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

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

DRAFT: Endorsements by experts of statements which raise major issues
- with NASA's plans to return samples from Mars in the early 2030s
- and suggest a reasonable alternative to resolve those issues
- also endorsements to support the Space Studies Board
- when they highlight NASA's need for external peer review for matters beyond their own sphere of excellence

Stopped after the first few requests before any endorsements were received (PEIS was finalized while working on this and NASA's answers to public comments showed that another approach was needed - this also didn't seem the right approach on reflection as academics are more used to the process of peer review).
Please see: BOOK: Preprint to submit to academic publishers

(Video: Endorsements by experts of statements about major issues with NASA's Sample Return MIssion EIS)

Please also check out the Letters page as I am doing open letters to various experts based on their specialty.

Letters

Please also check the preprint which I'll submit to journals for publication if NASA don't withdraw the EIS.

Your endorsements are not intended as peer review but just to endorse the statements I made to NASA.

If ready to endorse go here:

More simply you can just sign the letter saying NASA's EIS is not ready to be finalized.

These endorsements are to encourage NASA to take their responsibilities under NEPA seriously and to realize they do have to look at comments that raise serious issues. For my comments on their plans which I submitted in a timely fashion during the NEPA process, see this section in my open letter:

The endorsements are to accompany an open letter to NASA, which is nearly ready to send. The open letter is here:

NASA are required under NEPA to consider any major issues raised in a timely fashion during the comments period as mine were, and to look at major points of view on environmental effects, and to consider reasonable alternatives also submitted in a timely fashion as mine were.

However NASA are convinced that they have already shown that any environmental effects would not be significant and any health effects negligible, based on the Mars meteorite argument amongst others. They are confident that this argument is a consensus amongst scientists.

You can help a lot if you can endorse that the Mars meteorite argument is invalid.

You can also help by endorsing that the other three arguments they use are invalid. All four of these were only used previously in a non peer reviewed op ed. by Robert Zubrin, president of the Mars society which three planetary protection experts rebutted vigorously in the next edition of the Planetary Report. 

These endorsements are part of a very positive vision for a possible future for the Mars sample return and sample returns in the future, to return the samples to a miniature life detection lab above GEO. There are likely to be many solutions but this is one that NASA are legally required to consider under NEPA since I presented it in timely fashion during the NEPA process. I hope they can open out to consider a wide range of possible ways forwards. See:

At present NASA's final PEIS presents no alternatives except the obligatory "no action" and mentions no other views on environmental effects. except their own and has no mention of quarantine or any suggestion that health or environmental effects could be large-scale, even unprecedented, in the likely low risk but worst cases although that is the consensus of the major mars sample return studies.

Though many of the things I say are already backed up by peer reviewed sources, NASA has nobody left on their team with basic training in planetary protection. See:

Also see my response to the final PEIS:

The issue here is how to get NASA's attention and to help them understand that it is possible for their brilliant engineers and mission planners to make basic mistakes like this in a topic that is outside their own sphere of excellence.

NASA’s EIS is in a statutory wait period at present to be finalized by July 8th. This means there is an opportunity to encourage them to change direction and withdraw their EIS or at least not to finalize it yet with these numerous mistakes in it.

If you are a recognized expert on a relevant topic or discipline and wish to endorse any of these statements please email me at the email address at the head of the page.

The reason to endorse my statements rather than just talk to NASA directly yourself is that NASA are legally required to listen to anything I say that raises major issues with the EIS under NEPA that I said in a timely fashion during the NEPA commenting process. So I'm trying to use that combined with endorsements to get them to take their planetary protection responsibilities seriously.

It's the same for my reasonable alternative of returning samples to a miniature lab above GEO. The reason for focusing on that particular plan is because I made the suggestion in a timely fashion and they are legally required under NEPA to consider it and are not doing so, excluding it improperly. I hope if they do consider it they will open out and listen to other reasonable alternatives not submitted under NEPA. But for now it's the only leverage we have and it seems a good plan, I've given it a lot of thought, it plays to their strengths and does keep Earth 100% safe.

I know that many of those reading this will be keen on Mars colonization and keen for humans to go to Mars as soon as possible.

However, I expect many of you who are keen on Mars colonization will still want to make sure that

I am doing this open letter and asking endorsements because NASA's final Environmental Impact Statement fails on all those counts. For the details see

Headers of sections are like mini-abstracts
- hover mouse over left margin for floating table of contents
- skip to next as another way to get a quick overview of the open letter
- citations use short form with inline links to the papers for convenience
- headings in dark blue are hyperlinked to themselves for copy / paste

For this page for responses to your replies to comments in the EIS, as for the open letter, I do the citations in a way that's makes it easier to click through to the paper when reading online, without losing your place in the page here. I use a direct hyperlink to the online paper and add the page number if available.

I also often add the author and date like this (NASA, 2017, Europa Lander Study 2016 Report). It is easy to convert these short form citations to the long form in any citation format you prefer (e.g. with the google scholar button),

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 table of contents of all the section titles.

The skip to next / back links give another way to go through the open letter quickly. You can read the title of each section then read on to find more or click next The top level next lets you skip through the top lively headers like reading an abstract of the open letter.

For my background see About me.

Headers in dark blue are hyperlinked to themselves - this lets you copy / past them into other pages or emails to link to them. You can use the "copy header as link with minimal styling" to copy just the link itself, not the header and without text colour or the text size. This is useful if you want to link to it from another page or an email etc. Use Ctrl + click for no styling (though browsers often add their own styling as well as programs you paste the link into). The minimal styling sets the linked text to underline with a dark blue color. This only works for headers that I have added anchors to and linked to themselves - will do that to them all when finished but if the button shows or the header is coloured dark blue it's okay

Search this page

Search this page for (enter text to find)

Search for complete word only (if only one word entered):
Search for exact phrase

Endorsements to get NASA's attention as part of a combined approach of vivid planetary protection scenarios
- a new inspiring vision for the future for enthusiasts for human space exploration
- keeping Earth 100% safe (no appreciable risk) by returning samples to a miniature life detection satellite above GEO
- all materials returned to Earth are sterilized and never declared safe to return unsterilized
- rapid development of 100% sterile landers for Mars using modern high temperature technology to make Marscopters and eventually complete landers and rovers that sterilize themselves by heating themselves briefly to 300�C before they start their mission on Mars

Endorsements seems the main thing that could help to get their attention, as part of  a combined approach of

  1. vivid planetary protection scenarios such as mirror life, and a novel fungal genus from Mars that terrestrial life has never encountered in all its billions of years of evolution to show that we need to look at a likely low risk of large-scale and indeed unprecedented levels of harm - like the need to look at scenarios of the very low risk of house fires when designing a house to be fireproof with smoke detectors.

    (Smoke detector graphic from The EnergySmart Academy)  

    This for instance is about the mirror life scenario as an example of exotic biology. It's the one form of life there's a reasonable consensus about that it would work, life that's evolved from the mirror organics from the organics terrestrial life uses. .Although it would be independently evolved we can show that it is feasible because terrestrial life with all the chemicals flipped as in a mirror should still function.

    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.

    NASA has made many extraordinary geological discoveries on Mars, such as the CO2 geysers.

    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).

    So why would we assume that we will only find familiar life on Mars? It might have life as exotic as life based on mirror organics or even more unusual. But if Mars has mirror life then we would need to consider carefully about whether our biosphere would function the same way if we had mirror life mixed up with ordinary life at the microbial level.

