whether it shares a common ancestor with life on Earth. (iMOST : Page 88)

…

A subset of the investigations will only be successful at detecting Mars life if it shares a common ancestor with Earth life due to travel on meteorites or space debris, whereas other suggested investigations are based on more general characteristics of living entities. (iMOST : Page 89)

As for getting here faster, the most recent opportunity for any life to get from Mars to Earth was after the impact that formed the Zunil crater on Mars around a million years ago (direct crater count suggests 700,000 years ago) (Hartmann et al, 2010).

Any samples returned by Perseverance will get here in far less time than the approximately 700,000 years since the last meteorite was ejected from Mars to Earth.

YOUR OWN CITATION FOR “POTENTIAL MARS MICROBES WOULD BE EXPECTED TO SURVIVE EJECTION FORCES AND PRESSURE” SAYS SAMPLES MIGHT COME FROM “SITES THAT MECHANICALLY CANNOT SURVIVE EJECTION FROM MARS“ AND SAYS ITS RECOMMENDATIONS DO NOT APPLY TO SAMPLES FROM MARS

Your own citation for "potential Mars microbes would be expected to survive ejection forces and pressure" makes this very point.

. …. 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),

. MSR FINAL EIS 3–3

Your cite there is a study of planetary protection requirements for Mars’s moon Phobos. Any life in samples from Phobos has already survived ejection from Mars. But samples from Mars are in a very different situation.

It says that potential Mars microbes in some surface materials (like dust and dirt and salt) would NOT even get into a meteorite.

"MSR [Mars Sample Return] 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"

(Planetary protection classification of sample return missions from the Martian moons : page 5 [use X to close splash])

There is a minor typo on this page, “Mars” for “Phobos” which could conceivably partly explain the confusion, and why this was selected as a citation for the EIS statement?

NASA's citation for "potential Mars microbes would be expected to survive ejection forces and pressure" says "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"

The Phobos sample return study covers this reasoning in more detail on page 44-5. On the last point they say:

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.

Samples with current liquid water and recent ice seem especially fragile to natural transport to Earth.

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.

[Added bullet points to the original text]

(Planetary protection classification of sample return missions from the Martian moons : page 44-5. [use X to close splash])

The meteorites from the Zumil impact arriving today are better protected than Phobos samples, because any materials on the Phobos surface had the extra sterilization stage of the impact on the surface of Phobos which the team worked out is more sterilizing than the fireball of re-entry to Earth’s atmosphere.

The meteorites from Zumul crater also get here faster than any materials in samples from Phobos because the most recent samples in the Phobos samples were ejected from Mars by the same impact and have been sitting on the surface of Phobos subject to cosmic radiation sterilization ever since.

This would be a more accurate summary of NASA’s citation:

The natural delivery of Mars materials can provide better protection and faster transit than the Japan’s samples from the top 2 cms of the surface of Phobos but this reasoning does NOT apply to samples from Mars

… potential Mars microbes could be in habitats that can’t mechanically get into meteorites or unable to survive ejection forces and pressure or transfer through space.

(National Academies of Sciences, Engineering, and Medicine and the European Science Foundation 2019)

In short, NASA’s citation is a planetary protection study for samples returned from Mars’s moon Phobos and says clearly that it shouldn’t be used to support a meteorite argument for samples from Mars itself. It says it shouldn’t be used to support the very argument you use it as a citation for.

This is a particularly clear case. To use it in this way without alerting the reader to the discrepancy fails NEPA requirements for scientific integrity.

The EIS doesn’t alert the reader to this discrepancy.

TO PROVE NO POTENTIAL INVASIVE MICROBES IN OUR SAMPLES WE NEED TO PROVE ALL (NOT JUST SOME) SPECIES CAN GET HERE ON A METEORITE - ANALOGY: STARLING IS AN INVASIVE SPECIES IN THE USA BUT THE SWALLOW IS NOT BECAUSE IT CAN CROSS THE OCEAN

Since most terrestrial microbes can’t get from Mars to Earth, it’s not very plausible that in ALL possible scenarios for Martian life, ALL species of martian microbes would be able to get from Mars to Earth - yet that’s what would be needed to prove we can’t have invasive species from Mars in the samples.

I give the example of swallows and starlings in my preprint. The barn swallow is not an invasive species as it was already here, because it can fly across the Atlantic. However, European starlings can’t fly across the Atlantic, which is how they could become an invasive species in the USA. The Department of Agriculture estimates that starlings cost the US economy $1 billion a year for agricultural damage alone.

Starling damage reported to the USDA’s Wildlife Services program averages less than $2 million per year, but this is a fraction of all starling damage. Agricultural damage alone is estimated currently at $1 billion per year. Other damage, such as costs for cleaning and maintaining city centers near roosts, veterinary care and loss of production at CAFOs, and public health care, are unknown. A complete inventory of all economic damage likely would show that the starling is the most economically harmful bird species in the United States

(European Starling : 16).

Text on graphic: Some microbes may be able to get from Mars to Earth – what matters for invasive species are the ones that can’t.

Barn swallow - can cross Atlantic

Starling - invasive species in the Americas

Didymosphenia geminatum invasive diatom in Great Lakes and New Zealand, can’t even cross oceans

This doesn’t mean that all European birds would be invasive in a harmful way. Introductions can often be beneficial (The potential conservation value of non‐native species).

But if a species can’t cross the Atlantic it has the potential to be invasive.

IT’S THE SAME PICTURE FOR MICROBES - MANY CROSS OCEANS AND ARE NOT INVASIVE - BUT FRESH WATER DIATOMS CAN’T CROSS OCEANS AND HAVE BEEN INVASIVE IN THE GREAT LAKES AND ARE INVASIVE TODAY IN NEW ZEALAND

Didymo in the illustration in the last section is an invasive species of fresh water diatom in New Zealand. A few decades back the Great Lakes had many problems with non indigenous invasive diatoms that clogged up water treatment plants and caused bad smells in drinking water which shows that microbial life can be invasive too (Diatoms as non-native species)

Just as it’s microbes that can’t cross oceans that have some potential to be invasive on Earth, it’s any microbes that can’t cross the cold and vacuum of space and can’t survive ejection from Mars or get into a meteorite that are the ones that have some potential to be invasive introductions to Earth’s biosphere.

This again is of central importance.. Another country or private space might use NASA’s statement to argue in good faith, but mistakenly, that any life from Mars has already got to Earth.

The natural delivery of Mars materials can provide better protection and faster transit than the current MSR mission concept.

. MSR FINAL EIS 3–3

They might then see no need to take any precautions to protect Earth.

WE DO NOT KNOW THAT ANY SPECIES ON MARS HAVE EVER BEEN TRANSFERRED TO EARTH IN A METEORITE and as we saw, your own citation says it shouldn’t be used for this argument (Planetary protection classification of sample return missions from the Martian moons : page 5 and page 43 [use X to close splash])

THE EIS FOCUSES ON BEST-CASE SCENARIOS - INDEED SAMPLES CAN BE HARMLESS IN MANY WAYS - BUT NEVER MENTIONS WORST-CASE SCENARIOS - LIKE DESIGNING A SMOKE DETECTOR WITHOUT CONSIDERING THE WORST CASE OF A HOUSE FIRE

Your EIS considers a best-case where

I will show in this open letter that NONE of these statements are supported by your citations. The EIS doesn’t alert the reader to many ways these assumptions could be invalid.

If this is not challenged, other space countries and private space may well use your arguments to infer in good faith there is no need to take ANY precautions for samples returned from Mars.

There are lots of ways that the sample returned from Jezero crater COULD be harmless.

However, despite the statements in your EIS, we DO NOT KNOW ANY OF THESE THINGS.

GENERAL PUBLIC FOCUS MORE ON RISKS; MISSION PLANNERS ON MISSION REQUIREMENTS - A PRE-STERILIZED RETURN SATISFIES BOTH

Margaret Race made a relevant point in another paper. To summarize her main points she says scientists are likely to focus on

So it is natural for you to focus on those.

The general public are likely to focus on

(Planetary Protection, Legal Ambiguity, and the Decision-Making Process for Mars Sample Return : page 348)

We see the results of this different focus in the report.

Let’s look at another example:

THE EIS IS INCORRECT WHEN IT SUGGESTS JEZERO CRATER IS BIOLOGICALLY ISOLATED FROM THE REST OF MARS - FRAGMENTS OF MICROBIAL BIOFILMS ARE STILL VIABLE AFTER BLOWN HUNDREDS OR EVEN THOUSANDS OF KILOMETERS IN EXPERIMENTAL TESTS

NASA: (paraphrase) If there is life on Mars it can’t get into Perseverance's samples in Jezero crater:

“Consensus opinion within the astrobiology scientific community supports a conclusion that the Martian surface is too inhospitable for life to survive there today, particularly at the location and shallow depth (6.4 centimeters [2.5 inches]) being sampled by the Perseverance rover in Jezero Crater, which was chosen as the sampling area because it could have had the right conditions to support life in the ancient past, billions of years ago. (Rummel et al. 2014, …)”

.. MSR FINAL EIS 1–6

MARS MAY HAVE MANY ASTROBIOLOGICAL SURPRISES THAT COULD BE A SOURCE FOR BIOFILMS BLOWN IN THE DUST STORMS AND NIGHT-TIME WINDS - SUCH AS ANALOGUES OF THE CRYOCONITE HOLES = MINIATURE GREENHOUSES WITH AN ICE LID - IN THE MCMURDO DRY VALLEYS IN ANTARCTICA

Cryoconite holes are one of many proposed terrestrial analogue habitats for Mars that I found in the literature survey that have a strong rationale but has had little attention in the Mars exploration community. They are common in the McMurdo dry valleys in Antarctica, one of our closest Mars analogue habitats on Earth. Calculations show that they should also form on Mars but would be impossible to detect from orbit. They are of especial interest as a way that present day Mars could have small quantities of fresh water - but not that small, over the entire ice cap this and other ways of providing subsurface ice melt such as liquid water around embeded meteorites in the ice could provide a total of many thousands of cubic kilometers of fresh water on Mars.

Cryoconite holes form when dust blown in the wind lands on ice in Antarctica. Heated by the sun the dust gradually sinks into the ice and as it sinks, an ice layer forms above it making a miniature greenhouse heated by the sun. Sunlight gets through the transparent ice above it but the heat is trapped. Fountain et al. found with rough calculations that the cryoconite holes contribute at least 13% of the meltwater for Canada glacier in the McMurdo dry valleys (Evolution of cryoconite holes and their contribution to meltwater runoff from glaciers in the McMurdo Dry Valleys) Cryoconite holes provide a refuge for life in ice sheets, rich in microbes such as mats of various types of cyanobacteria, bacteria, algae, and higher life such as rotifers and tardigrades (Ice shelf microbial ecosystems in the high arctic and implications for life on snowball earth) The algal mats in the cryoconite holes are as productive as algal blooms in the polar seas (ibid, page 141). This shows how it works:.

Two ice covered cryoconite holes on the left and sketch of how they work on the right (Measuring and modeling evolution of cryoconite holes in the McMurdo Dry Valleys, Antarctica)

These cryoconite holes have been proposed as a way that life could survive and propagate in the polar ice caps on Mars, as well as possibly comets and Europa (Microorganisms on comets, Europa, and the polar ice caps of Mars) (The search for a signature of life on Mars: a biogeomorphological approach : 14)

- OR FROM ICE BOULDERS ON THE FLANKS OF OLYMPUS MONS EXCAVATED BY AN IMPACT IN 2022 FROM METERS BELOW THE SURFACE

We don’t know that the cryoconite holes exist on Mars and likely won’t know until we can send landers to explore the ice sheets close up. But we have found recently exposed ice boulders from crater impacts on Mars. in this remarkable photograph from NASA’s Mars reconnaissance orbiter of a crater that was detected by the small earthquake tremors it generated as it impacted on Mars by NASA’s Insight Lander.

(, NASA’s InSight Lander Detects Stunning Meteoroid Impact on Mars )

Simulated flyover of it here

https://www.youtube.com/embed/NR7QCUit-do

This crater threw up boulders from the subsurface of the Amazonis Planitia region on the flanks of Olympus Mons, the largest known volcano in the solar system which has been geologically active recently and is clearly not yet dormant. This is especially interesting for recent or even maybe present day life because lava flowed there less than 24 million years ago.

Fuller et al. suggest that if here was life there at the time, perhaps living below the surface in subsurface groundwater at the time of the lava flows, it’s highly likely it erupted to the surface, where standing water formed briefly. Any standing water would freeze over rapidly and the ice evaporate into the thin atmosphere leaving traces of any life on the surface where we may be able to detect it still today (: The role of geologically recent volcanism and sedimentation in the formation of the smoothest plains on Mars. ) This is also a region with rootless cones (volcanic cones without a magma chamber below them) active even more recently, some as recently as 10 million years ago (. Rootless cones on Mars indicating the presence of shallow equatorial ground ice in recent times. ). Rootless cones may have had hydrothermal systems above 0 C for up to 1,300 years (. . Explosive lava‐water interactions in Elysium Planitia, Mars: Geologic and thermodynamic constraints on the formation of the Tartarus Colles cone groups.. ) Then depending on how geologically active Mars is today, there may be subsurface caves with life there even today.

Present day life could get there from below or it might reach the region as viable spores or propagules in the dust, dirt or bouncing dust grains.

Some of the bouncing sand grains would fall on the ice boulders, and they would then be warmed by the sun. If they form miniature melt ponds they could melt their way down into the ice (called cryoconite holes), maybe to the point where the melt pond freezes over to trap liquid water similarly to the way the cryoconite holes freeze over in the McMurdo dry valleys in Antarctica, again like the suggestion for the polar regions of Mars. The sand grains might bring life with them.

Based on this technology we can also build Mars copters, miniature landers, gliders, Mars aerostats (balloons), cave hoppers and rovers to send to the regions of Mars most vulnerable to forward contamination in the knowledge that there is no life on any of them, 100% confident. The rovers won’t need to be contained in anything either. They can just be heated for a few minutes any time after they leave Earth’s biosphere, even after they are released from the “mother ship” and before they change course to a trajectory to land them on Mars.

THE EIS DOESN’T CITE THE SPACE STUDIES BOARD REVIEW FROM 2015

Your EIS doesn’t cite the Space Studies Board review in 2015 which found knowledge gaps in SR-SAG2 about transport of life in the atmosphere and a potential for habitats even in places like Jezero Crater that may be impossible to see from orbit.

Rummel et al. is the 2014 SR-SAG2 review (A new analysis of Mars “special regions”: findings of the second MEPAG Special Regions Science Analysis Group (SR-SAG2)) [Their second source for this sentence, Grant et al, is just a cite for the selection criteria for Jezero crater]

SR-SAG2 uses maps to map out uncertain regions that may contain “Special regions” which are defined as regions (SSB, 2015 :6).

“within which terrestrial organisms are likely to propagate, or a region which is interpreted to have a high potential for the existence of extant martian life forms.”

(Review of the MEPAG report on Mars special regions :6).

It doesn’t discuss the potential for Martian life so that already is a limitation for backwards contamination since Martian life might conceivably be capable, for instance, be able to live in cold salty water beyond the limits for terrestrial life. It just says:

At present there are no Special Regions defined by the existence of extant martian life, and this study concentrates only on the first aspect of the definition.

(SR-SAG2 : 888)

NASA and ESA commissioned a review in 2015 by the Space Studies Board, ESSC and NASEM, which found serious knowledge gaps in the 2014 SR-SAG2 review which you rely on here and especially the way it relies on maps from orbit.

Text on graphic: SR-SAG2 recognizes the need for buffer zones around the RSLs …

but MEPAG Review says it
- doesn’t adequately discuss transport of life in Martian atmosphere [ e.g. dust]
- only briefly considers implications of our lack of knowledge of new microhabitats impossible to see from orbit [microscale conditions]

[paraphrases (Review of the MEPAG report on Mars special regions :11 - 12) ]

Map from: (A new analysis of Mars “special regions”: findings of the second MEPAG Special Regions Science Analysis Group (SR-SAG2) : Fig. 47 )

Perseverance landing site marked

THIS REVIEW WAS COMMISIONED BY NASA AND ESA PARTLY ABOUT CONCERNS THAT MEPAG IS NOT INDEPENDENT OF NASA AND ITS VIEWS ARE TOO CLOSELY ALIGNED WITH NASA’S MARS PROGRAM OFFICE

NASA and ESA were planning independent reviews and finding both had the same concerns combined it in a single review. They commissioned this review partly out of concerns that MEPAG is not independent from NASA.

There were two reasons why both agencies [NASA and ESA] took the seemingly unusual step of independently commissioning reviews of a review paper that was to be published in a peer-reviewed journal.

First, there is the perception in some circles that MEPAG is not independent and that its views are too closely aligned with NASA’s Mars Program Office.

