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

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

DRAFT: Call to NASA by experts in relevant disciplines
- to defer finalizing your Environmental Impact Statement for a Mars Sample Return mission
- or to withdraw your EIS
- because it hasn't addressed many serious issues raised by the public
- and lacks scientific integrity
- for instance the Mars Meteorite argument
- its most important planetary protection sentence, is
- rebutted on page 5 of its main cite to the National Academy of Sciences
- and the "Affected area" for environmental effects is
- restricted to the Utah Test and Training Range
- from the start of the process
- based on non peer reviewed arguments found only in the EIS
- instead of set to "Global" as in
- all previous Mars Sample Return Studies

This call to NASA was never sent (PEIS was finalized while working on this and NASA's answers to public comments showed that another approach was needed). Please see: BOOK: Preprint to submit to academic publishers

To sign this call to NASA, please email me at the contact address above with details of your name, area of expertise and affiliation (or former affiliation e.g. if retired) and let me know if you want to be added as a signature to call on NASA to defer the mission, or additionally, to withdraw it.

I am looking for experts to endorse this call to NASA, experts with an affiliation with some recognized organization (or retired) or who have published on relevant topics in peer-reviewed journals, including a wide range of relevant fields like public health, risk assurance, HEPA filters, meteorites, early life, synthetic biology etc. Also do check out the Endorsements by experts page and see if there is anything particular you'd like to endorse there.

It's especially useful if you can do a personal endorsement as a video or text. Do let me know via email if you can do that too.

Thanks!

Call to NASA from experts in disiciplines relevant to your final Environmental Impact Statement to return samples from Mars in the 2030s

Dear NASA,

Your Final Environmental Impact Statement for your Mars sample return mission is not ready to be finalized because it hasn't addressed many issues with it raised by the general public in response to your request for comments under NEPA, as outlined in this open letter

We do need to take care with the Mars samples. Experts are of the view that the risk is likely low, but the worst case is a potential for large scale effects on the environment or large-scale effects on human health.

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

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

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

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

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

NASA's second planetary protection officer Cassie Conley similarly said

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

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

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

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

A low risk of large-scale effects is highly significant as we see from the example of a house fire.

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

You can endorse that the "Affected location" should have been set to global from the start here on the endorsements page.

Also the serious issues raised by the public need to be addressed. For instance your most important sentence for planetary protection, about the Mars meteorite argument, is rebutted by its main cite, and the public are not alerted to this. Instead you give the impression of a consensus in favour of this reasoning.

NASA:

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

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

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

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

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

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

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

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

...

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

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

This is one of numerous issues which show that the EIS is not ready to be finalized. All four of your main planetary protection arguments fail scientific integrity. For the other three:

NEPA requires that the Environmental Impact Statements maintain scientific integrity.

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

Also the public submitted at least three reasonable alternatives to NASA's plans which you didn't consider.

They were never mentioned in the EIS and from the replies to public comments this is because NASA set narrow prescreening requirements that can only be satisfied by near clones of NASA's mission plans - all alternatives have to be able to definitively determine if its safe to return the samples unsterilized, and alternatives can't test the unsterilized samples in situ (so they have to return unsterilized samples to terrestrial labs).

This goes against the latest ruling by the Council on Environmental Quality in 2022 that an agency has to consider alternatives that don't meet the applicants listed goals but better meet other policies and requirements of NEPA and the agency

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

... Constricting the definition of the project's purpose could exclude “truly” reasonable alternatives, making an EIS incompatible with NEPA's requirements.

... Always tailoring the purpose and need to an applicant's goals when considering a request for an authorization could prevent an agency from considering alternatives that do not meet an applicant's stated goals, but better meet the policies and requirements set forth in NEPA and the agency's statutory authority and goals. The rule of reason continues to guide decision making in such contexts.

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

For many other examples of how your EIS fails central requirements under NEPA see NOT_READY_TO_FINALIZE. on the endorsements page.

Here is a screenshot with a shorter form of the letter, suitable for sharing in social media.

Text on graphic:

Affected location: Utah Test and Training Range (UTTR), Utah Global

Dear NASA,

All major Mars sample return studies say there's a likely low risk of large-scale harm to human health from the samples. The most recent study by the European Space Foundation says they should be assigned risk group 4, high risk of individual and community spread.

All major studies also agree on a likely low risk of large-scale harm to the environment. It wasn't appropriate to restrict the zone to a local zone in advance based on original non peer reviewed arguments only presented in the EIS itself. Your main Mars meteorite argument is rebutted by its own main cite, and many issues raised by the public have not yet been addressed.

This EIS is NOT ready to be finalized. Please defer or withdraw, and do consider the suggested reasonable alternatives that play to your strengths as an organization. Thanks!

We have until July 8th to ask NASA to defer the decision or withdraw the EIS, see below

But after that date, if they do finalize it, I will continue to ask them to withdraw it as not scientifically credible and for all the issues mentioned here.

We call on you to defer finalizing this EIS until you consider and fix the many issues identified by the general public in response to your request for public comments.

Signatures:

Additionally we call on you to withdraw this EIS

Signatures:

Personal statements

Feel free to add personal statements - in text or video format - about why NASA needs to defer finalizing the EIS or to withdraw it.

This will help to show to NASA that these are experts who have given the matter some thought and attention and it's also an opportunity to present particular points you wish to draw their attention to.

We have until July 8th to ask NASA to defer the decision or withdraw the EIS

NASA's final PEIS was published on June 8th. This starts a minimum 30-day "wait period"

Publication of the final PEIS begins the minimum 30-day "wait period," in which agencies are generally required to wait 30 days before making a final decision on a proposed action (NEPA, n.d., National Environmental Policy Act Review Process)

So we have until July 8th to ask NASA to defer the decision or with draw the EIS before it is finalized.`

Form to fill in to send an endorsement email to me

You can send an email to Robert Walker, robert@robertinventor.com

Or you can fill in this form which in most browser will make an email ready for you to send using mailto. It also gives an idea of what you need to say in your email.

The example paper is optional but would help to show you are a peer reviewed author in your area of expertise.

You can fill the affiliation field with whatever is relevant. Just asking for people who are expert in the relevat disciplines.

Name:
Affiliation (or former affiliation):
Relevant area of expertise:
Example paper:

Personal message:

Email:
Call NASA to:
Defer Nasa's Mars sample return final PEIS
Withdraw Nasa's Mars sample return final PEIS its Mars sample return final PEIS

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 | | Why this needs an open letter with endorsements | DRAFT: Call to NASA to defer or withdraw EIS | Letters | BOOK: Preprint to submit to academic publishers

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