    You can endorse these scenarios here:
    SCENARIOS. Endorse scenarios of life based on mirror organics from Mars
    - and a novel fungal genus no terrestrial organism has ever encountered similar to Aspergillus
    - as scenarios for a small risk of unprecedented harm to the environment or human health,
    - similar to the house fire scenarios that give us a reason to fireproof houses and install smoke detectors

  2. inspiring the humans to Mars enthusiasts with a different vision of the future, that we can have humans in space everywhere else, and it likely even inspires humans to Mars orbit, even if the Mars surface turns out to have life such as mirror life or a hazardous new genus of fungi that can never be returned to Earth

    Composite of photo from the Cupola of the ISS (Russian cosmonaut Dmitri Kondratyev (left), Expedition 27 commander; and Italian Space Agency/European Space Agency astronaut Paolo Nespoli in the Cupola, use still cameras to photograph the topography of points on Earth. Picture taken by 3rd crew member, Cady Coleman) and Hubble photo of Mars (, Photograph of Mars taken by the Hubble Space Telescope during opposition in 2003. 3)  

    You can endorse statements relevant to the future here:

    FUTURE. We don't know what we will find on Mars by way of astrobiology
    - we need to plan our missions in a way that is flexible enough to accommodate all possibilities
    - including futures where it is not possible for human astronauts to ever land on Mars and return
    - it is too soon to make mission plans orientated for particular goals such as to land human astronauts on the surface of Mars
    - we first need to understand Mars far better
    - whether it has a biosphere and if so
    - whether it is safe for the Martian biosphere to mix with Earth's biosphere
    - and even if it has no biosphere but has prebiotic chemistry with the very earliest steps towards evolution of life
    - it is a decision for our civilization and not just for NASA whether we introduce the anthropocene irreversibly
    - to the only other terrestrial planet within light years of Earth

  3. If we return samples to a lab staffed by human technicians we need precautions in place for a lab leak, since even the best maintained labs can have them on occasion. But there is no way to use quarantine to keep out mirror life, or indeed fungi that can be serious sometimes for vulnerable people. Indeed many terrestrial diseases can't be kept out using quarantine. This is a striking example to show how quarantine for a short period of time can't keep out fungi (the Zinnia plants on the ISS were stressed for other reasons but the fungal parasites didn't help matters and two of them died).

    Text on graphic: Mold growing on a Zinnia plant in the ISS. The mold fusarium oxysporum likely got to the ISS in the microbiome of an astronaut (Draft genome sequences of two Fusarium oxysporum isolates cultured from infected Zinnia hybrida plants grown on the international space station). (How Mold on Space Station Flowers is Helping Get Us to Mars)

    You can endorse statements about quarantine and the need to respond to lab leaks here:

    QUARANTINE. Endorse need for precautions to respond to lab leaks in any Mars Sample Receiving Facility
    - but quarantine of human technicians can't keep out lifelong symptomless carriers like Typhoid Mary
    - or many human diseases like Carl Sagan's example of Leprosy, latency period can be 2 decades
    - or fungal diseases of vulnerable humans, crops or other organisms
    - or life based on mirror chemicals that is pre-adapted to also use normal organics from infall from space
    - and that Robert Walker's scenario of a miniature life detection lab above GEO solves all human quarantine problems
    - at likely lower cost than a fully telerobotic biosafety laboratory without even small risks of escapes
    - due to terrorism, criminal damage, plane crashes, inexperienced operators and other issues

    The natural way to solve this is with a fully telerobotic biosafety laboratory but we have no experience of running a biosafety laboratory without human technicians and if we are operating the instruments telerobotically, what about doing it in orbit? That leads to the reasonable alternative based on the incredible shrinking life detection instruments we have today.
     
  4. A reasonable alternative that has potential to keep Earth 100% safe, not even low risk, with greatly increased science return with less impact on the timeline too and that plays to NASA's strengths as an organization.

    It's based on NASA and ESA's joint plan to search for life in situ on Europa from 2016.

    Graphic from (NASA, 2017, Europa Lander Study 2016 Report)

    It would be returned to above GEO in a safe inclined orbit in the Laplace plane so it can't contaminate satellites in GEO

    Graphic obtained by modifying the ESA graphic, (Oldenburg , 2019, , Mars Sample Return overview infographic )

    Those bonus samples are needed because with nobody left on their team with an understanding of planetary protection, NASA has permitted a level of contamination with terrestrial life that makes the Perseverance samples almost certainly of no interest to astrobiology past or present. See:

    Planetary protection officer John Rummel's image of a train wreck for the permitted levels of terrestrial contamination of the samples
    - one of the last things your planetary protection experts warned you about before you closed down the planetary protection subcommittee
    - risk of returning samples of no astrobiological interest [NEW]

    They would be returned to a very excellent Mars simulation chamber, rather like BIOMEX on the outside of the ISS but able to replicate Martian gravity, and daily and seasonal cycles.


    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 (Mojarro et al., 2016, SETG: nucleic acid extraction and sequencing for in situ life detection on Mars). Astrobionibbler from (Elleman, 2014, Path to Discovery) ISS centrifugal motor for plant experiments, dialable to any level from microgravity to 2g (Centrifuge Rotor [biology experiment on the ISS])

    I'm sure a university would be delighted to design and build one at its own expense, like the Michigan Mars simulation chamber. The cost to NASA would likely be minimal. Mainly the cost of the shell, solar panels, and the rocket launch. We can send about five times the payload to above GEO that we can send to Mars.

    I'm sure a university would be delighted to design and build one at its own expense, like the Michigan Mars simulation chamber. The cost to NASA would likely be minimal. See:

    Rough estimate of payload capacity to above GEO
    - with the Falcon Heavy allowing for station keeping for 15 years, and transfer from GTO, we should be able to send 20 tons at a cost of less than $100 million
    - with the Atlas V 541 as for Perseverance we can send nearly 5 tons to above GEO
    - compare 1.025 tons for Perseverance,
    - and even more capacity by 2033
    - so there isn't any issue with sending numerous small life detection instruments to above GEO

    There are numerous exquisitely sensitive life detection instruments now that we can send there with the amazing shrinking of technology.You can endorse those here

    No humans ever go anywhere near it and anything returned to the Earth's biosphere is thoroughly sterilized.

    You can endorse this reasonable alternative here:

    You can also endorse the alterative to sterilize all samples      

    You can also endorse Chester Everline's alternative of a deferred sample return, prioritizing in situ searches on Mars.  

    In a valid EIS, NASA should consider all reasonable alternatives so please feel free to endorse any or all of these that you consider to be reasonable, on the basis of your expertise.

  5. combined with rapid development of 100% sterile landers on Mars to prepare for a rapid biological survey in the near future by specifying components that can withstand a few minutes of heating to 300�C before they reach Mars based on modern chips able to run at 300�C (silicon on insulator), other high temperature equipment such as video cameras and sensors placed near jet engines, and in electric cars, and NASA's own HOTTECH program to develop landers for Venus able to function for months even at 500�C

    Main image: “Safely tucked inside orbiting habitat, space explorers use telepresence to operate machinery on Mars, even lobbing a sample of the Red Planet to the outpost for detailed study." (Telerobotics Could Help Humanity Explore Space) Tele-operated Centaur as an insert from: Carter Emmart / NASA Ames research center , Almost Being There: Why the Future of Space Exploration Is Not What You Think,

    You can endorse this here:

The aim here is to show that there is a reasonable alternative to consider. There may be many other alternatives. However, this one has legal standing as I proposed it under NEPA which should help them to pay attention. If experts have other suggestions do feel free to mention them in your endorsements.

The main other practical alternatives mentioned in the public comments requested by NASA under NEPA are to sterilize all samples returned to Earth, or deferred sample return, prioritizing in situ searches until we have a better understanding of what life there is on Mars if any.

Headers of sections are like mini-abstracts
- hover mouse over left margin for floating table of contents
- skip to next as another way to get a quick overview of the open letter
- citations use short form with inline links to the papers for convenience
- headings in dark blue are hyperlinked to themselves for copy / paste

For this endorsements page as for the open letter, I do the citations in a way that's makes it easier to click through to the paper when reading online, without losing your place in the page here. I use a direct hyperlink to the online paper and add the page number if available.

I also often add the author and date like this (NASA, 2017, Europa Lander Study 2016 Report). It is easy to convert these short form citations to the long form in any citation format you prefer (e.g. with the google scholar button),

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 table of contents of all the section titles.

The skip to next / back links give another way to go through the open letter quickly. You can read the title of each section then read on to find more or click next The top level next lets you skip through the top lively headers like reading an abstract of the open letter.

For my background see About me.