(Review of the MEPAG report on Mars special regions: xi – xii).
[by the Space Studies Board, the European Space Sciences Committee and the National Academies of Sciences, Engineering, and Medicine]

With this background it is a very serious omission for NASA’s EIS to cite the 2014 study and not cite the 2015 review which was commissioned precisely because of the lack of independent voices within NASA to highlight issues with its 2014 review.

THE SPACE STUDIES BOARD FOUND SEVERAL KNOWLEDGE GAPS SPECIFICALLY IN THE RESEARCH THAT NASA RELIES ON FOR THIS EIS - SUCH AS A KNOWLEDGE GAP ABOUT TRANSPORT OF VIABLE LIFE IN THE ATMOSPHERE - LATER CONFIRMED BY BILLI ET AL AND OTHERS

This review found that SR-SAG2 doesn’t adequately discuss the transport of material in the Mars atmosphere [e.g. in dust storms] see page 12.

This is indeed a knowledge gap. Amongst several relevant discoveries, later research found that small fragments of biofilm, thin layers of a microbial colony three hundredths of a millimeter thick, can travel 100 kilometers in daylight in the light Martian winds before it is sterilized.

See A desert cyanobacterium under simulated Mars-like conditions in low Earth orbit: implications for the habitability of Mars

Billi et al’s paper on biofilm transport doesn’t take account of the effect of UV on perchlorates in the biofilm, but in my paper I find

(An Overview of Biofilm Formation–Combating Strategies and Mechanisms of Action of Antibiofilm Agents : Figure 1)

We should mention experiments by Wadsworth et al which highlighted the biocidal effect of perchlorates activated to cholorates and chlorites by UV. This is something to consider but the experiment had many limitations.

It was tested at normal atmospheric pressure though in absence of oxygen. It was tested at 25 C and 4 C, high temperatures for Mars.

The chemical nature of this bacteriocidal effect is confirmed by carrying out the experiment at 4 °C, when the loss of viability is over ten times lower than at 25 °C, suggesting that lower temperatures lower the rate of the chemical reaction or the diffusion of activation products and reduce the rate of bacteriocidal effects. Nevertheless, the effect is still observable

They only tested b. subtilis. Other terrestrial extremophiles could be more resilient. They found that it was reduced in rock analogues

The effect is less pronounced within the rock analogue system likely caused by screening within the rock, which reduces the penetration of UV radiation compared to the liquid system.

The rock analouge system consisted of:

“sintered discs of silica grains commercially produced to give a pore size of 100–160 µm”

(Perchlorates on Mars enhance the bacteriocidal effects of UV light)

Also they didn’t test a biofilm.

Other experiments show microbes could be viable after transport in bouncing sandgrains [NEEDS CITE]

This leads to an intriguing possibility. If microbial life can be transferred in dust storms - but perhaps rarely and only some species make it, perhaps every 100,000 to 500,000 years, then Mars could have islands of habitability for microbial life with some species common to all the regions but others diversify into niche species that can’t be transported far in the dust storms and that have evolved locally for millions of years or more. This is based on David Steadman’s suggestion for the dispersal of bird life in island communities who suggests a timescale of 100,000 to 500,000 years for the first birds to get to a new island and then slow collinization by fewer and fewer species. If Mars had a similar situation for microbes it could be exceptionally biodiverse on the microbial level for such a desert landscape [MY OWN SUGGESTION]. It might also have independently evolved life in regions that can’t be reached by dispersal via dust storm perhaps including cave systems that survive from past hydrothermal events with large areas of liquid water.

(Extinction and Biogeography of Tropical Pacific Birds)

SR-SAG2 ONLY BRIEFLY CONSIDERED OUR LACK OF KNOWLEDGE OF MICROENVIRONMENTS - WITH A USEFUL LIST OF THE TYPES OF MICROENVIRONMENTS POSSIBLE ON MARS

The 2015 Space Studies Board review also found that SR -SAG2 only briefly discussed the implications of our lack of knowledge of microenvironments.

(Review of the MEPAG report on Mars special regions : 12 )

SR-SAG2 gave a useful list of these microenvironments by type:·

(A new analysis of Mars “special regions”: findings of the second MEPAG Special Regions Science Analysis Group (SR-SAG2): page 204)

However, it doesn’t discuss them much further. These potential microenvironments on Mars have been the subject of many research papers which the EIS doesn’t discuss.

To take an example, that may be relevant to Jezero crater, terrestrial microbes can exploit water that condenses in micropores in salt or gypsum in deserts when the rest of the desert air is far too dry for life. Your former planetary protection officer Cassie Conley suggested that the same thing might happen on Mars. (Going to Mars Could Mess Up the Hunt for Alien Life) as did Paul Davies (The key to life on Mars may well be found in Chile) and Wierzchos et al. (Microbial colonization of Ca‐sulfate crusts in the hyperarid core of the Aacama Desert: implications for the search for life on Mars).

THE SSB REVIEW DREW ATTENTION TO BIOFILMS WHICH CAN MAKE REGIONS MORE HABITABLE - ONLY MENTIONED IN ONE SENTENCE IN SR-SAG2

The SSB review also drew particular attention on page 11 to the capability of microbes to use biofilms to make regions habitable that wouldn’t be otherwise.

The Atacama gritcrust would be an example here (The grit crust: A poly-extremotolerant microbial community from the Atacama Desert as a model for astrobiology)

For scientific integrity your Environmental Impact Statement needs to cite the 2015 review and discuss what it says. This is especially important since the 2014 SR-SAG2 was seen as too closely aligned with the aims of NASA’s Mars Program Office, as one of the two main reasons for the 2015 review.

Also it needs to recognize that these weren’t backwards contamination studies and didn’t consider the question of what might count as a habitat for an alien biology. In all these examples we need to bear in mind that if there is Martian life, it has adapted to those conditions for billions of years and may be based on a different biochemistry with capabilities terrestrial biochemistry doesn’t have.

YOUR STERILIZATION WORKING GROUP’S CONCLUSION THAT MARTIAN LIFE HAS NEAR-ZERO PROBABILITY OF HARM FOR HUMANS IS NOVEL AND CONTRADICTS PREVIOUS PEER-REVIEWED LITERATURE ON MARS SAMPLE RETURN

Your sterilization working group comes to a conclusion that is not found in any previous peer-reviewed study on Mars sample return backward contamination.

“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 in the context of backward planetary protection and Mars Sample Return: conclusions from the Sterilization Working Group: page 6)

They reach this conclusion by only examining diseases adapted to humans.

They don’t cite this to any previous study, and I have not been able to find any precedent except a non peer reviewed op ed. by Robert Zubrin (Contamination From Mars: No Threat) which was strongly criticised by experts including your planetary protection officer at the time John Rummel:

John Rummel: How ought others judge the cost-benefit ratio of Mars exploration if we don't take simple precautions to avoid potentially harmful consequences? Harshly, I suspect.

Margaret Race: If he were an architect, would he suggest designing buildings without smoke detectors or fire extinguishers?

("Opinion: No Threat? No Way")

Zubrin makes all three of the main arguments used in the EIS - NONE OF THESE OCCUR IN THE PEER REVIEWED PLANETARY PROTECTION LITERATURE

It is a striking similarity. There is no reason to suppose the sterilization working group was influenced by Zubrin’s non peer reviewed op ed. and they don’t cite it. But there may be a common background, which I discuss in my preprint, such as enthusiasm for physical exploration and pushing through frontiers, a focus on the mission objectives, a keenness to send astronauts to Mars, and a pre-existing optimism, possibly inspired by science fiction, that if there is anything on Mars it can’t harm us.

However in the worst case scenario we find interesting life on Mars that is harmful to Earth and can never be returned to Earth. This is currently a possible scenario. It could envigorate space exploration and lead to more rather than less public interest and enthusiasm for astronauts in space.

THE PLANETARY PROTECTION LITERATURE ALREADY MENTIONS TETANUS - SOMETIMES ACCIDENTALLY DEADLY FOR UNVACCINATED NEWBORNS - AND LEGIONNAIRES’ DISEASE - A DISEASE OF MICROBIAL COMMUNITIES THAT SEES THE LUNGS AS SIMILAR TO A MICROBIAL BIOFILM AND IS SOMETIMES DEADLY TO US - NEITHER ADAPTED TO HIGHER LIFE OR HUMANS

The sterilization working group doesn’t discuss the illustrative examples from the 2009 paper: (Assessing the Biohazard Potential of Putative Martian Organisms for Exploration Class Human Space Missions)

Indeed the passage discussing the potential for martian microbes to infect humans on page 6 has no citations for any of the diseases or to the planetary protection literature.

In this way they missed:

The sterilization working group doesn’t alert the reader to the existence of such diseases.

STERILIZATION WORKING GROUP DISCUSSES CANDIDA - A FUNGAL INFECTION ADAPTED TO HUMANS - BUT DOESN’T ASK IF THERE ARE OTHER FUNGAL INFECTIONS THAT ARE NOT ADAPTED TO US

The sterilization working group does discuss Candida a fungal infection that they correctly say has adapted to humans over long periods of time.

As with the other diseases, the passage gives no citations for their statement about Candida. I was able to confirm that experts say it is adapted to humans. But the natural next question for someone looking for worst-case scenarios rather than best-case scenarios is - what about other fungal infections of humans? Are they adapted to us?

I can’t find previous discussions of fungal infections in the Mars sample return literature, so needed to do my own research into this. To date, the planetary protection literature hasn’t tried to be comprehensive and only looks at a few illustrative examples.

Following up this example I found an example new to the planetary protection literature (as far as I know).

A SEARCH FOR FUNGAL DISEASES NOT ADAPTED TO HUMANS FINDS ASPERGILLUS - WITH 200,000 CASES A YEAR OF OF INVASIVE ASPERGILLIOSIS MORTALITY 30% TO 95%, 400,000 CASES OF ALLERGIC PULMONARY ASPERGILLIOSIS AND 4.8 MILLION CASES OF ASTHMA TRIGGERED BY ASPERGILLUS FUMIGATUS

The two most deadly fungal infections for humans are Candida and Aspergillus. Aspergillus fumigatus is NOT adapted to humans. We get an estimated 200,000 life threatening invasive aspergillosis infections a year with mortality rates varying from 30 to 95%. This disease affects people who are immunocompromised mainly.

. Hidden killers: human fungal infections.

The progressive and very serious disease of chronic pulmonary aspergillosis (CPA) affects around 400,000 globally and only occurs in people who are not immunocompromised with symptoms of “weight loss, profound fatigue, productive cough, significant shortness of breath, and life-threatening hemoptysis [spitting out of blood from the lungs]”.

Then allergic bronchopulmonary aspergillosis affects 2.5% of patients with asthma, and an estimated 4.8 million people globally. All three diseases are different manifestations of the same fungus, Apergillus fumigatus (with a couple of other aspergillus species also involved in some cases). For details, see:

(Global burden of allergic bronchopulmonary aspergillosis with asthma and its complication chronic pulmonary aspergillosis in adults)

ILLUSTRATIVE WORST CASE EXAMPLE OF A NEW INVASIVE FUNGAL DISEASE USING ASPERGILLUS FUMIGATUS AS A PLAUSIBLE ANALOGUE OF A NEW FUNGAL GENUS FROM MARS

To help focus attention I’ve added a new fungal genus as a new illustrative planetary protection example. Aspergillus turns out to be a plausible analogue for a new fungal genus from Mars that might be a serious invasive disease of humans.

It’s also an example of something else. Our immune system might also overreact to a novel fungal genus from Mars. This idea of an allergic reaction to life from Mars seems to be new to the planetary protection literature. I followed it up as a result of discovering that many serious effects from Aspergillus in patients with a competent immune system are due to their immune system over-reacting to it.

IF OUR IMMUNE SYSTEM IS FACED WITH A NOVEL FUNGAL GENUS FROM MARS IT NEVER SAW BEFORE - IT MIGHT BE MYSTIFIED AND MOUNT NO DEFENSE, AS FOR INVASIVE ASPERGILLIOSIS OR IT MIGHT OVERREACT AS FOR ALLERGIC PULMONARY ASPERGILLIOSIS OR ASTHMA TRIGGERED BY ASPERGILLUS

Our immune system has evolved over millions of years to defend us against Aspergillus. Many parts of the immune system work together to

When our immune system doesn’t spot Aspergillus or responded to it we get invasive aspergillosis, a very serious disease with high mortality as we saw.

When our immune system does spot it, it has to clear the aspergillus microbes from our lungs. However, at the same time it has to avoid over-reacting in a harmful inflammatory response. Otherwise we may get asthma, or worse, allergic pulmonary aspergillosis. I will indent a summary of how this works as “Techy details”

Techy details: Our immune system detects fungi using its pathogen-associated molecular patterns (PAMPs). It likely uses pattern recognition receptors (PRRs) which trigger the immune response. There are different patterns for each of the main fungal genera that affect humans: Candida, Aspergillus and Cryptococcus (Antifungal immune responses: emerging host–pathogen interactions and translational implications : table 1)

Then to dampen down the inflammation when it’s not needed - this is a complex finely tuned reaction that involves the inflammation dampening Treg cells and many T-helper cells.

Techy details: Our immune system detects fungi using its pathogen-associated molecular patterns (PAMPs). It likely uses pattern recognition receptors (PRRs) which trigger the immune response. There are different patterns for each of the main fungal genera that affect humans: Candida, Aspergillus and Cryptococcus (Antifungal immune responses: emerging host–pathogen interactions and translational implications : table 1)

The most important ones for our adaptive immune response to aspergillus that we use to avoid over-reacting are the Th1, Th17, Th22, Th2, Th9, Treg, and Tr1 cells (The multifaceted role of T-helper responses in host defense against Aspergillus fumigatus)

If our immune system faces a novel fungal genus it’s never seen before in all of terrestrial evolution, it will be a major challenge to mount such a finely tuned response

For instance, as a thought experiment, suppose an alternative evolutionary history where our immune system has only ever encountered Cryptococcus. Now we return Aspergillus from another planet. Our immune system won’t be able to see Aspergillus fumigatus (it will have none of those PAMPs from the techy details above).

Now lets try this thought experiment again, Aspergillus is new as before, but our immune system already encountered Candidas on Earth. Now it has some but not all of the PAMPs needed for the introduced Aspergillus.

If it does recognize Aspergillus the T-helper and T-reg responses are unlikely to achieve the fine balance to avoid overreacting with an allergic reaction.

It might be a similar situation to one or other of these scenarios, if we introduce a novel fungal genus from Mars to Earth’s biosphere which has the capability to grow in the environmental conditions it finds inside or on humans.

YES ON SOME SCENARIOS, MARTIAN LIFE FROM MARS WILL BE ABLE TO LIVE ON EARTH - WE HAVE EXAMPLES OF SPECIES THAT LIVE IN THE PERMAFROST THAT CAN ALSO GROW AT HUMAN BODY TEMPERATURES

Here some people will argue that any Martian life will be unable to live at human body temperatures. The sterilization working group argues that terrestrial life wouldn’t be able to survive on Earth at all.

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.

(Biological safety in the context of backward planetary protection and Mars Sample Return: conclusions from the Sterilization Working Group: page 6)

[bolding added for the two examples in brackets]

This has a major omission, polyextremophiles that live in a wide range of extreme environments and can often also live in normal environments. Their own citation, Merino et al., includes one remarkable polyextremophile, amongst many extremophiles that can only tolerate a narrow range of conditions. Planococcus Halocryophilus has a salinity range 0 to 19% and temperature range -15 °C to 37 °C

Text on graphic: Merino et al.'s table of extremophiles has one remarkable exception with a very broad temperature range

Optimal growth 25°C. Metabolic activity at least to -25°C. Found at -16°C.

(Living at the extremes: extremophiles and the limits of life in a planetary context.: table 3)

p. Halocryophilus Or1 was actually isolated from Canadian permafrost (Planococcus halocryophilus sp. nov., an extreme sub-zero species from high Arctic permafrost), likely grows in sub-zero brine veins around soil particles at an ambient temperature of around -16°C. The researchers found it has an optimal growth temperature of 25°C and can continue to grow right up to 37 °C (human blood temperature) tested (Bacterial growth at− 15 C; molecular insights from the permafrost bacterium Planococcus halocryophilus Or1).

The -15 °C in that table isn’t likely to be the lowest limit for growth as p. Halocryophilus Or1 shows metabolic activity down to at least -25 °C which is the lowest temperature tested (Bacterial growth at− 15 C…). . It’s hard to study growth at low temperatures, as it takes 1,000 to 10,000 years for microbes to successfully colonize granite in the McMurdo dry valleys (Growth on geological time scales in the Antarctic cryptoendolithic microbial community). So it’s certainly possible that p. Halocryophilus can grow colonies extremely slowly at −25 °C. It might be able to grow at even lower temperatures as that’s the lowest tested for metabolic activity. So it is a reasonable an analogue for a Martian microbe for temperature tolerance.

ILLUSTRATIVE WORST CASE EXAMPLE OF MIRROR LIFE TO HELP FOCUS ATTENTION ON NEED TO PROTECT EARTH’S BIOSPHERE AS A WHOLE

I mentioned earlier on the blue-green algae Chroococcidiopsis is one of our top candidates for a terrestrial life form that could live on Mars if there is water available for it to use.

We don’t know Martian life is related to us.

Astrobiologists, including the teams that were gathered by NASA to advise them on the sample return mission tell us life on Mars may well be independently evolved.

There is a distinct need for novel techniques specialized for biochemical systems that do not share a chemical heritage with life on Earth.

(Final Report of the Mars Sample Return Science Planning Group 2 (MSPG2) : page S-21)

Also from iMOST in their discussion of experiments they wish to do with the samples returned from Perseverance to look for any signs of viable or recently dead present day life on Mars:

Page 88: We cannot predict with any accuracy life's form and characteristics, … or whether it shares a common ancestor with life on Earth.

…

Page 89: A subset of the investigations will only be successful at detecting Mars life if it shares a common ancestor with Earth life due to travel on meteorites or space debris, whereas other suggested investigations are based on more general characteristics of living entities.

…

Page 91: The short-term survivability of nucleic acids means that its detection would be strong evidence of recent life. This investigative avenue is feasible only if life on Mars and Earth share a common origin and thus share DNA/RNA as genetic material.

(The potential science and engineering value of samples delivered to Earth by Mars sample return: International MSR Objectives and Samples Team (iMOST) )

So what could we find by way of an alternative biology on Mars? There are many ideas, but one of the top candidates for an alternative form of biology is mirror life, which everyone agrees is biologically plausible, evolved from scratch from the mirror images of the chemicals used by terrestrial life.

Text on graphic: Normal life, Mirror life, DNA, amino acids, sugars, fats, everything flipped. Most normal life can’t eat mirror organics. Martian mirror life might be able to eat normal organics.

When a molecule can occur in two mirror forms, like your hands, it’s called chiral - the word chiral is derived from the Greek word χειρ (kheir) for hand. Terrestrial life is homochiral, which means that nearly all of its asymmetrical (chiral) molecules occur in only one of its two mirror forms. Also terrestrial life for the most part can’t use any mirror organics it finds and just ignores them.

If we could flip a cake in 3D, like reflecting it in a mirror, all the way down to its molecules, we might be able to eat it, like artificial sweeteners, but our metabolism couldn’t do anything with the flipped starches or proteins, and many fats would also be inaccessible (An adventure in stereochemistry: Alice in mirror image land)

ONE MODERN THEORY - PUNCTUATED CHIRALITY - MAKES IT A 50 - 50 CHANCE THAT INDEPENDENTLY EVOLVED LIFE IS MIRROR LIFE COMPARED TO US

According to one modern theory - punctuated chirality - there’s a 50 - 50 chance that independently evolved life on Mars uses mirror organics.

According to this theory, early on as life was just starting to evolve, there were patches of chemicals that worked together with each other in chiral networks which expand converting a non chiral substrate into chiral organics and where two chiral networks of opposite chirality meet there are ways for them to slowly convert each other to the opposite chirality.

There would be many such patches, some with the same chirality as terrestrial life and some with mirror organics. According to this theory, these patches would expand and flip each other back and forth in chirality on an environmental scale, with the chirality reset multiple times in Early Earth even if it didn’t go extinct (Punctuated chirality : 6) until one of them got established as the basis for the evolution of life.

If so, depending on how the flips went on Mars, life could easily have evolved from chemicals with the opposite chiral bias to Earth life

Our analysis predicts that other planetary platforms in this solar system and elsewhere could have developed an opposite chiral bias.

(Punctuated chirality : 7)

They predict that in the universe as a whole if an organic is found in a large sample of independently evolved forms of life it should occur in roughly equal amounts in normal and mirror forms

As a consequence, a statistically large sampling of extraterrestrial stereochemistry would be necessarily racemic on average

(Punctuated chirality : 7)

Text on graphic: By the theory of punctuated chirality, in a large sample of glucose from many planets containing life or prebiotic chemistry, roughly half would be D-glucose and half L-glucose

D-Glucose which terrestrial life can use

L-Glucose used as an artificial sweetener

Similarly for all organics that can occur in two mirror forms

Graphic for L-glucose and D-glucose by reflecting the graphic horizontally. Grey: Carbon, Red: oxygen, white: Hydrogen.

WORST CASE SCENARIO HERE IS THAT MIRROR LIFE RETURNED FROM MARS GRADUALLY FLIPS NEARLY ALL TERRESTRIAL ORGANICS INTO INDIGESTIBLE MIRROR ORGANICS OVER TIMESCALES OF DECADES OR CENTURIES - THE LEVEL OF ASSURANCE WE NEED TO PREVENT SUCH A SCENARIO, IF IT IS POSSIBLE - IS A MATTER FOR WIDER DISCUSSION AND CAN’T BE SETTLED FOR THE REST OF HUMANITY BY NASA MISSION PLANNERS

Synthetic biologists plan to gradually flip ordinary to mirror life over a period of a decade or so – and will make sure synthetic mirror life is engineered to depend on chemicals only available in the laboratory. They warn escape of mirror life could cause major transformations of the terrestrial biosphere by locking up organics in unusable mirror forms. See: (Mirror-image cells could transform science-or kill us all)

Martian life likely already has the isomerases to metabolize organics of opposite sense, whether it is mirror or normal life - because nearly all organics are either made abiotically locally, or are infall from comets, asteroids and interplanetary dust, with organics of both senses.

Eventually terrestrial microbes likely develop isomerases to metabolize mirror life, but higher life couldn’t evolve so quickly. The outcome is a mix of normal and mirror organics. In Kasting and Church’s worst case scenario mirror life retains the edge over normal life in this evolutionary race and eventually there is little left except mirror organics and life that can use it. They suggest humans could go extinct in this worst case scenario at least in the natural ecosystems

In Kasting and Church’s worst case scenario mirror life retains the edge over normal life in this evolutionary race and eventually there is little left except mirror organics and life that can use it. They suggest humans could go extinct in this worst case scenario at least in the natural ecosystems

“—both Kasting and Church think mirror predators would evolve, but whatever life existed on Earth by that point wouldn’t include us.

(Mirror-image cells could transform science-or kill us all)

In this worst case I don’t think humans would go extinct even on the centuries timescale. We could enclose large areas of Earth with its tropical jungles, coral reefs etc, in habitats similarly to Biosphere 2 (Under the Glass Systems).

There might well be things we can do to help terrestrial microbes win the evolutionary race with the imported mirror life.

But it’s far better not to do the experiment.

We will only know if we are in the scenario of a Mars with mirror life if we look for it and find it.

If we are in that scenario, we would likely decide as a civilization we must never return Martian mirror life back to Earth.

So, to help focus attention on the potential for adverse effects on the environment, in the very worst case we could return microbes that could transform Earth’s biosphere in ways we can’t predict.

THIS IS A WORST CASE SCENARIO - ASTROBIOLOGISTS BELIEVE THE POTENTIAL FOR LARGE SCALE EFFECTS IS LIKELY VERY LOW - BUT AS FOR A HOUSE FIRE WE DO NEED TO BE PREPARED FOR WORST CASES SCENARIOS - EVEN IF VERY UNLIKELY

These are worst cases not likely cases.

But as with house fires, and smoke detectors we do need to look at worst cases. We can’t protect Earth properly if we only look at the most optimistic scenarios.

We can’t rely on the same risk-benefit calculus for release of SARS and for release of mirror life.

Some synthetic biologists say we need a level of assurance for synthetic biology far higher than for any biosafety laboratory. Schmidt said:

… maybe [1 in 100,000,000,000,000,000,000] is more than enough …

The probability also needs to reflect the potential impact, in our case the establishment of an XNA ecosystem in the environment, and how threatening we believe this is.

The most important aspect, however, is that the new safety mechanism should be several orders of magnitude safer than any contemporary biosafety mechanism

(Xenobiology: a new form of life as the ultimate biosafety tool.)

[In this quote XNA refers to life based on a different informational polymer from DNA. Similar remarks would apply to mirror life]

The same precautions may be needed for returning alien biology from another planet.

NASA DOESN’T HAVE THE COMPETENCE OR AUTHORITY TO DECIDE THIS FOR THE REST OF HUMANITY - “THIS IS NOT A TECHICAL QUESTION FOR SCIENTISTS AND ENGINEERS. RATHER IT IS A MORAL QUESTION CONCERNING ACCEPTING RISK” - RICHARD RANDOLPH

This is NOT something that NASA mission planners can decide for the rest of humanity. This is NOT something we can decide using the scientific method.

We need a wider discussion here to work out the necessary level of assurance if there is indeed a potential for returning mirror life from Mars. This is one of the NEPA’s central requirements for a valid EIS.

Agencies shall prepare environmental impact statements using an interdisciplinary approach that will ensure the integrated use of the natural and social sciences and the environmental design arts … The disciplines of the preparers shall be appropriate to the scope and issues identified in the scoping process
§ 1507.2 [links directly to legal text]

Mars sample return studies emphasize the need to involve the public early on, not just in the USA, but through fora open to representatives from all countries globally because negative impacts could affect countries beyond the ones involved directly in the mission

RECOMMENDATION 3

Potential risks from an MSR are characterised by their complexity, uncertainty and ambiguity, as defined by the International Risk Governance Committee’s risk governance framework. As a consequence, civil society, the key stakeholders, the scientific community and relevant agencies’ staff should be involved in the process of risk governance as soon as possible.

In this context, transparent communication covering the accountability, the benefits, the risks and the uncertainties related to an MSR is crucial throughout the whole process. Tools to effectively interact with individual groups should be developed (e.g. a risk map).

RECOMMENDATION 4

Potential negative consequences resulting from an unintended release could be borne by a larger set of countries than those involved in the programme. It is recommended that mechanisms and fora dedicated to ethical and social issues of the risks and benefits raised by an MSR are set up at the international level and are open to representatives of all countries

(Mars Sample Return backward contamination–Strategic advice and requirements : 59)

The public weren’t involved early on in that way. Not only that, the few in the public who did discover NASA’s request for public comment weren't given the opportunity to comment on a scientifically valid EIS.

We can’t rely on the same risk-benefit calculus for release of SARS and for release of mirror life, without legislative / executive / public involvement to decide if this is what we should do.

The theologian Richard Randolph put it like this, from a Christian perspective:

The risk of back contamination is not zero. There is always some risk. In this case, the problem of risk – even extremely low risk – is exacerbated because the consequences of back contamination could be quite severe. Without being overly dramatic, the consequences might well include the extinction of species and the destruction of whole ecosystems. Humans could also be threatened with death or a significant decrease in life prospects

In this situation, what is an ethically acceptable level of risk, even if it is quite low? This is not a technical question for scientists and engineers. Rather it is a moral question concerning accepting risk

(Chapter 15, God’s preferential option for life: a Christian perspective on astrobiology)

THE MAIN CONCERN OF THE GENERAL PUBLIC IN THEIR COMMENTS ON THE EIS WAS RISK OF HARM TO HUMAN HEALTH AND EARTH’S ENVIRONMENT - 50 OUT OF 63 COMMENTS IN THE FINAL EIS

Several dozen distinct members of the public expressed views that suggest they would be in support of Sagan’s quote that I use at the start of this open letter, on a not very widely publicised EIS.

“The likelihood that such pathogens exist is probably small, but we cannot take even a small risk with a billion lives.”

(The Cosmic Connection – an Extraterrestrial Perspective)

Nine commentators specifically mention unprecedented harm and 50 out of 63 made comments that make it clear they would agree with Sagan’s view.

This figure of 50 out of 63 shouldn’t be read as a percentage of the public as it is not a poll. But it does show that at least several dozen of the members of the public who were reached in the not very well publicized second round of comments had concerns similar to Sagan.

50 out of 63 shouldn’t be read as a percentage of the public as it is not a poll. But it does show that at least several dozen of the members of the public who were reached in the not very well publicized second round of comments had concerns similar to Sagan.

These are links to all the comments. Many are short and succint but clear in what they intend to say. The ones that would surely agree with Sagan are highlighted in bold.

Those are 56 comments so far that would agree with Sagan.

Four more comments were very detailed with attachments making the same point.

Thomas Dehel quoting from an interview he did with Gill Levin, principle investigator for the first and only direct life detection experiment sent to Mars, who died shortly before the start of the EIS process

"I believe people will realize, especially after the Covid-19 catastrophe, that even if there’s only a small chance that something could be contagious and pathogenic, coming from a foreign planet, I don’t think it’s worth taking that chance….you don’t take unnecessary chances where the risk-to-benefit ratio is almost infinite.”

. Comment posted December 13th

Barry DiGregario quoting from an interview he did with Carl Woese when he was alive.

“When the entire biosphere hangs in the balance, it is adventuristic to the extreme to bring Martian life here. Sure, there is a chance it would do no harm; but that is not the point. Unless you can rule out the chance that it might do harm, you should not embark on such a course”

. Comment posted December 5th

Carl Woese is the biologist who used gene sequencing to identify the archaea, the third realm of life. As the botanist Otto Kandler put it: “He opened a door which nobody expected to exist” (The singular quest for a universal tree of life)

Chester Everline, co-author of your handbook on probabilistic risk assurance (Probabilistic risk assessment procedures guide for NASA managers and practitioners) found that the EIS didn’t state clearly what level of risk NASA is prepared to take for Earth’s biosphere:

A possible consequence of unsuccessful containment is an ecological catastrophe. Although such an occurrence is unlikely, NASA should at least be clear regarding what level of risk it is willing to assume (for the biosphere of the entire planet)

(Comment posted December 20th)

My own final comment, in 14 points ending:

Let's make this an even better mission and SAFE for Earth.

. Comment posted December 20th

THE LANGUAGE “POTENTIAL FOR LARGE-SCALE NEGATIVE EFFECTS APPEARS TO BE LOW BUT IS NOT DEMONSTRABLY ZERO” AND ”NEAR-ZERO PROBABILITY OF [ANY] ENVIRONMENTAL EFFECTS” SEEMS SMALL BUT HAS MAJOR LEGAL EFFECTS - REMOVING NEARLY ALL THE GUARD RAILS TO PROTECT EARTH’S BIOSPHERE

The National Research Council in 2009 put it like this for large scale harm to humans and the envioronment.

The committee found that the potential for large-scale negative effects on Earth’s inhabitants or environments by a returned martian life form appears to be low, but is not demonstrably zero

Page 6 of: (Biological safety in the context of backward planetary protection and Mars Sample Return: conclusions from the Sterilization Working Group)

This is what the sterilization working group said:

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.

The difference between “appears to be low, but is not demonstrably zero” and “near-zero probability” may seem subtle. But we need to notice that the “appears to be low” is for large-scale negative effects. The “near -zero” is for ANY environmental effects.

This difference has major legal consequences.

All previous studies have said numerous laws to protect Earth’s environment would be triggered by a Mars sample return and other agencies such as the CDC, Department of Agriculture, most recently, from 2019. Updating Planetary Protection Considerations and Policies for Mars Sample Return (with your former planetary protection officer Cassie Conley as co-author)

If there is even a low potential for large scale negative effects, NASA themselves are mandated to consider such matters as:

● impact on the environment,

● impact on the oceans,

● impact on the great lakes,

● escape of invasive species,

● lab biosecurity against theft

See: page 3–3 of NASA Facilities Design Guide

Yet there is no discussion of the potential for large-scale effects on the great lakes, or oceans, or environment or other such matters in your draft EIS.

DRAFT EIS FOCUSES DETAILED DISCUSSION OF ENVIRONMENTAL EFFECTS ALMOST ENTIRELY ON THE UTTR SOUTH RANGE LANDING SITE - WITH ALMOST NO DISCUSSION OF EFFECTS OF ACCIDENTAL RELEASE FROM THE SAMPLE CONTAINMENT FACILITY - THE MAIN FOCUS OF PREVIOUS SAMPLE RETURN STUDIES

NASA only discuss environmental effects in the immediate area where the Earth Entry system (EES) with aeroshell and containing the sample capsule hits the Earth and similarly for transport of the samples and the sample receiving facility.

The risk here is very low as terminal velocity is quite low, 90 miles an hour and it’s not hard to design a capsule that won’t break after impact at 90 miles an hour even on a hard surface and this is soft sand. For the landing site they say that they expect the impact to make an impact crater 0.5 meters deep and 1.2 meters wide (Mars Sample Return DRAFT EIS : 3–18).

They plan to decontaminate the landing site with chlorine dioxide such as is used in drinking water and aldehyde (Mars Sample Return DRAFT EIS : 3-35), saying:

The standard decontamination of biohazards in soil typically involves applying chemical sterilants as liquid or fumigants (such as chlorine dioxide or aldehyde) in place (EPA 2017).

…

NASA believes these types of decontaminates would be effective given the assumption that any putative Mars life forms would be similar to “life as we know it” with a water-mediated carbon-based biochemistry, and that there would not be any “unique” biohazards associated with the Mars samples

(Mars Sample Return DRAFT EIS : 3-35)

From their cite , this shows the effect of 24 hours of high concentrations of CLO2. It has almost no effect on top soil below a depth of one inch below the surface.