Headers in dark blue are hyperlinked to themselves - this lets you copy / past them into other pages or emails to link to them. You can use the "copy header as link with minimal styling" to copy just the link itself, not the header and without text colour or the text size. This is useful if you want to link to it from another page or an email etc. Use Ctrl + click for no styling (though browsers often add their own styling as well as programs you paste the link into). The minimal styling sets the linked text to underline with a dark blue color. This only works for headers that I have added anchors to and linked to themselves - will do that to them all when finished but if the button shows or the header is coloured dark blue it's okay.

How to endorse
- use the Endorse check boxes [MID EDIT]
- give me a list of the points you want to endorse and I'll add your name to them
- you can add your own personalized statements or videos or make additional points
- or endorse anything in the open letter or my comments not mentioned here yet

I will be emailing experts in various fields to ask for endorsements. Also if anyone reading this has relevant expertise and want to contribute an endorsement do say! Contact me at support@robertiventor.com

The easiest way to endorse any of these statements is to just indicate which ones you wish to endorse, e.g. METEORITES.1 IN_SITU.3 etc

I've added endorsement check boxes to the Meteorites argument section and will add to the rest of the page to make it easier.

I will then add your name to the relevant point(s) and a short description of who you are and your area of expertise. If you wish me to link to a profile or bio elsewhere or supply a description to use please do so, thanks!

It is a great help if you can also give a personalized endorsement saying in your own words what you endorse and if you can also supply a short video to embed or link to that's great! Hopefully this can help impress on mission planners and rocket scientists and engineers that there is something here they need to pay attention to. For more on this see:

Of course if you see any mistake however minor or major in any of these statements, please don't hesitate to tell me right away. Thanks!

Also I welcome suggestions to rephrase any points not yet endorsed. Sometimes it's been quite tricky to find a good way to phrase the statements and do feel free to suggest alternative phrasing especially in these early stages if you are the first to endorse a statement - any inaccuracies, ambiguities, etc.

Do suggest new points of interest to astrobiology or biosafety or other relevant fields
- this page is necessarily focused on my own comments and those of others who responded to NASA's request for public comments under NEPA
- however this is an opportunity to draw NASA's attention to other points of interest for your discipline
- I know that some astrobiologists feel their discipline is often neglected in the geology and engineering focused decision making at NASA
- so do please take this opportunity to draw NASA's attention to priorities for astrobiology that they may have overlooked

Legally NASA are only obliged to pay attention to my comments. However it is possible that this open letter gets significant attention at some point.

This is an opportunity to mention other priorities for astrobiology to draw attention of NASA to these priorities and to the perspectives of astrobiologists which are underrepresented in mission plans for Mars.

Because of the focus on my own comments, this page naturally tends to highlight particular views that I found of especial interest and wished to draw NASA's attention to.

However I'm keen to present the full diversity of views in astrobiology on this topic to NASA. So please feel free to add new points and raise new ideas in your comments too and any of your own suggested alternatives.

While it is of the nature of the situation that this open letter has to focus on my own suggestion and those of others who commented within the NEPA process, I am hopeful that this can lead to a much wider debate of the many ways we can move forwards and with a wide range of participation from the lay and scientific public.

I will add relevant new points to endorse as appropriate to these sections or new sections.

Short list of main points to endorse

If you can endorse any of these statements relevant to your own expertise this is a great help. I have used cites of the highest integrity already - but as I explained in the intro, need endorsements to show to NASA that my use of these cites is valid as we can't expect them to be familiar with the planetary protection literature or to understand basic planetary protection concepts.

To help explain the motivation and need for these endorsements I have added quotes from the relevant sections of NASA's final PEIS below some of them, and what NASA's own cites say - it is easy to check that they have no familiarity with the literature and had no process in place to prevent major issues in scientific integrity such as in the case of their most important argument, a cite that rebuts it. They don't alert the reader to this discrepancy, and from the background history and their lack of any members with relevant expertise or interests, this surely is simply because they didn't notice it.

To endorse a statement just tell me via email which one you endorse. To make it easier to identify them each section is labelled and identified. So for instance you could endorse METEORITES.1 or SRSAG2_GAPS.2 or METEORITES.1-7 or SRSAG2_GAPS.1-5 and so on.

I use letters to subdivide further. So for instance you can endorse RISK_ASSURANCE.2 to endorse all of point 2, or RISK_ASSURANCE.2.a if you just want to endorse the a case there.

Or alternatively copy / paste the statements you wish to endorse or indicate them in any other way that makes it clear which one(s) you endorse.

I've divided this up into sections:

METEORITES. Endorse that many terrestrial species couldn't survive ejection into space and months in vacuum and cold
- so we can't know in advance that ANY species of Martian life already got here in meteorites
- never mind ALL species in all scenarios
- and endorse that NASA's meteorite argument is rebutted by its own main cite

Skip to METEORITES.endorsements if ready to endorse

This is the first of four arguments that are the foundation of the entire EIS. See below:

NASA say that any life they return gets here better protected and faster in the meteorites that get to Earth from Mars after large impacts on Mars.

NASA:

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

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

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

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

The samples they 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.

NASA say in this passage that any life on Mars gets here faster and better protected in those meteorites than in their sample tubes.

Without this argument most of NASA's other arguments in the EIS fall apart.

Yet it is directly rebutted by both of the National Academy of Sciences cites that NASA's team thinks they have used to establish it as a scientific consensus.

This argument is even rebutted more briefly already on pages 4-5 of their main National Academy of Sciences cite for it. We can only assume that nobody in their team read the study carefully as far as page 5 of what is arguably by far the most important cite for planetary protection in the EIS.

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)

Actually we know where the most recent rocks to leave Mars came from, Zunil crater. It's hundreds of thousands of years old, and our best estimate with cratering counts is 700,000 years ago., at the latest half a million years before modern humans first evolved.

The rocks were also ejected from well below the surface, in the Martian cryosphere where the temperature is an ultracold -73 C (200 K) and the presence of life is very unlikely (unless the impactor that formed Zunil crater hit a local geological hot spot on Mars - these occur rarely with none known on present day Mars).

See: (MORE DETAILS - BECAUSE MANY BELIEVE THIS INVALID ARGUMENT)
our martian meteorites left Mars at least hundreds of thousands of years ago
- all come from at least 3 meters below the surface
- modeling suggests they all came from a depth of at least 50 meters
- many microbes that live in rocks need access to sunlight
- also many microbes are not adapted to live inside rocks
- also most of the martian subsurface is very uninhabitable
- uniform -73°C at a depth of 12 centimeters or deeper
- except at geothermal hot spots if any

NASA's own iMost team said:

“We cannot predict with any accuracy life's form and characteristics, whether it would be viable …, or whether it shares a common ancestor with life on Earth.”

(Beaty et al., 2017, iMOST : 88)

I've broken this up into many individual statements so that you can endorse some or all of them instead of a single statement where you need to endorse all or nothing - as there are many ways that the natural flux is very different from transfer of materials in the sample tubes.

Please feel free to endorse any of these statements, or add your own.

It is enough to endorse statement 1 alone, that the Mars meteorite argument is invalid.

METEORITES.endorsements

If Mars has native life:

.

  1. The Mars meteorite argument is NOT VALID at current state of knowledge. There are scenarios where Mars has native life which can grow on both Mars and on Earth but is not able to travel between the planets in a meteorite.

    Microbes similar to b. subtilis could get here in a meteorite on rare occasions. Most terrestrial microbes couldn't get here if they lived on Mars, or could only get here on very rare occasions (such as after very big impacts in the early solar system).
     
    Endorse - Click here when ready to email your endorsements to me
     
  2. "The microbes may NOT be able to survive impact ejection and transport through space.” (SSB, 2019, Planetary protection classification of sample return missions from the Martian moons : 45)
     
    Endorse - Click here when ready to email your endorsements to me
     
  3. surface salts, dust, and dirt from Jezero crater CAN'T mechanically become a Mars meteorite and the layers of surface rock that Perseverance samples are highly unlikely to be able to get into a meteorite or to survive the fireball of exit from Mars or the fireball of re-entry to Earth.