It is much more effective on clay or sand with a 100 million fold reduction. So it might work well in a desert. But this is only for colony forming units and it’s not of course certified for use with a scenario of martian spores that may be far more resilient to oxidants than terrestrial spores given how oxidising the surface of Mars is.

(Assessment of the Decontamination of Soil Contaminated with Bacillus anthracis Spores Using Chlorine Dioxide Gas, Methyl Bromide, or Activated Sodium Persulfate)

But this is a minor point as the main issue is for containment in a BSL-4 after the samples are removed from the landing site. They don’t seem to discuss this at all, which is the main focus of attention in previous Mars sample return studies.

This is all I can find about environmental effects of accidental release of Martian life from a BSL-4.

By applying the BSL-4 framework, NASA is able to identify and analyze reasonably foreseeable environmental impacts of its Proposed Action (e.g., the air emissions from a representative existing BSL-4 facility) and evaluate, from a programmatic perspective, whether the environmental effects may be significant. This programmatic analysis can be utilized to guide SRF type and location planning, as well as analyses once these aspects have been identified and proposed.

(Mars Sample Return DRAFT EIS : EIS : 2-12)

To paraphrase, they are saying “nothing to look at here, will just handle it like any other sample in a BSL-4”.

All this is legally simple for as long as effects are local. But their plans would need to be examined in great detail by other agencies if there is potential for large-scale effects.

Just by omission, that these things are not considered, it shows that authors of the EIS are of the view that “near - zero” means there is no need to consider wider environmental effects.

They clearly feel they have no need to consider them even udner these direct obligations for NASA as a government agency under numerous executive orders from past presidents of the USA.

NATIONAL RESEARCH COUNCIL (2009): NASA NEEDS TO WORK WITH BIOSECURITY AGENCIES LIKE THE CDC AS WITH THE INTERNATIONAL COMMITTEE FOR BACK CONTAMINATION FOR THE APOLLO MISSION (BASED ON POTENTIAL FOR LARGE-SCALE NEGATIVE EFFECTS)

The 2009 sample return study by the National Reserch Council says

As already noted, the design, construction, and operation of an SRF (Sample Receiving Facility) will require the coordination and work of multiple teams of experts, comprising a decade or more of planning. It will be important for various layers of scientific and technical oversight to be in place early in the planning process to ensure continuity through the lenthy and complex Mars sample return planning process.

In addition to the establishment of a body to provide scientific and technical advice relating to an SRF, there is also a need for higher-level oversight of all planetary protection requirements associated with Mars sample return. It is clear to the committee that NASA will need to obtain continuing interagency advice (e.g. from the Centers for Diseas Control and Prevention and relevant biosecurity agencies and organizations) on planetary proteciton policies and compliance, similar to the functional role played by the Interagency Committee on Back Contamination (ICBC) during the Apollo program..

(Assessment of planetary protection requirements for Mars sample return missions : Pages 67–8)

NASA don’t mention any proposal to set up technical advice or to work with other agencies while developing the Sample Receiving facility. Also it is too late to do this with the timetable set up in the 2009 report for a sample returned in 2033. They should have started long ago or would need to postpone the sample return significantly to contain the samples with this level of thoroughness.

Instead NASA just plan a normal internally managed BSL-4 with no oversight from anyone else.

ONCE POTENTIAL FOR LARGE-SCALE EFFECTS IS RECOGNIZED, MANY US AGENCIES WILL NEED TO DECLARE AN INTEREST - SUCH AS CDC, DOA, OSHA, DOI ETC

US agencies that would get involved include:

The PPAC which was disbanded in 2006 had representatives from:

It also had international representatives from other space agencies such as:

List of agencies from: . (Review and Assessment of Planetary Protection Policy Development Processes : page 26) supplemented by (The Goals, Rationales, and Definition of Planetary Protection: Interim Report : page 37)

ESA ARE CLOSELY INVOLVED AS THEY FETCH THE SAMPLES FROM MARS TO THE MARS ASCENT ORBITER, AND RETURN THEM FROM MARS ORBIT TO THE SURFACE OF EARTH - SO THE LEGISLATION OF THE EU, UK AND OTHER MEMBER STATES MAY APPLY - ALSO THE ESPOO CONVENTION

This is a joint ESA / NASA mission. The papers I found don’t go into this. But ESA are closely involved as they are responsible for fetching the samples from Mars and returning them to Earth.

So, the legislation of ESA member states would seem relevant. That includes the UK, the EU and other member states and cooperating states. Se (Member States & Cooperating States )

With the EU involved,

Also the UK and many other member states of ESA are parties to the Espoo convention. List of parties: UNTC

Under that convention they would need to consult with each other on all major projects that can have an effect outside of their own boundaries - which would certainly apply to a Mars sample return release of life that transformed the biosphere (Environmental Assessment - Espoo Convention)

INTERNATIONAL ORGANIZATIONS MAY GET INVOLVED LIKE THE FAO FOR POTENTIAL FOR LARGE SCALE EFFECTS ON FOOD AND AGRICULTURE, THE WHO BECAUSE OF POTENTIAL FOR LARGE SCALE EFFECTS ON HUMAN HEALTH ETC

It seems unlikely worst case scenarios would be ignored as the legal proceedings continue. So, for any Mars sample return mission for any country, at some stage, international agencies may get involved like

Many international treaties and domestic laws of other countries are also likely to be relevant. Race and Urhan et al summarize some of these potential legal ramification see:

In the USA, the Environmental Protection Agency partners with the United Nations Environment Program (UNEP), and Arctic Council, so they’d likely get involved.

THIS RESEARCH EFFORT CAN’T SUCCEED WITHOUT “BROAD ACCEPTANCE AT BOTH LAY PUBLIC AND SCIENTIFIC LEVELS” - JOHN RUMMEL, FIRST NASA PLANETARY PROTECTION OFFICER

This is how John Rummel, your 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: 96)

This doesn’t look like broad acceptance of NASA’s proposed action. It may be stopped at various points.

JOHN RUMMEL: THE RESULT IS A BUREAUCRATIC “TRAIN WRECK” - CONTAMINATION BY TERRESTRIAL LIFE IN THE PERSEVERANCE SAMPLES WILL OVERWHELM ANY BIOSIGNATURES FROM PAST LIFE AND ONLY DETECT PRESENT DAY LIFE IF LOCALLY VERY ABUNDANT IN ONE OF THE LOCATIONS SAMPLED

Your first planetary protection officer, John Rummel refers to this as a "train wreck" in 2017, referring particularly to issues with the sterilization of the sample tubes.

If the issues aren't resolved, Rummel says, the rover could be headed for a bureaucratic "train wreck".

(With planetary protection office up for grabs, scientists rail against limits to Mars exploration)

I found the contamination in the sample tubes is so high, for returned rock samples it will completely overwhelm expected traces of recognizable past organics even for recently exposed rocks. Your engineering team thinks they achieved 8.1 ppb of terrestrial contamination with up to 0.7 ppb per tested biosignature. (Mars 2020: mission, science objectives and build. In Systems Contamination: Prediction, Control, and Performance 2020 : table 6)

This is lower than the expected 100 ppb of organics in a sample similar to a Martian meteorite. However Pavlov et al found that after exposure to just 70 million years of surface ionizing radiation all except 0.1 ppb of those organics will be either directly damaged or will react with oxygen radicals liberated from the silicon oxides in the dirt and rock and will no longer show recognizable biosignatures. For clays with water incorporated as well it’s a 10 fold reduction every 10 million years, or 1000 fold in 30 million years.

Page 1112: Our results have serious implications for the current MSL, Mars 2020, and future MSR, ExoMars missions. [for the search for past organics] … knowledge of the exposure age at the drill locations is critical before sampling at shallow rock depths to avoid highly radiologically processed material.

The Perseverance rover does not have the capability to measure the exposure age of the collected
samples in situ.

(Rapid Radiolytic Degradation of Amino Acids in the Martian Shallow Subsurface: Implications for the Search for Extinct Life : page 1112)

We show that one potential reason for the lack of detection of complex organic molecules in the martian surface is due to their rapid alteration and degradation by cosmic rays.

…

In general, it would be extremely unlikely to find primordial amino acid molecules in the top 1 m of martian rocks due to their effective radiolysis by cosmic rays regardless of a rock type or location on Mars.

(Rapid Radiolytic Degradation of Amino Acids in the Martian Shallow Subsurface: Implications for the Search for Extinct Life : page 113)

Perseverance doesn’t have Curiosity’s capability to detect exposure ages of the rocks, and would need to find samples with less than a twentieth of the youngest measured exposure ages for Curiosity of 80 million years to be detectable amongst a background signal of 8.1 ppb of organics. As a result it is highly unlikely to sample rocks young enough to have detectable past biosignatures even if they originally contained past life.

For this reason I propose as a “stretch goal” for the bonus samples to add sterile handling capabilties to a Marscopter and use it to retrieve a pebble from the youngest impact crater that we can find within reach of the ESF fetch rover, or perhaps a rapidly eroding outcrop (see below). There are likely to be rocks with very young exposure ages in Jezero crater. Pavlov et al suggeste looking for recent impact craters and rocks exposed by rapid wind erosion or perhaps in a deep valley. (Rapid Radiolytic Degradation of Amino Acids in the Martian Shallow Subsurface: Implications for the Search for Extinct Life : page 113)

We will see this level of forward contamination will also almost certainly make it impossible to detect any present day life in the samples in the low numbers of viable spores expected in Jezero crater, if it does have present day life.

BEST OUTCOME - NASA WITHDRAWS THE EIS, AND AT THEIR LEISURE DOES THE SIZE LIMIT REVIEW - DOES A NEW EXTENSIVE MARS SAMPLE RETURN STUDY - RESTORES THE INTERAGENCY PANEL AND DOES THE EIS PROPERLY - OR FINDS AN ALTERNATIIVE LIKE THE PROPOSAL HERE THAT RETURNS ONLY STERILIZED SAMPLES TO EARTH

First NASA could withdraw the EIS, do the size limit review, do a new sample return study, and do a scientifically rigorous EIS. Or it could decide to sterilize the samples before returned to Earth which would be a far simpler process.

This seems far the best outcome for NASA. Not forced to do anything by a court decision. Not responding to public panic. They can decide in their own time how to proceed. This is my hope and why I am writing this open letter.

At their leisure, NASA can then work on a 100% safe mission using sterilize first, or they can work on other ideas, but it’s all done in coordination with the general public, legal experts, ethicists, social scientists etc.

Even a last-minute conversion to a 100% safe mission in the early 2030s could cause problems if NASA do it in response to panic from a distrustful public who might not believe the proposed sterilization is adequate. It is far better to get the public involved from the outset.

THE EIS MAY BE STOPPED BY OTHER AGENCIES IF ANY OF THEM LOOK BEYOND THE CONCLUSION “THAT THE POTENTIAL ENVIRONMENTAL IMPACTS WOULD NOT BE SIGNIFICANT”

Assuming NASA continue with the EIS, it could be stopped by other agencies. However, as it is currently, the draft EIS says there would be no significant environmental effects, so they’d have no reason to look at it closely

… support the judgement that the potential environmental impacts would not be significant.

(Mars Sample Return DRAFT EIS : 3-16):

But if any of them do look at it more closely they’d see many issues with the citing and sources and see that that statement is not scientifically credible, that we don’t KNOW it would have no environmental or public health impacts or even large scale impacts, and may stop it.

OR IT CAN BE STOPPED BY A COURT CASE AFTER THE EIS IS FINISHED AND PUBLISHED - ANYONE WHO TOOK PART IN PUBLIC COMMENTS HAS STANDING TO DO THIS - PROBABLY WITH HELP OF ONE OF THE LARGE ORGANIZATIONS THAT FREQUENTLY CHALLENGE ENVIRONMENTAL IMPACT STATEMENTS

The next point it can be stopped is in a court case after the EIS is finished and published. There is no provision for legal challenges within NEPA, so it is done through judicial review, usually on the basis that:

They can only be taken to the courts by someone with “standing”. For this, they need to take part in the public comments or debate in the NEPA process, and need to be directly affected by the proposed action. There are many members of the public who have standing in this sense. (National Environmental Policy Act: Judicial Review and Remedies)

THE USUAL WAY TO BLOCK SIMILAR ACTIONS IS TO USE THE ARGUMENT THAT NOBODY HAS STANDING BECAUSE THEY ARE ALL EQUALLY AFFECTED - SUCCEEDS PERHAPS HALF THE TIME - BUT THIS WOULD BE A HUGELY DAMAGING ARGUMENT FOR NASA TO USE

There you have to show that you are particularly affected by it, which is normally understood to mean more so than by others. If the petitioner claims NASA overlooked a worst case risk of global effects NASA could try to block it

In the past, environmental cases have gone either way based on subtle legal arguments about whether environmental effects give the petitioner “standing” for the case (Newly Imposed Limitations on Citizens' Right to Sue for Standing in a Procedural Rights Case).

However, the publicity would be hugely damaging for NASA if they used that legal argument to try to prevent legal scrutiny of their EIS.

REMEDIES WOULD LIKELY INCLUDE AN INJUNCTION TO STOP THE MISSION PLANS WHILE THE COURT CASE IS IN PROGRESS - AND THEN SOME EQUITABLE RELIEF SUCH AS A REQUIREMENT TO STERILIZE THE SAMPLES BEFORE THEY REACH EARETH

If it does get as far as the courts, the case is usually (National Environmental Policy Act: Judicial Review and Remedies : section: Remedies in NEPA Litigation)

If that is all the court does, the agency can continue with the project while it does those proceedings.

However at this point the court can also order “equitable relief”

So if a case is taken out and it’s successful, that could lead to a justice asking NASA to either stop the mission or to use some other remedy such as to sterilize the samples first before they are returned to Earth.

IF NOT CHALLENGED - NEXT STEP IS THE PRESIDENTIAL DIRECTIVE NSC-25 - WHICH REQUIRES THE PRESIDENT TO ORDER A REVIEW OF LARGE SCALE EFFECTS THAT COULD REASONABLY BE EXPECTED EVEN IF THE AGENCY FEELS CONFIDENT THAT SUCH ALLEGATIONS ARE FALSE

If nobody takes them to court or NASA successfully block the case so it never reaches the court, the next step is the presidential directive NSC-25, which requires the president to order

It has to be done even if the agency feels confident such allegations are false (Presidential Directive NSC-25: Scientific or Technological Experiments with Possible Large-Scale Adverse Environmental Effects and Launch of Nuclear Systems into Space)

This happens after the NEPA process is completed (Planetary Protection, Legal Ambiguity, and the Decision Making Process for Mars Sample Return).

WORST CASE FOR NASA AND FOR THE SCIENCE RETURN - THAT NOTHING IS DONE UNTIL 2033 AND THEN WITH MOUNTING PUBLIC CONCERN THEY HAVE TO ORDER THE SPACECRAFT RETURNING THE SAMPLES TO CONTINUE PAST EARTH FOR RETRIEVAL AND STERILIZATION LATER

If it gets past all those hurdles with little public awareness, it could be stopped at the last minute with samples already on their way back to Earth. At that point, if not before, experts would look at the published EIS and see it wasn’t scientifically credible.

Mounting global public concern could lead to Congress and the president acting to tell NASA to divert the mission away from Earth. A worst case here might be an infodemic about Mars life similar to the COVID infodemic, junk science, problems for NASA’s credibility, and issues with eventual return of even 100% safe sterilized samples.

LIKE A GNAT TRYING TO DRAW THE ATTENTION OF THE CAPTAIN OF THE TITANIC TO THE ICEBERG OF MAJOR DAMAGE TO NASA’S SCIENTIFIC CREDIBILITY IN 2033

John Rummel’s image that, the rover could be headed for a bureaucratic "train wreck" (With planetary protection office up for grabs, scientists rail against limits to Mars exploration) brought to mind the iceberg that sunk the Titanic. Here the iceberg represents public and scientific opinion in 2033 when they find out that

Text on graphic: What we need to prevent in 2033 - NASA’s mission plans - NASA’s future science credibility - Public and scientific opinion

(Stöwer Titanic)

(NASA logo )

This is what would surely happen to the samples once public attention and scientific attention shows that NASA has no realistic plan to protect Earth, possibly realizing this only in 2033 when the samples are already on their way back to Earth.

The space enthusiasts lobby is powerful but so also are the farmers, the Audobon society, the CDC, the Department of Agriculture and if it comes to a vote in Congress, those strongly in support of a Mars sample return to the extent space enthusiasts are will be a small minority.

Text on graphic: Worst case for NASA, samples have to fly past Earth in 2033 without landing

… Bye for now will return later once you are ready to sterilize my samples.

The space lobby is strong - & so are

  • farmers and Department of Agriculture,
  • Audobon society (for birds)
  • fishermen, NOAA and Fish and Wildlife service
  • public health, and CDC

etc…

There is a reason ALL sample return studies say OTHER AGENCIES and the PUBLIC must be INVOLVED IN YOUR PLANS at an EARLY STAGE - and together they have far more votes in Congress.

This may happen in 2033, if NASA still have no scientifically credible plans.

This EIS will not stand up to the smallest amount of independent scrutiny and peer review.

Image shows frame from: (Solar Orbiter’s Earth flyby)

As a member of the public, not attached to any academic body, sometimes I feel like a gnat trying to draw the attention of the pilot of the Titanic to the iceberg.

But the iceberg of future public and scientific opinion is there whether the captain notices it or not.

I do have an advantage however. I can just say things as they are plainly and simply more easily. Writing this as an individual is far simpler than it would be if I was a tenured professor or researcher in an institution.

AWKWARD POSITION WHERE THE LEADING AUTHORS ON PLANETARY PROTECTION AS NASA OR ESA EMPLOYEES OR EX EMPLOYEES CAN’T BE EXPECTED TO WRITE A CRITICAL REVIEW OF THEIR OWN AGENCIES

In particular we are currently in the awkward position where due to NASA’s previous excellence in planetary protection, the authors who have written most extensively on planetary protection are previous employees of NASA or in some way connected to NASA or ESA.

There are many other authors you would expect to write a paper on this topic of the need for NASA to take more care over planetary protection. Sagan and Lederberg sadly died. Gill Levin also passed away just before the process of NASA’s draft EIS started.

However there are many still alive today who have written extensively on a Mars sample return.

But sadly many of those are former NASA or ESA planetary protection officers or employees. They are authors, co-authors or contributors for most of the recent substantial research on a Mars sample return. There doesn’t seem to be much awareness more widely at present.

The issue here is you can’t expect who has published research funded by NASA on this topic to publicly challenge their agency’s environmental impact statement, unless they were to go all the way to the dramatic move of whistleblowing. For example, John Rummel is author or co-author or contributor of much of the literature on the topic (. Curriculum Vitae). In the Space Studies Board planetary protection reviews he would be one of the “only two or three individuals with direct experience of the issue to be addressed”

(Review and Assessment of Planetary Protection Policy Development Processes : Page 77)

He was the obvious person to contact as your first planetary protection officer and as co-author of almost all the major studies on backward contaminationa. But as a former NASA planetary protection officer it’s no surprise he just deferred to the planetary protection office when I tried to contact him about it via email.

One NASA employee, Chester Everline, a JPL employee and a principal author of NASA’s probabilistic risk assessment guide . (Probabilistic risk assessment procedures guide for NASA managers and practitioners), made a detailed public comment in which he said

Chester Everline: A possible consequence of unsuccessful containment is an ecological catastrophe. Although such an occurrence is unlikely, NASA should at least be clear regarding what level of risk it is willing to assume (for the biosphere of the entire planet)

He said that when NASA set out the list of options to assess in the EIS it should have included the reasonable alternative to delay the return until the risks are better understood.

A better statement of options should include the possibility of delaying the return of Mars samples until the risks associated with their return are better understood

(Comment posted December 20th)

But there is no way he could liase with me on this topic. When I contacted him I well understood when he replied in a short one sentence email that as a JPL employee he couldn’t engage.

BUT WE CAN TURN THIS AROUND - WE CAN STEER THIS POTENTIAL TITANIC BACK TO THE CLEAR WATERS OF CREDIBLE SCIENCE

This is probably why it’s required someone not connected in any way to NASA to write this open letter and preprint.

Text on graphic: This open letter describes one of likely many ways NASA can change course and avoid driving directly into the bureaucratic “train wreck” of a forced flyby without landing in 2033 and then sterilization of all the samples.

(Photograph of the iceberg that likely sunk the Titanic)

(Titanic iceberg)

A WORST CASE SCENARIO OF MIRROR LIFE HELPS FOCUS ATTENTION ON OUR RESPONSIBILITIES AS ALMOST ALL ASPECTS OF HUMAN LIFE ARE POTENTIALLY AFFECTED - JUST AS THE SCENARIO OF A HOUSE FIRE HELPS FOCUS ATTENTION ON RESPONSIBILITIES TO INSTALL A SMOKE DETECTOR PROPERLY

Indeed, with mirror life from Mars as an example worst case scenario, there would be few aspects of human life not relevant in some way in discussions of the very worst-case scenarios.

In this way, a scenario of mirror life can help focus attention on our responsibilities to protect Earth’s biosphere. This doesn’t happen if we focus exclusively on best case scenarios with no harm or near zero possibility of harm to humans or Earth’s environment, even if the best case scenarios may indeed be likely ones. Returning to what John Rummel said:

People have to have some kind of respect for the unknown. If you have that respect, then you can do a credible job, and the public is well-served by your caution.”

(Controversy Grows Over whether Mars Samples Endanger Earth)

I suggest in this case respect for the unknown should involve considering the scenario of mirror life, for as long as it remains an astrobiologically plausible scenario for Mars.

The analogy of a house fire helps again. If we pay close attention to a scenario of a house fire it helps us install smoke detectors properly. If we think a house fire is impossible, we might leave smoke detectors out altogether.

As the legal process continues, surely there would be open public debate about these scenarios, and if the discussion expands in this way, potentially it might lead to much wider involvement in the international community. It would be necessary to convince the public, and interested experts in all these agencies that this is a safe mission and that all their concerns have been answered.

In short, great care is taken to make sure Earth is kept safe.

NASA’S PLAN TO USE BIOSAFETY LEVEL 4 CONTAINMENT RELIES ON SAMPLE RETURN RECOMMENDATIONS FROM 1999 - THE ESF REDUCED THE SIZE LIMIT 20-FOLD IN 2012 AND ADDED A NEW REQUIREMENT OF 100% CONTAINMENT AT 0.05 MICRONS BECAUSE OF ADVANCES IN OUR KNOWLEDGE OF VERY SMALL ORGANISMS AND GENE TRANSFER

The draft EIS says they would use many of the basic principles of a Biosafety level 4 facility (BSL-4):

Nevertheless, out of an abundance of caution and in accordance with NASA policy and regulations, NASA would 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 and impact humans or Earth’s environment.…

The material would remain contained until examined and confirmed safe or sterilized for distribution to terrestrial science laboratories. NASA and its partners would use many of the basic principles that Biosafety Level 4 (BSL-4) laboratories use today to contain, handle, and study materials that are known or suspected to be hazardous.

(MSR Campaign Programmatic EIS, DRAFT Mars Sample Return (MSR) Campaign Programmatic Environmental Impact Statement : S2–4)

But the ESF set requirements well beyond an BSL-4 in 2012

RECOMMENDATION 7:
The probability that a single unsterilised particle of 0.01 μm diameter or greater is released into the Earth’s environment shall be less than [one in a million]

…

The release of a single unsterilized particle larger than 0.05 μm is not acceptable under any circumstances

(Mars Sample Return backward contamination–Strategic advice and requirements : 48)

This is how the 2012 ESF report explained its decision at the time of the study:

The value for the maximum particle size was derived from the NRC-SSB 1999 report ‘Size Limits of Very Small Microorganisms: Proceedings of a Workshop’, which declared that 0.25 ± 0.05 μm was the lower size limit for life as we know it (NRC, 1999). However, the past decade has shown enormous advances in microbiology, and microbes in the 0.10–0.15 μm range have been discovered in various environments. Therefore, the value for the maximum particle size that could be released into the Earth’s biosphere is revisited and re-evaluated in this report. Also, the current level of assurance of preventing the release of a Mars particle is reconsidered.

(Mars Sample Return backward contamination–Strategic advice and requirements : 3)

So NASA’s BSL-4 recommendation goes back to the science of 1999 and a lot has changed in our understanding since then

WE DON’T YET HAVE THE TECHNOLOGY TO CONTAIN STARVED ULTRAMICROBACTERIA STILL VIABLE AFTER PASSING THROUGH 0.1 MICRON NANOPORES - A LIKELY SCENARIO FOR MARS - EVEN INDEPENDENTLY EVOLVED ULTRAMICROBACTERIA COULD TRANSFORM OUR BIOSPHERE OR HARM HUMANS - E.G MIRROR LIFE

Text on graphic: ESF study requires at most one particle released from the facility of ANY SIZE above 0.01 microns and 100% CONTAINMENT ABOVE 0.05 microns - this requires breakthrough technology as the methods used by current air filters couldn't achieve it

Below maximum penetrating particle size: Filters rely on jostling of particles by air molecules until they hit a fiber by chance.

Above MPPS: Particles are comparable in size to the gaps between fibers and are stopped by hitting them.

(Application of Electrospun Nonwoven Fibers in Air Filters : Figure 1)

Recent air filter technology reviews don’t mention any attempts to achieve 100% containment above any size. Also they don’t mention anything approaching 1 in a million chance of releasing a single particle in the lifetime of a facility at all sizes above 0.01 microns. See: (Application of Electrospun Nonwoven Fibers in Air Filters)

The 100% requirement would seem to need some new breakthrough technique rather than incremental changes such as more layers of filters or varying the spacing as those couldn’t get it all the way to 100% containment of such small particles.

WE ALSO NEED TO CONTAIN GENE TRANSFER AGENTS AT 0.01 MICRONS ABLE TO TRANSFER NOVEL CAPABILITIES OVERNIGHT IN SEAWATER AND AFTER A SIZE LIMIT UPDATE - MAY NEED TO BE PREPARED FOR A SCENARIO OF MIRROR-LIFE RIBOCELLS SIMILAR IN SIZE TO GENE TRANSFER AGENTS - AND NONE OF THE STUDIES MENTION PRIONS

Text on graphic: Size limit 1999 to 2012: 0.2 microns

ESF Size limit (2012): 0.05 microns

The European Space Foundation study in 2012 reduced the limit from 0.2 microns to 0.05 microns after the discovery that these ultramicrobacteria are viable after passing through 0.1 micron nanopores

Next size limits review might reconsider ribocells – theoretical size limit 0.01 microns

Background graphic: SEM of a bacterium that passed through a 100 nm filter (0.1 microns), larger white bar is 200 nm in length (Passage and community changes of filterable bacteria during microfiltration of a surface water supply)

A self contained viable mirror cell from Mars might potentially be as small as a ribocell. Research since 2012 has made this seem increasingly plausible.

THE ESF STUDY IN 2012 SAID THE SIZE LIMIT AND LEVEL OF ASSURANCE NEEDS TO BE REVIEWED ON A REGULAR BASIS (AND MORE OFTEN THAN ONCE A DECADE) - THIS HAS NOT BEEN DONE AND NASA DOESN’T DISCUSS THIS RECOMMENDATION

NASA hasn’t mentioned this recommendation in the EIS - given all the other omissions it is possible the authors of the EIS never noticed it.

RECOMMENDATION 8: Considering that (i) scientific knowledge as well as risk perception can evolve at a rapid pace over the time, and (ii) from design to curation, an MSR mission will last more than a decade, the ESF-ESSC Study Group recommends that values on level of assurance and maximum size of released particle are re-evaluated on a regular basis

(Mars Sample Return backward contamination–Strategic advice and requirements : 21)

They mention the need for review since the MSR mission will last more than a decade. This is already a decade since that study in 2012 and the samples won’t return until more than two decades after the ESF review. A new size limit review is definitely required under their Recommendation 8. It also needs to look at levels of assurance, is 1 in a million enough at any level of containment, and if so at what levels of containment?

The next review may examine new research into extremely small early life cells such as ribocells with enzymes made from fragments of RNA instead of proteins (Maintenance of Genetic Information in the First Ribocell). Steven Benner and Paul Davies say the small 0.01 micron diameter structures in the martian meteorite ALH84001 are consistent with RNA world cells (‘Towards a Theory of Life’: 37). Panel 4 for the 1999 workshop estimated a minimum size of 12 nm in diameter and 120 nanometers in length for early life RNA world cells, if there is an efficient mechanism for packing its RNA (Size limits of very small microorganisms: proceedings of a workshop : 117).

As we learn more about the mystery of the first cell, these researches may lead to a review of the size limit to accommodate new ideas

We are a long way from solving the mystery of the first cell, but more and more of the puzzle- pieces are known. The problems, both dynamical and structural, have been identified, and for some, solutions proposed.

(Maintenance of Genetic Information in the First Ribocell).

NASA MIGHT BE ABLE TO USE AN AIRFLOW INCINERATOR AT 500°C IN THE FINAL EIS - HOWEVER, THIS IS NOT THE SAME AS HEATING ESCAPED PARTICLES TO 500°C AND MAINTAINING THEM AT THAT TEMPERATURE FOR MINUTES AND WOULD NEED TO BE DEVELOPED AS A NEW PROTOCOL BEFORE IT COULD BE USED FOR THE VERY SMALL ULTRAMICROBACTERIA AND EXTRATERRESTRIAL LIFE

This is a suggestion by one astrobiologist (private communication). Everyone agrees extraterrestrial life from Mars would be sterilized by a few minutes of heating to 500°C.

Here for instance is a summary by Rummel et al. saying that the sterilizing effects of heat or ionizing radiation would be broadly the same for extraterrestrial life as for terrestrial life.

If there were a life-form on Mars based on other than carbon-containing molecules, the energies holding such molecules together would not be much different than those for proteins and polynucleotides.

Hence, bond breakage by heat or gamma radiation should be similar for Earth and Mars life forms, and sterilization conditions for Earth microorganisms should eradicate microorganisms of similar size from Mars.

There is no absolutely optimal approach to decontamination under these circumstances, but enough is known about the relationships among organism size, repair mechanisms, and survivability, that the maximum survivability of any martian organisms can be estimated with some confidence.

(A draft test protocol for detecting possible biohazards in Martian samples returned to Earth : Page 10)

Chris McKay’s idea is to use an air-flow incinerator instead of an oven, which researchers do use sometimes. The standards for a biosafety class III cabinet for a BSL-4 laboratory do include an option to use an air incinerator instead of the second HEPA filter. See page 37 of (Primary containment for biohazards: selection, installation and use of biological safety cabinets)

Would an air incinerator be sufficient to contain the very small ultramicrobacteria, possibly ribocells, and extraterrestrial biology?

These might be effective as a way to contain very small cells, but we need to be aware that they are not rated as such or tested to do this. We have never had to contain ultramicrobacteria in any biosafety laboratory and we have no technology designed to do this.

If NASA with to explore this, it still needs a new EIS.

Once we know what needs to be achieved, NASA need to look into technology.

Then, I think once it goes through WHO, CDC etc there may well be:

It is too soon to propose a new technology before we know the requirements or the testing methods or who will evaluate it and how. However we can look briefly at some of the issues we would need to consider.

MARTIAN LIFE MAY BE SIGNIFICANTLY MORE RESILIENT TO HIGH TEMPERATURES THAN TERRESTRIAL LIFE - PERHAPS AN AIR INCINERATOR COULD WORK - BUT IT NEEDS TO BE EVALUATED IN A PROPER PROCESS JUST AS THE BSL-4 STANDARDS WERE

The NIH guidelines for research involving recombinant or synthetic nucleic acid molecules specifies that these air incinerators need to be tested against a challenge aerosol of hardy spores, either b. subtilis var niger spores, or b. stearothermophilus spores (NIH guidelines April 2019).

However, for a Mars sample return, it also has to contain potential Martian life potentially more resilient than terrestrial life after millions of years of evolution in the extreme conditions on Mars. It may have:

Then in addition

By the ESF requirement, it has to contain

Then Martian microbes could use a more resilient backbone than DNA for its informational biopolymer. In one experimental test of PNA heated for 150 to 200 ms

See : Fig 10 of (Thermal stability of peptide nucleic acid complexes)

In a test of melting for 200 ms,

See : Fig 4 of (Thermal stability of peptide nucleic acid complexes)

Mars could have more stable informational polymers through an accident of evolution, or through adaptation to ionizing radiation, or adaptation to high temperatures or both. Mars had subsurface hydrothermal systems in the recent past, and they may well be present today as well, and may well be a refuge for surface life at times when the surface is less hospitable.

In short, an airflow incinerator may be part of a future solution, but it couldn’t be added in at the last minute in an ad hoc way to “fix” the draft EIS.

There would be a lot of preliminary work needed before it could be considered as a solution. The EIS would need to restart with a new technology review based on examining whether such technology could be used to contain an alien biology to the required level of assurance. There seem to be many things that such a review would need to consider.

The standards would need to be developed with the same level of care that was used to develop the standards for BSL-4 facilities and Biosafety class III cabinets.

UNDER THE NEPA REQUIREMENTS NASA SHOULD COMPARE ANY ALTERNATIVE SUCH AS USE OF AIRFLOW INCINERATORS WITH THE REASONABLE ALTERNATIVE TO STERILIZE THE SAMPLES BEFORE THEY REACH EARTH WHICH SEEMS FAR EASIER AND WITH NO POTENTIAL FAILURE MODES

Perhaps this will be an option in the future. However, it is not clear why we would do this for NASA’s mission, since there is a far easier approach, to sterilize the samples before they are returned to Earth.