    See: "The sample may well come from an environment that mechanically cannot become a Mars meteorite." (SSB, 2019, Planetary protection classification of sample return missions from the Martian moons : 45)
     
    Endorse - Click here when ready to email your endorsements to me
     
  4. It's much harder for a microbe to get to Earth in a meteorite than in a sample tube sealed with a small amount of atmosphere at Mars atmospheric pressure
    See: (MORE DETAILS - BECAUSE MANY BELIEVE THIS INVALID ARGUMENT)
    our martian meteorites left Mars at least hundreds of thousands of years ago
    - all come from at least 3 meters below the surface
    - modeling suggests they all came from a depth of at least 50 meters
    - many microbes that live in rocks need access to sunlight
    - also many microbes are not adapted to live inside rocks
    - also most of the martian subsurface is very uninhabitable
    - uniform -73°C at a depth of 12 centimeters or deeper
    - except at geothermal hot spots if any
     
    Endorse - Click here when ready to email your endorsements to me
     

You can also separately endorse that the meteorite argument is rebutted by the National Academy of Sciences cites.

Their argument is valid for samples returned from the Martian moons Phobos and Deimos because any Martian materials on those moons have already survived impact ejection from space, the additional sterilizing effect of impact on the Martian moons, and haven't been pre-selected from the surface or gently sampled.

Both cites directly rebut the argument for samples returned from the surface of Mars.

  1. The National Academy of Sciences study (SSB, 2019, Planetary protection classification of sample return missions from the Martian moons : 45) rebuts NASA's Mars meteorite argument.

    NASA shouldn't have used this study to support the argument.

    NASA should have made it clear that this cite rebutted the argument. It is a basic failing of scientific integrity by NASA not to alert the reader to opposing views in cites used.

    Endorse - Click here when ready to email your endorsements to me
     

    NASA's final PEIS cites the National Academy of Sciences study to support a statement that potential Mars microbes would survive ejection from Mars.

    Here "the natural delivery of Mars materials" means meteorites that get to Earth as a result of large impacts on Mars that throw material into space:

    “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, …, 2019), …”

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

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

    The National Academy of Sciences cite says clearly that their reasoning does NOT apply directly to samples returned from the Mars surface such as the samples collected by Jezero crater.

    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)

    [emphasis on central point in red and caps added to draw attention to the discrepancy]


    Also on pages 4-5:

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

    .

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

    .

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

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

    If we wish to use the Mars meteorite argument to show that there is no risk of any scenario of invasive microbes from Mars. we need to demonstrate that in ALL plausible scenarios for martian life, ALL species we could return in sample tubes can also get to Earth safely in meteorites.

    NASA's final PEIS also describes the Mars meteorite argument as a consensus which they say the National Academy of Sciences affirms:.

    If you analyse what NASA wrote carefully, the sentence just says that the National Research Council affirms the consensus that Martian material travels from Mars to Earth which of course everyone has agreed on for decades.

    One of the reasons that the scientific community thinks the risk of pathogenic effects from the release of small amounts ( less than 1 kilogram [ 2.2 pounds ] ) of Mars samples is very low is that pieces of Mars have already traveled to Earth as meteorites. The National Academies of Sciences affirmed the consensus that Martian material travels to Earth when they developed the planetary protection guidelines for sample return from Martian moons, Phobos and Deimos (National Academies of Sciences, ..., 2019) ....
    (NASA, 2023, Mars Sample Return FINAL PEIS : 3–3),

    .However in the context of the rest of the paragraph and because NASA doesn't tell the reader that the National Academy of Sciences rebutted its argument, and doesn't as much as hint that that anyone thinks the argument is invalid, the reader is likely to get the impression that the consensus on Mars material also extends to a consensus on Mars microbes in the entire scientific community and that the National Academy of Sciences affirms it to be a consensus The consensus is the opposite, that it is not valid (on current stage of knowledge about Mars).

    2. For more on this, see: First clear example of the lack of anyone from the discipline of planetary protection (at least as normally understood)
    - your most important planetary protection sentence, the Mars meteorite argument,
    - was proved invalid long ago, for instance in the National Academy of Sciences 2009 study
    - and your 2019 National Academy of Sciences cite also rebuts this argument for samples from Mars      

    .

  2. The 2019 National Academy of Sciences study DID establish that it is safe to return samples to Japan from the Martian moons.

    However, it was central to their reasoning that any Martian material on Phobos or Deimos already survived ejection from Mars, impact sterilization on the Martian moons, and hundreds of thousands of years of ionizing radiation since the last impact on Mars.

    They say  their recommendations do NOT apply to future sample return missions from Mars itself.
     
    Endorse - Click here when ready to email your endorsements to me
     

    The reason the argument works for samples from the shallow subsurface of the Martian moons is because any material from Mars in their samples survived similar processes to a Mars meteorite.

    This is the basic argument in the report (they tried other approaches but this is the only one that had no issues with it)

    First any Martian material on the Martian moons left Mars at the latest at the time of formation of Zunil crater, the last impact to send material into space fast enough to reach Earth or the Martian moon. That's at least hundreds of thousands of years ago.

    They then compared what happens to any organisms in martian materials for a Phobos sample return with what happens to them in martian materials in a Mars meteorite that reached Earth recently (SSB, 2019, Planetary protection classification of sample return missions from the Martian moons 59). :
    • Phobos sample return: Ejection from Mars → Shock of impact on Phobos → Remains in top 10 cm of the Phobos surface at least since formation of Zunil crater → returned to Earth in the Phobos sample return
    • Meteorites from Mars arriving today: Ejection from Mars → traveled from Mars to Earth for hundreds of thousands of years, at least since formation of Zunil crater → fireball of reentry into Earth’s atmosphere and delivered to Earth.

    Most of what happened is the same for both, for the samples from Phobos or Deimos and for the Mars meteorites. Only one step is different between them.  

    1. Both had to survive ejection from Mars
    2. Both were randomly selected from the surface of Mars by impact cratering
    3. Both had to inhabit material mechanically capable of becoming a Mars meteorite.
    4. Both survived at least hundreds of thousands of years of ionizing radiation, on the surface of Phobos since the last impact on Mars
    5. The Phobos samples had an extra sterilization by impact on Phobos or Deimos
    6. The Mars meteorites had an extra sterilization due to the fireball of re-entry.

    The conclusion then follows through a detailed analysis comparing the sterilization of impact on Phobos or Deimos with the fireball of re-entry. The committee found that any microbes from Mars would be far more sterilized by the shock of an impact into Phobos than a reentry fireball to Earth because only the surface of the rock is heated during the fireball of re-entry (SSB, 2019, Planetary protection classification of sample return missions from the Martian moons : 40) . For this part of the calculation, the committee assumed a 10% survival of microbes (underestimating a likely 80 to 100% survival) (SSB, 2019, Planetary protection classification of sample return missions from the Martian moons : 40).

    The stages of the journey from Mars to Earth are similar.

    The committee found that this reasoning can't be used for samples returned from Mars, concluding:

    Therefore, the committee finds that the content of this report and, specifically, the recommendations presented in it do not apply to future sample return missions from Mars itself
    ((SSB, 2019, Planetary protection classification of sample return missions from the Martian moons : 4-5) \

    3. .

  3. The National Academy of Sciences study from 2009, the most recent major Mars sample return study, also rebuts NASA's Mars meteorite argument.

    It says clearly that it is NOT appropriate to use the Mars meteorite argument.:

    The potential hazards posed for Earth by viable organisms surviving in samples [are] significantly greater with a Mars sample return than if the same organisms were brought to Earth via impact-mediated ejection from Mars

    ...

    Thus it is NOT appropriate to argue that the existence of martian meteorites on Earth negate the need to treat as potentially hazardous any samples returned from Mars by robotic spacecraft.

    (SSB, 2009, Assessment of planetary protection requirements for Mars sample return missions : 47)

    NASA shouldn't have used this study to support the argument.

    NASA should have made it clear that this cite rebutted the argument. It is a basic failing of scientific integrity by NASA not to alert the reader to opposing views in cites used.