If NASA do pursue this approach of an air-flow incinerator, they should by NEPA requirements also consider reasonable alternatives such as presterilizing samples before they return to Earth.

NASA’S MISSION CAN BE MADE 100% SAFE FOR EARTH BY STERILIZING SAMPLES BEFORE THEY REACH EARTH - WITH VIRTUALLY NO EFFECT ON THE SCIENCE

However you CAN turn this into a mission that is 100% safe for Earth and that achieves all the same science objectives and indeed achieves far more, by sterilizing all Perseverance's samples before they reach Earth.

The EIS only briefly considers the suggestion to sterilize samples before they reach Earth. They say that this would compromise some of the scientific goals and discuss it no further. But if protecting Earth is our top priority we need to look a little closer, what scientific goals are compromised and by how much?.

Consideration of techniques to assess samples and for sterilization prior to returning to Earth:

.,..

Sterilizing the entirety of the material returned from Mars would compromise specific scientific goals, as outlined in the discussion of sterilization-sensitive science by Meyer et al. (2022) in the “Final Report of the Mars Sample Return Science Planning Group 2 (MSPG2)”

(MSR Campaign Programmatic EIS, DRAFT Mars Sample Return (MSR) Campaign Programmatic Environmental Impact Statement : 4–2)

The studies that are most sensitive are the ones that are relevant to the search for PRESENT DAY LIFE or recent life in Jezero crater. Those naturally are very sensitive to sterilization. We already saw that only 1 out of 7 types of measurement can be done after sterilization.

However, Perseverance is not targeting a site on Mars with a high chnance to have present-day life. The chance of returning present-day life is probably low since Perseverance isn’t designed to try to find it.

If Peseverance does return present-day life, it will be accidental. If we look at its main astrobiological science objective, to search for past life, almost half the measurements can be still be done.

A corollary of Finding SS-1 is that the other (up to almost) half of the measurements described by iMOST for investigation into the presence of (mainly molecular) biosignatures of ancient life (Objective 2.2) in returned martian samples are sterilization-tolerant

(Planning implications related to sterilization-sensitive science investigations associated with Mars Sample Return (MSR) : Table 2)

Three out of 10 searches for carbon chemistry and past life, and 13 out of 25 of the searches for ancient life are sterilization insensitive according to iMOST.

Meanwhile as NASA themselves conclude, virtually all the geology can be done with sterilized samples. 115 out of 160 measurements are sterilization insensitive for geology.

(The potential science and engineering value of samples delivered to Earth by Mars sample return: International MSR Objectives and Samples Team (iMOST) : Table 2)

If these were unaltered samples of past life protected from surface conditions for billions of years, we could still do past life science, but the materials would be potentially very sensitive.

We could do geology after sterilization but 15 of the experiments would be impacted.

But the samples have been exposed to millions of years of ionizing radiation indeed the youngest Curiosity mudstone exposure ages are 80 million years. This is enough for them to be thoroughly sterilized - and to lose nearly all past organics!

Perseverance can't detect the exposure age of the rocks it samples, and has virtually no chance of returning samples with interesting evidence of past life organics.

We will find that in reality, there is a near certainty that NASA won’t be able to do ANY of these studies for past or present day life.

That’s because of another mishap similar to the mishap that saw the authors of the EIS say that existing credible evidence says Mars is uninhabitable while another team is planning to look for present day life.

In a similar way, we’ll find that

Again this seems to be a case of two teams not talking to each other, not unlike the Mars Climate Orbiter mishap that we mentioned before.

Sterilization will have virtually no impact on the geological science studies as you yourself concluded, and especially once you add in the exposure age, so long as we use ionizing radiation.

But because of forwards contamination sterilization will have no impact on studies for past life either as there won’t be any recognizable traces of past life. That leaves present day life but well see that also will most likely be unrecognizable amongst the contamination unless the samples have tens or hundreds of thousands of ultramicrobacteria per gram (assuming very small microbes ijn nutrient poor conditions).

Perseverance could spot a biofilm probably. It couldn’t spot a few spores in the dust. This also makes the safety testing impossible too.

THIS IS AN EASY WAY TO MAINTAIN YOUR WORLD-LEADING ROLE IN PLANETARY PROTECTION - TO STERILIZE SAMPLES BEFORE THEY RETURN TO EARTH - WHICH MAINTAINS VIRTUALLY ALL SCIENCE RETURN FOR THIS MISSION - AND ALSO GIVES AN EASY PRECEDENT FOR OTHERS TO FOLLOW

You have another option here to maintain your world-leading role in planetary protection, with no risk of harm to Earth and to provide an example for other space agencies to follow.

This is the option of a pre-sterilized sample return. This is a simple way of keeping Earth 100% safe that other space agencies and private space can copy easily. Your draft EIS didn’t even look at this option although I and several others recommended it in the first round of public comments.

NEPA requires you to look at reasonable alternatives.

(a) Evaluate reasonable alternatives to the proposed action, and, for alternatives that the agency eliminated from detailed study, briefly discuss the reasons for their elimination.

(b) Discuss each alternative considered in detail, including the proposed action, so that reviewers may evaluate their comparative merits.
§ 1502.14 [links directly to legal text]

The samples can be sterilized in a satellite resembling those in Geostationary Earth Orbit but in a higher orbit with no risk of contamination of either Earth or the satellites in GEO. Other missions could use the same satellite for sterilization for their missions too. The sample tubes wouldn’t need to be opened, just sterilize the whole sample.

This will have minimal impact on geology. From your own EIS you don’t expect any present-day life.

I and seven others made this suggestion in the first round of public comments.

NASA’S 8.1 PPB CONTAMINATION OF THE SAMPLES BY TERRESTRIAL ORGANICS WILL MASK THE 0.1 PPB OF MARTIAN ORGANIC LEFT AFTER ONLY 70 MILLION YEARS SURFACE IONIZING RADIATION - PERSEVERANCE CAN’T MEASURE EXPOSURE AGES AND CURIOSITY’S YOUNGEST RELEVANT SAMPLE HAD ~80 MILLION YEARS EXPOSURE

Meanwhile, it turns out your permitted forward contamination by organics from terrestrial life will make it impossible to detect biosignatures of past life even in samples with only 70 million years of surface exposure. That is enough to reduce recognizable biosignatures from 100 ppb as found in a Mars meteorite with only 2 million years of ionizing radiation exposure to 0.1 ppb.

The rest of the original 100 ppb is not destroyed. But it is broken up and transformed into other usually short molecule organics. It is no longer possible to distinguish it from other forms of organics exposed in the same way.

(Rapid Radiolytic Degradation of Amino Acids in the Martian Shallow Subsurface: Implications for the Search for Extinct Life)

Perseverance’s engineers believe they achieved contamination levels for returned rock samples of

(Mars 2020: mission, science objectives and build. In Systems Contamination: Prediction, Control, and Performance 2020 : table 6)

Though it’s possible Jezero crater has samples with younger exposure ages than that, Perseverance doesn’t have the capability to measure exposure ages in situ.

Text on image: Example of how design decisions for Perseverance were based on engineering and geology rather than astrobiology.

This tube was used to collect the first sample from Mars.

For a geologist, it is exceptionally clean, at most 8.1 nanograms of organics and at most 0.7 nanograms per biosignature.

For an astrobiologist, 0.7 nanograms per biosignature is enough to fill at least 7,000 ultramicrobacteria with just that biosignature, e.g. glycine, or DNA (maximum volume 0.1 cubic microns per ultramicrobacteria)

Astrobiologists need 100% clean sample containers with no organics. Their life detection instruments designed for in situ searches on Mrs can detect a single amino acid in a gram.

For engineers, sterilization would add an extra mission-critical failure point because they would need to open the sterile container for the tube on Mars.

SAFETY TESTING IS IMPOSSIBLE - WE CAN’T ACHIEVE EVEN A LOW LEVEL OF SAFETY ASSURANCE FOR THE PERSEVERANCE SAMPLES BECAUSE OF FORWARDS CONTAMINATION AND WITH CURRENT TECHNOLOGY - A MAJOR CHALLENGE EVEN WITH CLEAN SAMPLES TO ACHIEVE A LESS THAN 1 IN 2 CHANCE OF ONE VIABLE MARTIAN MICROBE IN A SAMPLE - NEAR CERTAINTY ALL THE PRESERVERANCE SAMPLES ARE SENT TO “HOLD AND CRITICAL REVIEW” AND ONLY RELEASED STERILIZED

This depends on the desired level of assurance. But if we require a high level of assurance that there is nothing in the sample that can harm Earth then it’s impossible to achieve this with current technology even for samples returned in a clean container with no forward contamination.

Kmineck et al agreed that it is not possible to prove safety by trying to predict effects of any life found.

During the Working Group’s deliberations, it became clear that a comprehensive assessment to predict the effects of introducing life in new environments or ecologies is difficult and practically impossible, even for terrestrial life and certainly more so for unknown extraterrestrial life.

The only way to prove safety is to prove that there is no life in the sample. This citation goes on to discuss how to test for life by checking for biosignatures.

This can achieve a level of safety assurance so long as the samples were free from forward contamination.

If we find no biosignatures we can be reasonably sure we haven’t sampled a biofilm, or a rock sample inhabited by a colony of Martian life. But we can’t rule out viable spores or propagules or other viable life in the dirt or dust brought to Jezero crater in the wind from distant or nearby places - or indeed, accidentally sampling only the edge of a patch of viable life.

So, if we wish to have a very high level of confidence that there is no life in the samples, there is no way in practice to achieve this by looking for biosignatures unless we destructively test most of the sample.

However, by Perseverance’s permitted levels of forward contamination, they are guaranteed to generate false positives for all the samples tested. So we can’t even achieve the rather lower bar they aimed for here.

The next stage is that the samples all go to “hold and critical review”.

This citation doesn’t say what would happen next.

(COSPAR Sample Safety Assessment Framework (SSAF))

CURRENT SCIENTIFIC OPINION IS THAT WE CAN’T PROVE SAFETY BY CULTIVATING POTENTIAL MARTIAN LIFE TO TRY TO SHOW IT’S SAFE AND WE CAN’T PROVE SAFETY BY CHALLENGING ANIMALS, PLANTS, MICROBES OR TISSUES WITH THE SAMPLES

Kmink et al agree with previous studies that it is not likely to be useful to try to get something to grow in the samples, to look for martian organisms to try to show they are safe, or use attempts to challenge plants and animal species or tissues (COSPAR Sample Safety Assessment Framework (SSAF)).

The issues are that we most likely can’t cultivate most or all martian organisms even if they would be able to survive fine on Earth - as we can’t cultivate most terrestrial life in the laboratory - that we can’t challenge all the possible life forms and ecosystems that could be affected, and it’s not wise to multiply potentially harmful organisms in a lab before you know what they could do to our biosphere.

The SSAF is in agreement with the position of the NRC Committee on Mars Sample Return Issues and Recommendations that “Attempts to cultivate putative organisms, or to challenge plant and animal species or tissues, are not likely to be productive” (NRC, 1997)

The major limitations of this approach are

  • that cultivation is not even possible for most terrestrial organisms and
  • challenge tests are typically tailored to one or a few targets of interest.
  • In addition, it is not considered advisable to multiply viable organisms that could have unknown and potentially harmful consequences.

Therefore, cultivation is not considered a diagnostic tool used by the SSAF. As an indirect consequence and due to the limited diagnostic scope that covers the potential avenues of causing harm, animal and plant inoculation are ruled out as well.

[Bullet points added]

(COSPAR Sample Safety Assessment Framework (SSAF) : page )

Another caveat here. Even if we find life as familiar as chroococcidiopsis, the question still arises – is it terrestrial or is it evidence of panspermia? We’d need to study it closely to see if it is sufficiently identical to any terrestrial strain.

WE CAN’T USE A GENETIC CATALOGUE TO RELIABLY DISTINGUISH TERRESTRIAL AND MARTIAN LIFE - BECAUSE OF “MICROBIAL DARK MATTER” E.G. ONLY 54 OUT OF 1250 GENERA IN PERSEVERANCE’S CLEAN ROOM CATALAGUE HAD ENOUGH READS TO IDENTIFY THEM ACCURATELY AND 4 SPECIES HAD LESS THAN 98.7% SIMILARITY TO ANY KNOWN TERRESTRIAL SPECIES

We currently have no way to reliably distinguish terrestrial from potential martian biosignatures. We could recognize familiar life like chroococcidiopsis which we already cultivate and have already sequenced. However, the vast majority of microbial species haven’t been characterized or sequenced or cultivated in the laboratory; the problem of “microbial dark matter” (The search for microbial dark matter)

The iMost team suggested a genetic inventory:

To appropriately interpret evidence for Mars life in returned samples, we must be able to distinguish
between terrestrial contaminates and indigenous martian life. For this reason, a genetic inventory of
both the spacecraft and sample processing/analysis facilities is critical … A genetic inventory
represents an important part of the background information related to detection of genetic material in
Mars spacecraft and returned samples.

(iMOST : 94)

However the issue of microbial dark matter makes it impossible to achieve this goal. Hendrickson did an attempt at a genetic catalogue using 98 swabs from the floors of the clean room that would be used to assemble the Perseverance rover before assembly started. However,

So, over 1000 genera were known to be present but couldn’t even be identified. This is not unusual, indeed this is expected and normal.

They used the 16S RNA ribosome subunit for identifying microbial dark matter as it is very stable, and is the basis for the modern classification method for microbes and other organisms due to Carl Woese (The singular quest for a universal tree of life). It is a short section of RNA which gets mixed with proteins to make up the structure of the ribosome used to translate RNA into proteins.

We are certain to detect many novel sequences like this after taking them to Mars and back. So we will get many genetic sequence false positives, and it will be impossible to prove they aren’t martian.

SO ALL PERSEVERANCE’S SAMPLES WILL GO TO HOLD AND CRITICAL REVIEW - AND NO AMOUNT OF HOLDING WILL ALLOW THEM TO BE RELEASED SAFELY UNSTERILIZED

So in short we can predict the effects of safety testing in advance.

SO WHY NOT JUST STERILIZE THEM ALL BEFORE THEY GET TO EARTH

So why not just sterilize them all before they get to Earth.

There are many experiments testing for past life that can only be done with unsterilized samples. But all the samples have likely had 10s or hundreds of millions of years of surface ionizing radiation so we can’t do those tests with past life.

We will only detect present day life on Mars by an extraordinary fluke as we can’t detect even thousands of ultramicrobacteria per gram of sample with biosignature tests.

On the remote chance there is present day life in the sample abundant enough or different enough to be detected above the noise of terrestrial contamination, we have a chance of still detecting it was there after sterilization.

But we are not likely to return present day life in a mission focused on looking for past life unless it is very abundant or by an extaordinary fluke.

We will see that the experiments that scientists want to do to search for present day life can all be done in orbit using telerobotics. Even gene sequencing can be done in orbit, end to end from sample preparation to a read out of the results using the technology of SETG.

SEVERAL MEMBERS OF THE PUBLIC SUGGESTED USING HUMANS TO STUDY SAMPLES IN SPACE - BUT ACCIDENTS CAN HAPPEN IN THE BEST SAMPLE HANDLING LABES - AND WE NEED A PROTOCOL FOR THEM - THE APOLLO MISSIONS USED QUARANTINE BUT THIS NEVER HAD ANY EXTERNAL PEER REVIEW AS IT WAS DECIDED BEFORE NEPA

Some authors have proposed using humans to study the samples in space. The idea is that technicians who are prepared to risk their lives in interest of science would study the samples in orbit, as for the Anteus report (Devincenzi, 1981) or on the Moon (Schrunk et al., 2007 : 146), and then we return the samples to Earth once they know they are safe.

Several members of the public also suggested this idea of returning the samples to a space station where they would be handled by human volunteers in public comments to NASA’s draft EIS.

Their comments are listed amongst the others in the section above (THE MAIN CONCERN OF THE GENERAL PUBLIC IN THEIR COMMENTS ON THE EIS WAS RISK OF HARM TO HUMAN HEALTH AND EARTH’S ENVIRONMENT - 50 OUT OF 63 COMMENTS IN THE FINAL EIS)

THE APOLLO QUARANTINE POLICY WOULD FAIL PEER REVIEW TODAY - IT WAS JUST SEEN AT THE TIME AS A WAY OF PROTECTING AGAINST THE FASTEST SPREADING DISEASES

This may seem a plausible solution since the Apollo astronauts had 3 weeks quarantine to protect Earth’s biosphere. The same approach was used to protect technicians who handled the Apollo samples in the laboratory. Technicians had to go into quarantine at least twice after a breach of sample containment during sample handling (When Biospheres Collide: A History of NASA's Planetary Protection Programs. : pages 241 and 458)

However the Apollo procedures were decided internally and only released on the day of launch, and this was never subject to legal review or public scrutiny (When Biospheres Collide: 452).

Carl Sagan gave the example of leprosy for the “vexing question of the latency period” (The Cosmic Connection – an Extraterrestrial Perspective)

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 (, Leprosy, Key facts).

The Apollo 3 week period was a compromise. NASA commissioned Baylor university to design a protocol for them to use. Baylor university recommended a quarantine period of at least 30 days with 60 days preferrable (Comprehensive Biological Protocol for the Lunar Sample Receiving Laboratory : 22)

NASA decided on three weeks as a compromise between no quarantine and the recommended 30 to 60 days. Their reasoning was that if astronauts and technicians can get through three weeks without adverse effects, any pathogen in the lunar samples is not fast acting. They reasoned that this gives time to prepare a remedial action, if a slower acting agent spreads outside the laboratory.

Richard Bryan Erb was the manager of the Lunar Receiving laboratory from 1969 to 1970 (. The Early History of Canadian Planetary Exploration.). This is what he said about the quarantine protocols as interviewed in 1999:

Erb: The lab worked. It worked well. We had some problems with the breaches in the biological barrier, and people would get contaminated in the labs, and then we'd dump them into quarantine as well. We had projected that this sort of thing could happen and that we would have lab technicians exposed and have to add them to the crew that was being quarantined. I believe it was a reasonably rigorous quarantine and an effective demonstration that there were no effects of the lunar material that showed up quickly.

You never know whether something might show up in thirty years. There are viruses and things that will show up long after the fact, but the theory was that if you can go through a quarantine for three weeks, which was the time set, without adverse effect, then you're obviously not dealing with something that is rapidly reacting and dangerous, so you would have time to prepare a remedial action. It was a good trade, I think, between a hazard, which was not very likely, but a risk of perhaps life on Earth, which was immense. So it was one of those fundamentally indeterminate things, and you just had to make a judgment call.

(, NASA Johnson Space Center Oral History Project Edited Oral History Transcript)

THEN THE SAFETY OF THE CREW TRANSCENTS THE QUARANTINE REQURIEMENT - SO IF AN ASTRONAUT OR TECHNICIAN DID BECOME ILL WITH A FAST SPREADING DISEASE - THE AFFECTED PERSON WOULD BE IMMEDIATELY RELEASED FROM QUARANTINE

Carl Sagan and Cyrus Levinthal raised the issue that “in emergencies the safety of the crew transcends the quarantine requirement.” in a meeting of the Planetary Biology Subcommittee in 1967 (. Lunar Receiving Laboratory Project History : 34)

Then, there is the vexing issue of serious medical incidents - not necessarily caused by the samples. If one of the Apollo astronauts became seriously ill and needed urgent treatment that wasn’t available within the quarantine facility, NASA’s stated plan was to immediately take them out of quarantine and to a hospital, as an authorized breach of quarantine (When Biospheres Collide: 229)

If a serious medical emergency had occurred that was beyond the capabilities of CRA [Crew Reception Area] equipment, NASA would have rushed the afflicted person from LRL to a hospital, regardless of quarantine requirements.

Although such a situation did not occur, this was another example of NASA’s policy to prioritize the lives of its people above back contamination requirements.

Suppose a technician in quarantine had a sudden medical condition such as a heart attack, unrelated to sample handling, that required urgent expert attention in a hospital. Suppose even that a technicians life-threatening condition is suspected to be caused by the sample. It would be hard to legally or ethically justify keeping the technician isolated, unless there was clear proof that removing them from quarantine constituted an overriding significant danger to others.

Even if something turned up that was pathogenic, deadly, and contagious, and we knew it was transmitting rapidly between technicians in quarantine, it would still be hard to know what to do, as Erb said interviewed in 1999 that they fantasized about the need to sacrifice everyone and buldoze it if they got a fast spreading disease:

Erb: You know, you fantasize about some of these scenarios, too. I thought supposing we do find something really deadly. What is the action? And it went through our minds that, well, you might, in fact, have to sacrifice everybody in the laboratory and bulldoze it under 100 feet of dirt.

(NASA Johnson Space Center Oral History Project Edited Oral History Transcript)

They couldn’t actually do that, it is of course not ethically acceptable and would be illegal. But what do you do?

The ethical conundrum here is an unknown and probably low probability of severe risk to Earth’s environment or to other humans or organisms is difficult to balance against the immediate certainty that without treatment an individual may die. The legal issue is one of human rights; could a technician legally be kept in quarantine in this situation, even if it is transmitting person to person in the laboratory, when it is known that removing them could save their life?

So any quarantine measures would be likely to adopt a similar policy to the one for the Apollo astronauts, that the quarantine would be breached if a technician’s life was at stake, while taking precautions to try to limit further spread. It would be ethically difficult to argue for any other policy. However if this is the policy, it significantly reduces the capability of the quarantine procedures to protect Earth.

So, quarantine can’t be used to protect Earth from putative martian organisms with unknown capabilities.

OTHER ISSUES WITH QUARANTINE - CAN’T KEEP OUT LIFELONG SYMPTOMLESS CARRIERS LIKE TYPHOID MARY OR DISEASE OF CROPS OR MIRROR LIFE

The length of quarantine period is just one of many issues. Once experts on infectious disease get involved they will find many other issues.

Once the issue is raised of possible pathogens of humans, the Occupational Safety and Health Administration in the USA is sure to declare an interest for questions of quarantine. The WHO is likely to declare an interest at an international level (. Updating Planetary Protection Considerations and Policies for Mars Sample Return. ).

These experts on infectious diseases are sure to raise the issue of a lifelong symptomless carrier / superspeader of an unknown pathogen. The best known example, which any infectious disease expert will know about, is Typhoid Mary, who had to be isolated through to her death because she was a spreader of typhoid, but never showed any symptoms of typhoid herself (. Mary Mallon: First Asymptomatic Carrier of Typhoid Fever). Quarantine periods are based on the body clearing the pathogen. But how do we know our bodies would clear a Martian pathogen ever?

No quarantine period can be long enough for a lifelong symptomless carrier, or indeed a life long or long term carrier with symptoms as with immunocompromised COVID patients (. Researchers tie severe immunosuppression to chronic COVID-19 and virus variants. ), or HIV patients. This may be a possibility for a novel pathogen based on a novel biochemistry, that our immune system doesn’t recognize as life, and so, can’t clear from the body.

Also, in a similar issue, quarantine can’t protect Earth from mirror life or indeed fungal diseases, or other pathogens which are harmful to other plants or Earth’s biosphere but don’t harm humans. Two zinnia plants on the ISS died of a fungal disease fusarium oxysporum probably brought there on an astronaut’s microbiome.

Mold growing on a Zinnia plant in the ISS. The mold fusarium oxysporum likely got to the ISS in the microbiome of an astronaut (Genomic Characterization and Virulence Potential of Two Fusarium oxysporum Isolates Cultured from the International Space Station). Two of the four infected plants died (How Mold on Space Station Flowers is Helping Get Us to Mars)

Human quarantine wouldn’t be a reliable method to keep a pathogen of terrestrial plants out of the terrestrial biosphere, at least until we know if there is life on Mars and what its capabilities are.

QUARANTINE ALSO CAN’T KEEP OUT DISEASES THAT ARE SYMPTOMLESS IN MOST YOUNG HEALTHY HUMAN TECHNICIANS LIKE ASPERGILLUS

This fungal disease disease fusarium oxysporum is also an occasional opportunistic pathogen of humans (. Genomic Characterization and Virulence Potential of Two Fusarium oxysporum Isolates Cultured from the International Space Station.). but didn’t harm the healthy astronaut who brought it to the ISS. In the same way a fungal pathogen from Mars could be harmless to young healthy technicians but be devastating to people with various health conditions or immunocompromised.

The ISS has a preflight “Health stabilization program” which uses vaccination and a 14 day quarantine to help prevent upper respiratory infection and gastroenteritis (. Health Stabilization Program V1 4.4.2.4). But this of course is not able to keep out crop pathogens or human pathogens that are rarely harmful to healthy people.

As another example, Aspergillus Flavus and Aspergillus niger are amongst the most common fungal spores in the HEPA filters on the ISS and found at relatively high concentrations compared to US homes (. Mold species in dust from the International Space Station identified and quantified by mold-specific quantitative PCR. ). Human quarantine couldn’t keep these out either as they can lead to harmless colonization of healthy humans but harmful pathogens of immunocompromised.

The blue green algae chroococcidiopsis are sometimes found in the human microbiome including in the nasopharynx (upper part of the throat behind the nose) (. Nasopharyngeal Microbiota as an early severity biomarker in COVID-19 hospitalised patients. ) and martian life might be pre-adapted to warmer temperatures.

The planetary protection literature rarely mentions these issues with quarantine. As we saw, Sagan raised the issue with using a quarantine period to protect Earth’s biosphere from an unknown biohazard as early as 1973 (, The Cosmic Connection – an Extraterrestrial Perspective : 130).

These issues aren’t discussed in either the 2009 NRC sample return study(. Assessment of planetary protection requirements for Mars sample return missions. ) or the 2012 (. Mars Sample Return backward contamination–Strategic advice and requirements ) ESF sample return study. This is an example that shows how vast the field of planetary protection is. Even though the 2009 NRC study is very extensive, it couldn’t cover everything and they didn’t look closely at the issues of quarantine.

This topic seems to have had little or no attention in the planetary protection literature since Sagan’s remark in 1973. There have been papers on quarantine since then but they don’t look at the wider picture of the latency period or symptomless spreaders, and so on.

All I have found so far is that interview with Erb where he briefly mentions that these questions will need to be considered again

Erb: It'll be interesting to go through this again as we tackle Mars samples return, because in three or four years we'll be coming back with samples from Mars, and we'll have to think through all the same decisions, but now with, I think, a much greater likelihood of life forms from Mars.

(NASA Johnson Space Center Oral History Project Edited Oral History Transcript)

NASA will have to work through this at some point if they continue with their current plans .But so far it isn’t even mentioned in the draft EIS. Clearly no-one in the NASA teams have given it any thought so far.

Once they do, and there is no way they can ignore this issue indefinitely - as they involve other agencies like the CDC in their planning they will find that there is no solution to the quarantine issues for human technicians studying Martian samples in terrestrial laboratories.

At least - there are no solutions that are acceptable according to modern ideas.

Quarantine may be useful in the future for some scenarios. Even then it couldn’t be used in all scenarios, as the example of mirror life shows. It would also be either challenging or impossible to use quarantine to keep out fungal diseases of humans, higher life or microbes, depending on the disease. There may be some pathogens that could be kept out using quarantine but it is hard to think of an analogue like this that is biologically plausible for Mars.

SO WE HAVE TO RETURN ANY SAMPLES TO A TELEROBOTIC FACILITY NOT STAFFED BY HUMANS

So, at least until we know the scenario we face on Mars, we have to return bonus samples too, to a telerobotic facility. We can’t let humans anywhere near them unless we can be 100% sure there is no possibility of a lab leak.

But if we are returning it to a telerobotic facility - how about putting it in space and operating it from Earth?

This wouldn’t have been a realistic solution as recently as a couple of decades ago. But now, with the incredible minmiaturization of instruments and the fast improvements in telerobotics it is a very feasible solution.

This is also a far lower cost solution than a space station staffed by human technicians.

An unmanned satellite also lets us study martian life without the forward contamination in a human occupied space station, as ultramicrobacteria can get through HEPA filters both ways.

SO LET’S MINIATURIZE THAT TELEROBOTIC FACILITY AND PUT IT IN ORBIT AROUND EARTH USING ARTIFICIAL GRAVITIY IN A SMALL CENTRIFUGE SO WE DON’T NEED TO OPERATE THE INSTRUMENTS IN MICROGRAVITY (PROPOSAL)

The current mission plan involves opening the sample tubes in a BSL-4 and doing preliminary tests on them. The gases collected from the sample tubes would be looked at inside the BSL-4. So there would be limited instruments available anyway - whatever we can put inside the small BSL-4 lab. With the current NASA plan humans would operate them but once we have risk of large scale effects human quarantine doesn’t work if there is a lab accident. So they would need to be operated telerobotically anyway.

But we have instruments of extraordinary precision designed for sending to Mars to search for life in situ.

We would study the bonus samples using instruments already designed for in situ searches for life biosignatures and processes on Mars. We can use a centrifugue for artificial gravity so the instrments don’t need to be redesigned for microgravity.

In this way also we build up a capability in space to anlayse future samples returned from Mars and elsewhere in the solar system.

The dust and dirt samples are just a start. There is likely no shortcut alternative to Sagan’s (Sagan, 1973):

“exhaustive program of unmanned biological exploration of Mars”.

WE HAVE EXTRAORDINARY INSTRUMENTS DEVISED TO SEARCH FOR LIFE IN SITU ON MARS NEVER SENT THERE - ALL 7 OF THE TOP PRIORITY PRESENT-DAY LIFE EXPERIMENTS CAN ACTUALLY BE DONE IN SITU ON MARS - AND SO CAN ALSO BE DONE IN ORBIT

This orbiting astrobiology lab is the equivalent of one geostationary satellite far above GEO. Humans can study the dust, dirt and atmosphere as they would on Mars using exquisitely sensitive in situ instruments designed for end to end sample preparation to analysis – these already exist such as the

Several instruments suggested for Europa:

(Report of the Europa Lander Science Definition Team)

So we are not in reality restricted to terrestrial labs. We can do all these experiments in situ on Mars with the advantage that the life is in its natural habitat or only recently removed from it - some microbes might die on the 6 months journeyu to Earth in darkness in a sample tube at low temperatures.

Astrobiologists are keen to send these missions to Mars but they seldom get selected and are always later descoped when they do. The main issue is that thye are not tested in space. So we can test them in space in this small satellite above GEO first, searching for life in the samples. Then we can use them in Mars in the future. Meanwhile these are tiny instruments of a mass of order single digit kilograms typically with modern technology - and we could send hundreds of them in a ton of equipment. We could send far larger instruments to a satellite above GEO.

STERILIZING SAMPLES IN SPACE ELIMINATES ISSUES OF PUBLIC OPPOSITION - WITH VIRTUALLY NO IMPACT ON SCIENTIFIC RETURN - AND SAVES ON UPFRONT COSTS IN THE 2020S

Sterilizing the samples in situ eliminates the risk of the general public being opposed and conspiracy theories. It also eliminates the issue of the presidential directive on large-scale effects or legal challenges to the EIS.

Also it removes the need for a heavy aeroshell, so it may have almost no difference on the return mission costs.

It saves on the cost of a sample-receiving facility. However this may not be large compared to the total budget.

In 2009 this was estimated at $121 million in real world dollars based on the 1999 requirements (Planning considerations for a Mars sample receiving facility: Summary and interpretation of three design studies : table 2).

However, this comes from a time when the idea was to test the samples in animals. Safety testing in terrestrial organisms is now not thought to be feasible. They say.

If a future version of the test protocol eliminates this requirement in accordance with state-of-the-art practices and refinements at the time the final protocol is implemented, the SRF design would potentially be simpler.

(Planning considerations for a Mars sample receiving facility: Summary and interpretation of three design studies : page 756)

Also, as we saw, it has likely virtually no impact on science return.

BONUS SAMPLES OF DUST, DIRT AND ATMOSPHERE, AND A PEBBLE FROM AN RECENTLY EXCAVATED CRATER

We can pre-sterilize containers, to send on the ESA fetch rover We only need to return a thimblefull of Martian dirt IN A 100% STERILE CONTAINER for it to be revolutionary.

We may resolve central questions in astrobiology if exceptionally lucky and return recently alive or viable present day life.

We can make a major first step towards asking the right questions for future searches.

The aim is to return

This shows how the atmospheric compressor works

First it uses the getter to remove evolved gases from the container wall. Then it closes one microvalve and opens another to get an atmospheric sample. Finally it closes both microvalves to the gas container and opens the vent to run more atmosphere through the compressor to collect dust in the filter

(Scientific value of returning an atmospheric sample from Mars)

We can detect life from the Gobi desert in dust in Japan (Aeolian dispersal of bacteria associated with desert dust and anthropogenic particles over continental and oceanic surfaces). So we have a chance of detecting viable or recently dead life from far away on Mars brought to Jezero crater in the dust stomrs.

If there is life locally in the dirt almost everywhere - most optimistic interpetation of Viking - we find it. Also if there are even a few cells per gram in the dust in the dust storms, we find it.

For this we need:

The pebble would ideally be from a rock that has organics in it, perhaps Perseverance could analyse the same stratum - but far from the pebble so as not to contaminate it.

Even if the pebble has high levels of organics, most likely it will be not due to life or it’s been chemically altered so much as to be unrecognizable. Or it might have spent a few million years on the surface in the very distant past and so be too degraded to be recognizable. But we do have decent chance of finding relatively unaltered organics from ancient Mars which might then lead us to new discoveries about the conditions back then, habitability, and some idea of what we are looking for.

Maybe Mars had abundant life in which case we have a chance. Maybe it didn’t have photosynthesis back then and the life was restricted to only a few locations even in Jezero crater in which case it will take a lot of searching to find it. But we can make a first step, a technology demo, and find out something about past organics and make a start on questions to ask next. And it will certainly count as an astrobiologically relevant mission.