    Endorse - Click here when ready to email your endorsements to me
     
    NASA's final PEIS implies that the 2009 report also supported the Mars meteorite argument like this:

    The NRC acknowledged that since the 1997 report, additional information has been discovered regarding the environment of Mars and the existence of life in inhospitable Earth environments once thought to be incompatible to life. The NRC reaffirmed the conclusion that the potential for pathogenic effects from the release of small amounts of Mars samples is regarded as being very low. Additionally, those life forms found in extreme environments on Earth have not been found to have pathological effects on humans (National Research Council 2009).

    [The NRC didn't come to that conclusion about extremophiles either, they drew attention to shared virulence genes between an extremophile and closely related human pathogens]

    One of the reasons that the scientific community thinks the risk of pathogenic effects from the release of small amounts (less than 1 kilogram [2.2 pounds]) of Mars samples is very low is that pieces of Mars have already traveled to Earth as meteorites

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

    From the context, continuing from the previous paragraph, this gives the impression to the reader that the 2009 NRC report is part of a scientific community that uses the Mars meteorite argument to argue for harmlessness.

    The NRC study actually rebuts the Mars meteorite argument. It is a basic requirement of scientific integrity to alert the reader to this opposing view at this point. But NASA's EIS NEVER alerts us to this opposing view ANYWHERE attributed to ANYONE.

    The 2009 report came to a very clear conclusion that it is NOT appropriate to use the Mars meteorite argument.:

    The Survival of Organisms Ejected from Mars

    A question of major importance with respect to back contamination of Earth by mechanisms of panspermia is whether putative martian organisms could survive ejection from Mars, transit to Earth, and subsequent passage through Earth's atmosphere.

    The potential hazards posed for Earth by viable organisms surviving in samples [are] significantly greater with a Mars sample return than if the same organisms were brought to Earth via impact-mediated ejection from Mars

    ...

    Thus it is NOT appropriate to argue that the existence of martian meteorites on Earth negate the need to treat as potentially hazardous any samples returned from Mars by robotic spacecraft.

    (SSB, 2009, Assessment of planetary protection requirements for Mars sample return missions : 47)

    [EMPHASIS MINE]


    I drew attention to this discrepancy in one of my attachments. They do quote my comment but they don't acknowledge any discrepancy between the 2009 report and their EIS even though I quoted that very passage.

    Robert Walker

    "In 2009, the National Research Council examined the possibility of life transferred on meteorites said the risk is significantly greater in a sample return mission - and said they can’t rule out the possibility of large scale effects in the past due to life from Mars – NASA’s EIS instead claims microbes will survive transfer from Mars to Earth more easily in a meteorite than in a sample return mission but their sources don’t back this up
    (NASA, 2023, Mars Sample Return FINAL PEIS  : B59-60),

    .

    This is their response:

    .

    NASA:

    NASA addresses unknown risks directly in its planetary protection guidance, and in response, the MSR Program would, as stated in the PEIS (p. 1-6), “implement measures to ensure that the Mars material is fully contained (with redundant layers of containment) so that it could not be released into Earth’s biosphere.” Additionally, the PEIS details and references on pages 3-3 to 3-4 information on the unlikely risks from “life that can’t get to Earth on meteorites.

    (NASA, 2023, Mars Sample Return FINAL PEIS  : B59-60),

    Pages 3-3 to 3-4 are the ones quoted here - they do NOT mention the possibility of "life that can't get to Earth on meteorites".

    Incidentally this passage also misrepresents what the 2009 report said about life in extreme environments.

    Additionally, those life forms found in extreme environments on Earth have not been found to have pathological effects on humans (National Research Council 2009).

    [The NRC didn't come to that conclusion about extremophiles either, they drew attention to shared virulence genes between an extremophile and closely related human pathogens]

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


    The 2009 NRC review adds a counter example of hydrothermal vent organisms which are evolutionarily close to human pathogens

    “However, it is worth noting in this context that interesting evolutionary connections between alpha proteobacteria and human pathogens have recently been demonstrated for natural hydrothermal environments on Earth

    … it follows that, since the potential risks of pathogenesis cannot be reduced to zero, a conservative approach to planetary protection will be essential, with rigorous requirements for sample containment and testing protocols of life forms that are pathogenic to humans’

    (SSB, 2009, Assessment of planetary protection requirements for Mars sample return missions> : 46)

    The NRC citation is to two species of microbes that live in the hot hydrothermal vents on the sea floor. These are strains of the class epsilon-Proteobacteria (Nakagawa et al., 2007, Deep-sea vent ε-proteobacterial genomes provide insights into emergence of pathogens) now reclassified as Epsilonbacteraeota (Waite,et al., 2017, Comparative genomic analysis of the class Epsilonproteobacteria and proposed reclassification to Epsilonbacteraeota (phyl. nov.) )

    These organisms don’t harm us, but their close relatives can. Helicobacter can cause stomach ulcers and Campylobacter can cause acute gastrointestinal disease in humans (Cornelius et al., 2012. Epsilonproteobacteria in humans) These pathogens harm us through virulence genes they share with the hydrothermal vent organisms. The same adaptations that help them survive in their ecological niches in hydrothermal vents also help them survive in humans

    Although they are nonpathogenic, both deep-sea vent epsilon-Proteobacteria share many virulence genes with pathogenic epsilon-Proteobacteria, [they give a list of virulence genes, and other capabilities that enhance virulence]

    … these provide ecological advantages for hydrothermal vent epsilon-Proteobacteria who thrive in their deep-sea habitat and are essential for both the efficient colonization and persistent infections of their pathogenic relatives.

    “… It follows that, since the potential risks of pathogenesis cannot be reduced to zero, a conservative approach to planetary protection will be essential, with rigorous requirements for sample containment and testing protocols of life forms that are pathogenic to humans’

    (Nakagawa et al., 2007 . Deep-sea vent ε-proteobacterial genomes provide insights into emergence of pathogens) ]

    It is a VERY MISLEADING summary to summarize that section as

    Additionally, those life forms found in extreme environments on Earth have not been found to have pathological effects on humans (National Research Council 2009).

    In more detail these were their main points.

    • There must have been transfers of material from Mars to Earth and Earth to Mars numerous times in the past
    • So it is possible that terrestrial life was delivered from Earth to Mars, or that life had an independent origin on Mars and then was transferred to Earth
    • These transfers must have been especially common in the past [this is during the "late heavy bombardment" after the formation of the Moon with many huge impacts on both planets]
    • It is not possible to determine if any viable life got from Mars to Earth.
    • There is no evidence in the modern era of large scale or negative effects [on Earth's biosphere / ecosystems] caused by Mars meteorites.
    • But we can't discount the possibility that such effects happened in the distant past
    • It is not known if putative martian organisms would be able to survive ejection, transit and impact delivery to Earth
    • In a scenario with life on Mars it is possible that martian life could be sterilized by shock pressure heating during ejection, or by radiation damage during transit
    • Based on current evidence it's not possible to assess past or future negative impacts from the delivery of putative extraterrestrial life.
    • This is something that needs more research

    There I'm summarizing some of the points in this quote:

    Martian Meteorites, Large-Scale Effects, and Planetary Protection

    Impact-mediated transfers of terrestrial materials from Earth to Mars, although considerably less probable than such transfers from Mars to Earth, should also have occurred numerous times over the history of the two planets. Thus, it is possible that viable terrestrial organisms were delivered to Mars at some time during the early history of the two planets. As noted above, it is also possible that if life had an independent origin on Mars, living martian organisms may have been delivered to Earth. Although such exchanges are less common today, they would have been particularly common during the early history of the solar system when impact rates were much higher.

    Despite suggestions to the contrary,it is simply not possible, on the basis of current knowledge, to deter- mine whether viable martian life forms have already been delivered to Earth. Certainly in the modern era, there is no evidence for large-scale or other negative effects that are attributable to the frequent deliveries to Earth of essentially unaltered martian rocks. However, the possibility that such effects occurred in the distant past cannot be discounted. Thus, it is not appropriate to argue that the existence of martian meteorites on Earth negates the need to treat as potentially hazardous any samples returned from Mars via robotic spacecraft. A prudent planetary protection policy must assume that a potential biological hazard exists from Mars sample return and that every precaution should be taken to ensure the complete isolation of any deliberately returned samples, until it can be determined that no hazard exists

    ...

    Although exchanges of essentially unaltered crustal materials have occurred routinely through- out the history of Earth and Mars, it is not known whether a putative martian microorganism could survive ejection, transit, and impact delivery to Earth or would be sterilized by shock pressure heating during ejection, or by radiation damage accumulated during transit. Likewise, it is not possible to assess past or future negative impacts caused by the delivery of putative extraterrestrial life, based on present evidence.

    Assessing the potential for impact-mediated interchanges of viable organisms between Earth and Mars remains an active area of research that may eventually lead to a more refined understanding of the potential hazards associated with Mars sample return. Thus, the committee encourages continued support for research to assess the potential for impact-mediated interchanges of viable organisms between Earth and Mars.
    (SSB, 2009, Assessment of planetary protection requirements for Mars sample return missions : 47)

    4. .

You can also endorse various additional statements:

  1. There IS a consensus about the transfer of Martian MATERIALS from Mars to Earth (Treiman et al., 2000, The SNC meteorites are from Mars), established through comparison of the composition of bubbles of gases in the meteorites with the composition of the Martian atmosphere measured by Viking.
     
    Endorse - Click here when ready to email your endorsements to me
     
  2. It is also reasonably established that SOME EXCEPTIONALLY HARDY TERRESTRIAL MICROBES such as b. subtilis may have the capability on RARE OCCASIONS to transfer from Mars to Earth if it does occur on Mars (Mileikowsky et al., 2000, Natural transfer of viable microbes in space: 1. From Mars to Earth and Earth to Mars : 392).
     
    Endorse - Click here when ready to email your endorsements to me
     
  3. However, the consensus in all the major peer reviewed studies is that the Mars meteorite argument is INVALID (at our current stage of knowledge of Mars), as it requires ANY potentially invasive species of life on Mars in ANY scenario to be able to get here in Mars meteorites, not just b. subtilis on rare occasions.
     
    Endorse - Click here when ready to email your endorsements to me
     
    See: You never noticed that the consensus of all the major studies is that the Mars meteorite argument is invalid
    - this should be mentioned and analysed as
    - not only a majority view but a consensus in the major studies
    - none of your own cites argue for it
    - and I haven't been able to locate a single peer reviewed study that supports it
     
  4. The evidence that "some organisms would likely survive certain interplanetary transits" (NASA, 2023, Mars Sample Return FINAL PEIS : B-35)
    - is like evidence that some swallows can cross the Atlantic
    - finding swallows in the Americas doesn't tell us anything about whether starlings can cross the Atlantic (they can't)
    - similarly though the very hardy b. subtilis may be able to cross between planets (plausible though not proven)
    - there may be many martian species that can't cross interplanetary space,
    - and it might well be that NONE of them can get here.
    - and we can't tell anything about whether a species can cause large-scale harm to Earth's inhabitants or biosphere
    - from their inability to cross interplanetary space
     
    Endorse - Click here when ready to email your endorsements to me
     
    1. Most terrestrial species would NOT be able to transfer from Mars to Earth
    2. What matters for invasive species are the ones that DON'T get here
    3. Barn swallows can cross the Atlantic but starlings can't. Starlings are the invasive species here, causing over $1 billion of agricultural damage a year (European Starling : 16). Even terrestrial microbes can be invasive. The freshwater diatom Didymo causes major problems in New Zealand, because it can't cross oceans or even from one New Zealand lake to another without human help (Spaulding et al., 2010. Diatoms as non-native species)
    4. Similarly there are many possible scenarios where Mars has mirror life, or an invasive fungus or some other form of harmful microbe that doesn't have the capability to cross between planets on meteorites.
    5. Just as barn swallows co-exist with starlings, Mars could have life that can transfer between planets co-existing with life that can't transfer between planets.
          

    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

    Microbes can be invasive too. One clear example of an invasive terrestrial diatom is the freshwater diatom "Didymo" (Didymosphenia geminatum) which causes many problems in New Zealand (Spaulding et al., 2010. Diatoms as non-native species) �
     
  5. On rare occasions some meteorites might get to Earth faster but certainly NOT WITH BETTER PROTECTION for microbes.:
     
    Endorse - Click here when ready to email your endorsements to me
     
  6. The most recent Mars meteorites that are arriving on Earth today come from an impact on Zunil crater HUNDREDS OF THOUSANDS OF YEARS AGO, best estimate 700,000 years by crater count, (Do young martian ray craters have ages consistent with the crater count system? : 626). That's half a million years before modern humans evolved.

    So the MARS METEORITES ARRIVING TODAY certainly AREN'T GETTING HERE FASTER than material in the sample tubes would.

    It's likely that the first few meteorites from the Zunil crater did get here faster than Perseverance's samples 700,000 years ago but NOT BETTER PROTECED with the shock of ejection from Mars, the cold and vacuum of space and the fireball of re-entry to Earth.
     
    Endorse - Click here when ready to email your endorsements to me
     
  7. By various lines of evidence, the MARS METEORITES LIKELY COME FROM THE EXTREMELY COLD CRYOSPHERE on Mars which is extremely unlikely to have been colonized by present day life as they come from a depth of several meters, well within the cryosphere. Anywhere below 12 centimeters has a uniform temperature of around -73°C except for VERY RARE HOT SPOTS   (Möhlmann, 2006, Adsorption water-related potential chemical and biological processes in the upper Martian surface. : figure 2)
     
    Endorse - Click here when ready to email your endorsements to me
     
    1. The meteorites we get today come from at least 3 meters below the surface by the ionizing radiation effects by low levels of radioisotopes produced by cosmic radiation (Eugster et al., 2002, Ejection ages from krypton‐81‐krypton‐83 dating and pre‐atmospheric sizes of Martian meteorites : 1355)
       
      Endorse - Click here when ready to email your endorsements to me
       
    2. They come from at least 1 meter below the surface (Elliott et al., 2002, The role of target strength on the ejection of martian meteorites : 3) because they don’t show any sign of ionizing radiation from the sky on one side of the rock.
       
      Endorse - Click here when ready to email your endorsements to me
       
    3. Impact modeling may suggest a depth of 50 to 100 meters below the surface (Nyquist et al., 2001, Ages and geologic histories of Martian meteorites : 152).
       
      Endorse - Click here when ready to email your endorsements to me
       
  8. Though Mars has had hot spots in the past, none are known at present and they have been rare in the past, so without further evidence, it's unlikely the asteroid that hit Zunil Crater hit a rare hot spot.
     
    Endorse - Click here when ready to email your endorsements to me
     
  9. While it is generally agreed that Mars meteorites travel from Mars to Earth, it doesn't follow that native Martian life would be able to get here on a meteorite.
     
    Endorse - Click here when ready to email your endorsements to me
     
  10. Endorse that you don't know of any peer reviewed study that supports the Mars meteorite argument that any life that can be returned in a sample tube can get here better protected and faster in a Mars meteorite.
     
    Endorse - Click here when ready to email your endorsements to me
     
  11. Endorse that we don't know whether life on Mars would share a common ancestor with terrestrial life or whether we will find that there has ever been transfer of viable life from Mars to Earth.

    NASA's iMOST team put it like this said:

    “We cannot predict with any accuracy life's form and characteristics, whether it would be viable …, or whether it shares a common ancestor with life on Earth.”

    (Beaty et al., 2017, iMOST : 88)

    �
    Endorse - Click here when ready to email your endorsements to me
     

Also if you wish to follow this up further, do feel free to endorse any of the other things I say here in the open letter :

and here

Also, do feel free to add any other details from your expertise

SRSAG2_GAPS. Endorse that the Space Studies Board Review in 2015 found significant knowledge gaps relevant to Jezero crater
- in the SR-SAG2 study NASA relies on
- finding knowledge gaps for ways for terrestrial life could spread in Jezero crater
- and that some of these knowledge gaps have been confirmed such as significant possibilities for transport of biofilm fragments in the atmosphere
- and novel microhabitat suggestions

Skip to SRSAG2_GAPS.endorsements if ready to endorse

The background here is that the influential SR-SAG2 report from 2014 presents a picture of an almost uninhabitable Mars with life only possible within some uncertain regions that we can identify from orbit.