We shouldn’t describe this to the public as a way to resolve central questions in astrobiology for past or present day life. It is most likely a first step that will end with as many questions as it resolves, but it will still be a major step forward and there is some potential for detecting present day life from Mars.

WE CAN ENHANCE THE MISSION WITH BONUS SAMPLES COLLECTED WITHOUT FORWARD CONTAMINATION IN A CLEAN CONTAINER SENT IN THE ESA FETCH ROVER AND RETURN THEM TO A SMALL CENTRIFUGE MARS SIMULATION CHAMBER ABOVE GEO

I also make suggestions for a way to greatly increase the science return by returning samples of the surface dust, dirt, atmosphere, and pebbles in a CLEAN container sent there in the ESF fetch rover.

This would be returned not to Earth but for remote study in the same satellite above GEO that we have for sterilizing the Perseverance samples.

We would study the bonus samples using instruments already designed for in situ searches for life biosignatures and processes on Mars. In this way also we build up a capability in space to anlayse future samples returned from Mars and elsewhere in the solar system.

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

This would be minimal cost for NASA as the instruments would be funded by universities.

Graphic shows: (NOAA’s new GOES-17 weather satellite has degraded vision at night) just to have an image of a geostationary satellite, not that it would be a $2.5 billion dollar satellite. SETG from (SETG: nucleic acid extraction and sequencing for in situ life detection on Mars) Astrobionibbler from (Path to Discovery) ISS centrifugal motor for plant experiments, dialable to any level from microgravity to 2 g (Centrifuge Rotor [biology experiment on the ISS])

Humans go nowhere near the satellite (human quarantine can’t keep out mirror life or fungal pathogens of crops or fungal diseases that only affect some people).

We can return subsamples of the dirt, dust, and pebbles to Earth but we would do 100% sterilization of those samples.

We would study unsterilized samples in a safe orbit above GEO until we understand what’s in the samples very well, then it is for us to assess whether to continue to keep them in orbit. It may take multiple missions to Mars before we understand it well enough to be sure that samples can be returned unsterilized.

We do need to be prepared for the possibility of a discovery of great interest, such as mirror life, that would mean we can NEVER return uncontained unsterilized samples to Earth. That is why we do all this. Because there is a significant, likely small possibility that Earth DOES need to be protected.

THIS MAINTAINS NASA’S POSITION AS A WORLD LEADER IN PLANETARY PROTECTION AND AS A PIONEER MAKING NEW DISCOVERIES ABOUT OUR SOLAR SYSTEM AND THE ORIGINS OF LIFE

In this way you can move forward from this EIS with a new approach that would

YOUR CURRENT COURSE BRINGS BACK MEMORIES OF THE CHALLENGER O-RING DISASTER - A SUPREMELY CONFIDENT ADMINISTRATION THAT HAS CUT OFF COMUNICATIONS WITH THE OTHER AGENCIES AND PLANETARY PROTECTION OFFICERS THAT WOULD HIGHLIGHT SO MANY ISSUES YOU DON’T SEE IN THE EIS

The way NASA are paying no attention to the main findings of their own previous planetary protection studies, or concerns of the public – and surely also NASA employees, brings back memories of the Challenger disaster and the O-ring failure.

https://www.youtube.com/watch?v=raMmRKGkGD4

Video: Richard Feynman debunks NASA

The issue with the O-ring that Richard Feynman demonstrated in that simple experiment using iced water were already known before the accident. But the investigation after the accident found that the high administration in NASA in a top down approach were not alerted to issues raised by some of its technicians (Rogers Commission, 1986 : 85).

Similarly there may be NASA employees attempting to alert the NASA administration to the backward contamination issues today. If so, NASA needs to listen to them.

THE SPACE SHUTTLE FLEW FOR MANY SUCCESSFUL MISSIONS BEFORE THE O-RING FAILED - ANOTHER PARALLEL AS THERE MAY BE MANY SAMPLE RETURNS BEFORE WE RETURN A PROBLEMATIC MICROBE FOR MARS - BUT WE NEED TO GET IT RIGHT AS FOR THE O-RING AND THERE WAS A POTENTIAL FOR FAILURE WITH COLD WEATHER AT ANY POINT FOR THE O-RING

Also in another parallel, the Space Shuttle flew successfully for many missions before the O-ring failed. In the same way we could return many samples from Mars with inadequate precautions before we encounter an issue with the protocols, but it’s not impossible we encounter a serious issue with the first samples.

The first samples are a precedent for future missions by NASA, other space agencies and private space companies. So we have to make sure our precautions to protect Earth’s biosphere are adequate from the get go.

WE SAW THAT NASA SHOULD HAVE DONE A SIZE LIMIT REVIEW AND LEVEL OF ASSURANCE REVIEW AS RECOMMENDED IN 2012 AND A NEW PLANETARY PROTECTION REVIEW

As we saw, according to recommendations in the planetary protection literature, NASA should have taken account of the ESF size limit review in 2012, and commissioned a new review of the size limit and level of assurance taking account of the views of the general public (. Mars Sample Return backward contamination–Strategic advice and requirements : 21) They should have set up fora to engage with the general public internationally so that we work together on the way forward (. Mars Sample Return backward contamination–Strategic advice and requirements : 59)

Also as we show in this paper, the science and our understanding of Mars has progressed so much NASA should have done a new Mars sample return study before doing the EIS because the one in 2009 (SSB, 2009) is way out of date.

They didn’t do any of those things.

That is why my preprint with a preliminary survey of some of the literature a Mars sample return study will need to review is 120,000 words long. Because NASA ddn’t do those things that would have led to new large scale sample return reviews and widespread feedback from other agencies like the CDC and the public generally and from other countries globally in public fora.

There is a need to raise public awareness not just to keep the public informed about preparations to protect Earth. I found that the topic is so multi-disciplinary and with so many connections between the disciplines that it needs many minds looking at it. I’d go further than the recommendation of the ESF study in 2012. We NEED this widespread engagement with the public and NEED to attract the interest of scientists in many disciplines not usually associated with space exploration, in order to find the best way forward.

There is no way my survey is a substitute for a new Mars sample return review, but it was important to cover some of the main topics such a review would cover in a preliminary way, since there hasn’t been a major review since 2009.

My preprint is here, and will give some idea of the challenges involved in doing a thorough Mars sample return back contamination study as a result of the advances in our understanding since 2009 - and because of the inherent multi-disciplinary nature of the issues and the complexity.

THIS SURVEY ALSO TURNED UP ISSUES SUCH AS SYMPTOMLESS CARRIERS FOR QUARANTINE NOT COVERED IN ANY PREVIOUS PLANETARY PROTECTION STUDY EVER - BACK TO APOLLO - THAT WOULD BE THE FIRST THING THAT WOULD BE UNCOVERED WITH A MAJOR FULLY FUNDED INTERAGENCY STUDY THAT INVOLVED THE CDC

We also need far more funding than for previous studies if we are to do an adequate job with multi-agency involvement and involvement of scientists of many different disciplines.

. NASA must protect Earth's biosphere even if Mars samples hold mirror life – a survey of recent planetary protection research plus new scenarios – for attention of space agencies and commercial space – with option to keep Earth 100% safe

As an example, some issues such as the issues with quarantine I mention here would have been uncovered decades ago with a better resources planetary protection division and with more work on liasing with the expertise in other agencies such as the CDC.

ISSUE OF FUNDING FOR NASA - NEED TO BE FUNDED FROM A SMALL BUDGET FOR THE EXPLORATION MISSIONS OR FROM THE SAFETY AND ASSURANCE BUDGET WHICH IS ALSO SMALL CONSIDERING IT COVERS ALL NASA OPERATIONS - A SEPARATE BUDGET REQUEST MAY BE NEEDED FOR PLANETARY PROTECTION OR EVEN A SEPARATE AGENCY TO DO THIS ADEQUATELY

So, part of the issue here is funding. We can’t expect NASA to do a very thorough job of planetary protection when it has to find the funds from its very limited budget for unmanned exploration.

As an example in the 2021 budget request, NASA has:

(NASA FY 2021 BUDGET REQUEST)

HOWEVER THE RECOMMENDATION TO STUDY IN A MINIATURIZED TELEROBOTIC FACILITY ABOVE GEO GREATLY REDUCES THE RESEARCH THAT IS NEEDED TO A STUDY OF STERILIZATION METHODS EFFECTIVE FOR ANY POSSIBLE ALTERNATIVE BIOLOGY FROM MARS - WHICH IS FEASIBLE UNDER THE CURRENT NASA BUDGET

However the proposal I gave here in my recommendation to sterilize all samples returned from Mars to Earth’s biosphere and studying the samples above GEO greatly reduces the amount of research needed into planetary protection before we return unsterilized samples for study closer to home.

With this approach of a miniaturized telerobotic facility above GEO we need research mainly into the levels of ionizing radiation needed to sterilize unfamiliar life possibly separately evolved with a more robust informational biomolecule than DNA or RNA and evolved over billions of years on Mars.

Once we settle on the level of sterilization and the method (likely gamma rays or X-rays) then we have little else to do by way of research before returning the samples from Mars.

This is why I think this is a way forward that would be especially useful to consider and would likely cost far less than approaches that involve initial containment on Earth once one considers the amount of research that needs to be done and the legal complexity for a mission that acknowledges the risk of large-scale harm to human health and the environment.

THERE MAY BE OTHER OPTIONS BUT THE MINIATURIZED ORBITAL TELEROBOTIC FACILITY CAME OUT AS A CLEAR FAVOURITE IN MY PRELIMINARY SURVEY - AND LONG TERM IF MARS HAS INTERESTING BUT HAZARDOUS LIFE LIKE MIRROR LIFE OR A NEW GENUS OF FUNGI - THEN WE COULD STUDY IT IN A FACILITY ON THE MOON WHICH BY THEN LIKELY HAS A PERMANENT HUMAN PRESENCE - WE COULD EVEN BUILD A PARTICLE ACCELERATOR ATTACHED TO A TELEROBOTIC FACILITY ON THE MOON

TWe may find other options. But so far, this came out as a clear favourite in my preliminary survey.

It can be scaled up to a larger international telerobotic laboratory like the ISS but in miniature (and a much smaller budget) with modules from other countries for analysis, sample preparation, sterilization, telerobotic handling.

If we find that Martian life is mirror life or in some other way so hazardous for Earth’s biosphere that it has to be contained far above a BSL-4, we may later need something larger and better resourced.

By then we likely have a permanent presence on the Moon. So, the best solution may be a telerobotically controlled laboratory on the Moon. Humans would still go nowhere near the facility but in a future where we have a permanent human presence on the Moon we could operate such a facility far more easily than one in GEO, for instance to install new robotic handlers, to add / remove materials, to service and maintain it etc especially if by then we need a large facility with large multi-tone instruments. We could even build a particle accelerator or accelerators on the lunar surface for such a facility to use.

NEED TO BUDGET TO PROTECT MARS IN THE FORWARDS DIRECTION TOO

Typically NASA spends about 1% of a robotic mission budget on planetary protection in the forwards direction. This is especially important now that we have

Perseverance’s mission is just the first step in such a progoram. Without 100% sterile landers it seems likely that any habitats on Mars would soon be contaminated by numerous species of terrestrial life, before we know what’s there, especially if terrestrial contamination can be spread in the Martian dust once it establishes a foothold somewhere on Mars.

This could also happen as a result of sample return missions if NASA or other space agencies or private space return samples from places on Mars considered to have a higher chance of present day life. By colecting the samples, a less than 100% sterile lander could irreversibly contaminate any local habitats, in the worst case making those samples our last record of species of microbes on Mars made extinct by the mission. This is especially possible in the scenario where Mars has early life that can’t compete with any modern life - a worst case for forwad contamination, best case for backwards contamination.

NO SINGLE MISSION COULD EVER FULFILL SAGAN’S “VIGOROUS PROGRAM OF UNMANNED MARTIAN EXOBIOLOGY” TO FIND OUT IF THE MARTIAN BIOSPHERE HAS EXTANT LIFE - ITS FULL DIVERSITY - AND WHETHER IT IS SAFE TO RETURN IT TO EARTH

There is no shortcut way to find out about the Martian biosphere if it has extant life. For instance Mars has ice boulders thrown up by a recent impact into the flanks of Olympus Mons on December 24 (NASA’s InSight Lander Detects Stunning Meteoroid Impact on Mars. Amongst many proposals for microhabiats on the surface of present day Mars, it may have cryoconite holes - dust warmed cavities with an ice lid forming a miniature greenhouse filled with fresh water - common in the McMurdo dry valleys in Antarctica - but undetectable from orbit (Microorganisms on comets, Europa, and the polar ice caps of Mars) .

NASA’s many discoveries have uncovered a Mars that is far more varied in terrain than we expected from the early explorations. In its own way, it is as varied as Earth for microbes, and Mars has a total surface area similar to the land area of Earth.

THIS OPEN LETTER PRESENTS AN INSPIRING ALTERNATIVE FUTURE WITH 100% PLANETARY PROTECTION BOTH WAYS USING THE REMARKABLE NEW TECHNOLOGY NASA HAS DEVELOPED FOR A VENUS LANDER - HOTTECH

We can now go far beyond Viking and achieve 100% planetary protection both ways. This is because of advances in high temperature components for industrial ovens, oil wells, jet engines and engines of electric vehicles, and improved further by NASA's remarkable advances in technology for the Venus (HOTTech) program. In 2017 The Venus lander teams sketched out a design for a largely mechanical rover with minimal onboard electronics capable of functioning at Venus surface temperatures of around 500 °C, as part of Venus Rover studies. The researchers proposed that the same approach could be useful for planetary protection (Automation Rover for Extreme Environments : Section 6.2)

NASA’s techological capability for (HOTTech) has advanced in the most remarkable way in just the five years since that report. We now have the capability to build a fully functioning rover that can survive for months on the Venus surface at 500 C with all the components needed for a science mission (Long-lived in-Situ solar system explorer (LLISSE) Potential Contributions to solar system Exploration). The technology only reached this level of maturity in the last few years due to far-seeing investment by NASA in the future of Venus surface exploration.

We need similar far-seeing investment in the technology for 100% sterile rovers on Mars and throughout the solar system so that we are ready to explore the sensitive environments of the subsurface oceans of Europa, and Enceladus and the likely “mud-ocean” of Ceres. Nothing short of 100% sterile would prevent forward contamination in a submarine explorer in an extraterrestrial potentially habitable ocean.

Heating terrestrial life to 500 C or even 300 C for a few minutes will sterilize it completely. We can use this technology in the near future to send sample retrieval rovers with capabilities similar to Perseverance but 100% clean, able to drill well below the surface of Mars and return 100% samples of past life and any subsurface present day life.

WE CAN EXPLORE AND EXPLOIT MARS WITHOUT HUMANS ON THE SURFACE, AS PART OF A VIGOROUS PROGRAM OF EXPLORATION AND PERHAPS SETTLEMENT THROUGHOUT THE SOLAR SYSTEM

We can explore and exploit Mars without humans on the surface, settling the Martian moons and orbital space habitats, as part of vigorous exploration and perhaps settlement throughout the solar system. Humans and robots work together each doing what it does best. Torrence Johnson, Galileo Chief Scientist, put it like this in the foreword to Meltzer’s “Mission to Jupiter” (Mission to Jupiter: a history of the Galileo project)

Torrence Johnson: What we call robotic exploration is in fact human exploration. The crews sitting in the control room at Jet Propulsion Laboratory as well as everyone out there who can log on to the Internet can take a look at what’s going on. So, in effect, we are all standing on the bridge of Starship Enterprise

We use humans and robots each doing what it does best. Which might or might not involve humans on the surface of Mars but certainly humans in space in many locations in the solar system.

My aim with this open letter and my survey is to do everything I can to help make sure voices and concerns of the public are heard. My wish is that this will encourage space agencies to do a rigorous scientific review with full public involvement.

I am sure somehow, the public and other agencies will get their say, though I don’t yet see clearly how exactly it will happen. I hope this will help make sure this happens sooner rather than later.

NASA needs to plan in a more flexible way where we have a future that is inspiring and encourages space exploration and settlement for ALL scenarios,

We can do this in a way that leads to broadband communications with Mars ready and tested and in constant use early on, which will be a major asset for robotic missions, and many assets on the surface, all ready for humans in orbit. This leads to exciting missions in orbit around Mars. Then if the Mars colonization enthusiasts are correct in their assessment that Earth’s biosphere is safe for Mars and the Martian biosphere, if any, is safe for Earth, they can soon progress to the surface. If Mars has something that can never be returned like mirror life, we continue to explore from orbit. I talk about how stimulating a mirror life planet (or other exotic life) in our solar system can be for future space exploration and settlement throughout the solar system.

I expand on that also in the preprint and have an executive summary of that part of it here:

For more about this all, see my preprint

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 | Call to NASA to defer or withdraw EIS | Letters | BOOK: Preprint to submit to academic publishers

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