NASA and ESA independently raised issues with this report, saying amongst other things that there is a perception that the authors were too closely aligned with NASA's Mars Program Office. This lead to the unusual step of commissioned a joint new Space Studies Review of SR-SAG2 in 2015 just a year after publication.

There were two reasons why both agencies 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. ...

(Space Studies Board, 2015, Review of the MEPAG report on Mars special regions. : xi – xii).

The 2015 review by the space studies board found major knowledge gaps in SR-SAG2 relevant to Jezero crater. One of the most important of these knowledge gaps is about the potential for terrestrial life to be transported in the atmosphere.

Experiments since then support the finding that this is a major knowledge gap. For example, Billi et al.'s experiments establish that thin layers of a dried biofilm (microbial colony) three hundredths of a millimeter thick, can travel 100 kilometers in daylight in the light Martian winds before it is sterilized by the UV (Billi et al.., 2019, A desert cyanobacterium under simulated Mars-like conditions in low Earth orbit: implications for the habitability of Mars).

These knowledge gaps are for terrestrial life as neither review considered capabilities of Martian life. There may be scenarios with Martian biofilms already established on Mars and adapted to martian conditions over billions of years and that took thousands of years to colonize a microhabitat in Jezero crater.

Based on the knowledge gaps identified in the Space Studies Board review, you can endorse any of these as a significant change relative to SR-SAG2 that NASA needs to take account of in a valid assessment of the potential for native Martian life in Jezero crater:

SRSAG2_GAPS.endorsements

  1. Potential to find new microhabitats on the surface that we didn't identify in maps from orbit
    See: that maps made from orbit represent an incomplete state of knowledge about habitability and are subject to change as our understanding of Mars changes
     
    Endorse - Click here when ready to email your endorsements to me
     
  2. Potential to find new ways for life to transfer in the atmosphere, for instance recent research into biofilms only 3/100ths of a millimeter thick.
    See: that SR-SAG2 didn't adequately discuss transport in the atmosphere
     
    Endorse - Click here when ready to email your endorsements to me
     
  3. Potential to find surprising new microenvironments we could never spot from orbit - SR-SAG2 did give a list of 7 potential types of surface microenvironment but took this no further (With the cold salty brines Curiosity found, stable through to 6 am on the surface sometimes - as an example discovery nobody predicted and a potential future surprise could include caves, or micropores in salt or gypsum both possible in Jezero crater - or something nobody predicted)
     
    Endorse - Click here when ready to email your endorsements to me
     
    See; that SR-SAG2 only briefly considered implications of lack of knowledge of microenvironments - it gave a list of seven potential types of microenvironment that may occur on the surface of Mars but then took this no further
     
  4. The importance of biofilms - that martian life could set up home in places that would be uninhabitable otherwise by building a "home" covered in organic plastics (EPS) to protect it from stresses and increase habitability including perhaps Martian biofilms that have evolved to exploit surface conditions for billions of years
     
    Endorse - Click here when ready to email your endorsements to me
       
    The Space Studies Review of SR-SAG2 draws special attention to biofilms - where many microbes work together to build a microbial "house" by exuding plastic-like substances called EPS to protect themselves - and exude various biochemicals to make their new homes more habitable and protect themselves from adverse conditions much like the way we use our houses
  5. Endorse that both SR-SAG2 and the MEPAG review focused on capabilities of terrestrial life and so may underestimate the capabilities of potential Martian life.
     
    Endorse - Click here when ready to email your endorsements to me
     
    Martian life could have
    1. adapted to get transported in dust storms more easily
       
      Endorse - Click here when ready to email your endorsements to me
       
      See: Yes perchlorates in the dust are bacteriocidal for b. subtilis when irradiated with UV
      - but the effects are far less at lower temperatures or when mixed with dirt or dust
      - a shadow under a rock or a few microns of dirt eliminates most of the UV
      - a microbe imbedded in a crack in a grain is also more protected
      - UV is reduced up to 97% during dust storms
      - winds continue at night
      - the organic plastic compounds exuded by biofilms (EPS) and other modifiers would protect microbes
      - for instance EPS could protect microbes against oxidants like chlorates, and chlorites, or indeed hydrogen peroxide
      - and Martian life is likely to have evolved extra protective layers
      - or coated itself with iron oxides
      - or evolve special biomaterials to protect itself against UV and oxidants
       
    2. developed complex biofilms and other structures like the structures of desert mosses to make even very cold brines more habitable
       
      Endorse - Click here when ready to email your endorsements to me
       
      See: Could there be oases for these biofilms even in Jezero crater? Perhaps Nilton Rennó's suggestion of biofilms exploiting the brines Curiosity found could describe a suitable oasis?
       
    3. has had the time to colonize an inhospitable microhabitat even if colonization takes millennia or millions of years as often happens in cold places like Antarctica
       
      Endorse - Click here when ready to email your endorsements to me
       
  6. Endorse that it is a serious omission in NASA's Environmental Impact Statement to cite SR-SAG2 and not cite the 2015 review that found these knowledge gaps in it relevant to Jezero crater.
     
    Endorse - Click here when ready to email your endorsements to me
     

See also:

For more background see my response to NASA's reply to my comment here:

PLAUSIBLE_INVALID. Endorse that these arguments are invalid:
- NASA's argument that Mars has been uninhabitable for millions of years
- rebut: NASA will test the returned samples for present day life
- NASA's argument that Martian life would not be able to grow on Earth because of lack of its required nutrients and condition
- rebut: their own cite includes a microbe isolated from Canadian permafrost that can grow up to human blood temperature
- NASA's argument from ten example diseases that human pathogens have to co-evolve with humans giving near zero risk of pathogens from Mars
- rebut: tetanus and Aspergillus fumigatus are two examples with serious and often fatal effects not adapted to an infectious lifestyle in any organism
- along with the Mars meteorite argument (rebutted by its own main cite)
- these all build up to NASA's conclusion that environmental effects would not be significant and the public health impacts negligible
- you can endorse that this conclusion is not valid
- NASA should continue to use the conclusion of the European Space Foundation that the samples should be classified as risk group 4, (high risk of individual and community spread)
- and their own conclusions in the official video by their second planetary protection officer Cassie Conley that they need to contain the samples as if they were the most hazardous Earth organisms known

Skip to PLAUSIBLE_INVALID.endorsements if ready to endorse

These are the remaining three arguments that are the foundation of the entire EIS. See earlier section

The four main arguments in brief are:

  • that Mars is uninhabitable
     
  • that any life on Mars wouldn't be able to survive terrestrial conditions
     
  • that any Mars life would be unable to harm humans
     
  • that if there is life on Mars it already got here in meteorites

presented as either certainty or near certainty.

You can endorse that the Mars meteorite argument is invalid (at our current stage of knowledge about Mars) here:

For the other three arguments, please add your name if appropriate to endorse that these arguments are not valid.

PLAUSIBLE_INVALID.endorsements

  1. We have not established that Mars has been uninhabitable for millions of years
    - or that there is no life in Jezero crater
    - there are many potential microhabitats and scenarios for life on Mars and in Jezero crater,
    - including life adapted to spread during Martian dust storms for billions of years
    - spread in the wind to Jezero crater from distant habitats
    - indeed NASA plan to test the returned samples for present day life
     
    Endorse - Click here when ready to email your endorsements to me
     

    NASA's final PEIS says:

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

    NASA's 2022 from the National Research Council says:

    “The exploration of … Mars … will help establish whether localised habitable regions currently exist within these seemingly uninhabitable worlds”. (Origins, Worlds, and Life : 393 [Click on the X to go straight to page 393]).

    Also if we look at NASA's Mars science goals, the second half of Goal 1 is to determine if Mars still supports life

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

    (Mars science goals, objectives, investigations, and priorities: 2020 version : 9).

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

    • test these very samples for metabolism and respiration (Beaty et al., 2017, iMOST : 92).
    • experiment to see if they can get anything to grow from them (Beaty et al., 2017, iMOST : 93).

    See: No we don't have evidence Mars is uninhabitable [IN NEPA BOTH]
    - you even plan to test Perseverance's samples to see if any lifeforms detected from Mars are still alive
    and Your own cite for “existing credible evidence" that Mars is uninhabitable is actually about searches to see if "habitable regions currently exist " on Mars
     

  2. Although some extremophiles require extreme conditions others do not
     
    Endorse - Click here when ready to email your endorsements to me
     
    1. the only extremophile in Merino et al (Merino et al., 2021, Living at the extremes: extremophiles and the limits of life in a planetary context.: table 3) able to live at ultra cold temperatures, Planococcus Halocryophilus, with growth at -15 C and metabolic activity down to -25 C is also able to grow up to human blood temperatures 37 C with optimal growth at 25 C.

      So the results about extremophiles in Merino et al don't support the conclusion of NASA's biological safety report

      (INVALID CONCLUSION FROM THE DATA) "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.”
       

      Here is how they put it, with a few of the earlier sentences to give it context, with the relevant sentences highlighted in red:

      For example, could Martian material somehow interfere with the ability of photosynthetic bacteria in Earth’s ocean to fix carbon dioxide and produce oxygen?

      ...
      Planetary protection must consider not just human health directly, but the entire biota of Earth. Organisms evolve to live in a particular environment, and while some are generalists, others can only survive in very specific conditions. In all cases, organisms do not replicate if critical nutritional or environmental conditions are lacking. 
      ...

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

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

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

      Their only cite, Merino et al, has only one example that's a plausible Mars analogue in temperature range and it is a counterexample: Planococcus Halocryophilus: (Merino et al., 2022, Living at the extremes: extremophiles and the limits of life in a planetary context: table 3) Optimal growth at 25°C and up to 37°C. Showed metabolic activity down to -25°C, the lowest temperature tested ((Bacterial growth at− 15°C …) and may grow at ultra low temperatures too slowly to test in the laboratory). isolated from Canadian permafrost with ambient temperature around -16°C . (Merino et. al., 2019, Bacterial growth at− 15 C; molecular insights from the permafrost bacterium Planococcus halocryophilus Or1)

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

      Planococcus Halocryophilus

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

      (Merino et al., 2021, Living at the extremes: extremophiles and the limits of life in a planetary context.: table 3)

      See: In worst case scenarios microbes that live in extreme conditions on Mars would be pre-adapted to warm conditions on Earth - the Biological Safety Report's own cite has an example of a microbe from the Canadian permafrost isolated at -16°C, may be able to grow below -25°C, with optimal growth at 25°C and able to grow up to human blood temperature

    2. there are many potential ways Martian microbes may be able to spread through Earth's biosphere
       
    3. there may be scenarios where some Martian organisms find warmer conditions on Earth more habitable than Mars, in much the same way that Planococcus Halocryophilus grows better at 25°C than at -15°C in the Canadian permafrost.
       
    4. We do NOT have proof that it's impossible for life on Mars to have large-scale effects on Earth's environment or its inhabitants
      See: ALL major studies to date through to the European Space Foundation study in 2012 that say the potential for even large-scale effects is NOT demonstrably zero
      - experts do believe the risk of large-scale harm to human health or the environment is low
      - but even a low risk of this nature is HIGHLY SIGNIFICANT
       
  3. There are many terrestrial organisms that can harm humans that are not adapted to infect any other organism and we do NOT have proof that it is impossible for life on Mars to harm terrestrial organisms
     
    Endorse - Click here when ready to email your endorsements to me
     

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

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

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

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

    (Biological safety : 6)


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

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

    • Legionnaire's disease
    • Tetanus (caused by Clostridia tetani)
    • Clostridia perfringens, one of the most common causes of food poisoning

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

    • Botulism (C. botulinum)
    • Ergot disease (C. purpurea)

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

    Warmflash et al conclude:

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

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

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

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

    The only paper I know of that uses anything resembling this argument is the non peer reviewed Op. Ed. by space colonization enthusiast Robert Zubrin, the author mentioned by Warmflash et al. as their cite (50)

    But couldn't such life, if somehow unearthed by astronauts, be harmful? Absolutely not. Why? Because disease organisms are keyed to their hosts. Like all other organisms, they are specially adapted to life in a particular environment. In the case of human disease organisms, this environment is the interior of the human body or of a closely related species, such as another mammal. For almost 4 billion years, the pathogens that afflict humans today have waged a continuous biological arms race with the defenses developed by our ancestors. An organism that has not evolved to breach our defenses and survive in the microcosmic free-fire zone that constitutes our interiors will have no chance of successfully attacking us. This is why humans do not catch Dutch elm disease and trees do not catch colds. Any indigenous Martian host organism would be far more distantly related to humans than are elm trees.

    (Zubrin, 2000, Contamination From Mars: No Threat)

    That's rebutted by the response in the next edition of the Planetary Report (the monthly magazine of the Planetary Society) by planetary protection experts (Rummel et al., 2000, Opinion: No Threat? No Way : 4 - 7). But it's widely believed by space enthusiasts who know of Zubrin's article and not the refutation. The biological safety report don't cite Zubrin, which suggests they came up with the reasoning independently, but either way it's invalid reasoning as we saw

    Indeed, the biological safety report give no cites for the ten diseases either to show they co-evolved with humans or other Earth hosts, though it's obvious for most of them, This paragraph has only have one cite, to show that humans have a common ancestor with snails and with mosquitoes 600 million to 1200 million years ago.

    On looking closer, it turns out that one of their ten examples is controversial. The strain of e-coli that produces Shiga's toxin may have got that capability in biofilms rather than humans. That's a theory of Łoś et al. from 2013 (Altruism of Shiga toxin-producing Escherichia coli: recent hypothesis versus experimental results, 2013).
    [For more details see link below, this is an extract from that section]

    See: Invalid use of ten examples of pathogens that co-evolved with humans or other Earth hosts to conclude that Mars is likely to have near zero probability of a direct pathogen - there are many counterexamples of pathogens that didn't co-evolve with humans or any other Earth host, like tetanus or Aspergillus fumigatus


NASA uses these three invalid arguments together with the invalid Mars argument to conclude that "potential environmental impacts would not be significant." It the combines them with assessments from Environmental Impact Statements for biosafety laboratories built for other purposes by other agencies go on to conclude that "the risk to the public [from lab leaks] is negligible"

You can endorse here that this is not valid reasoning

.

  1. NASA have NOT established that potential environmental impacts would not be significant or that the risk to public health from lab leaks is negligible because the reasoning depends on non peer reviewed invalid arguments
     
    Endorse - Click here when ready to email your endorsements to me
     
  2. NASA should continue to use the conclusions of the European Space Foundation in 2012 when they said that samples should be contained as if they were risk group 4 (high risk of individual and community spread) until they are better understood (Amman et al., 2012, Mars Sample Return backward contamination–Strategic advice and requirements : 24) and the conclusion of their second planetary protection officer Cassie Conley “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
     
    Endorse - Click here when ready to email your endorsements to me
     

    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

    .

NASA_4_ARGUMENTS. NASA's four main arguments, the basis of their case that environmental impacts would not be significant and health impacts negligible and their rationale for restricting this Tier 1 EIS to the effects of the samples on the Utah sands instead of global effects
- you can endorse here that it was invalid to restrict Tier 1 to the Utah sands, and that the environmental scope should have been global
- this would mean the entire EIS has to be restarted

Skip to NASA_4_ARGUMENTS.endorsements if ready to endorse

NASA's four main arguments in brief are:

  • that if there is life on Mars it already got here in meteorites
  • that any life on Mars wouldn't be able to survive terrestrial conditions
  • that Mars is uninhabitable
  • that any Mars life would be unable to harm humans

presented as either certainty or near certainty.

These four arguments would be major new findings in planetary protection if true. They would be of a level of importance where they would be surely be published in Nature.

But these arguments are not found in the planetary protection literature. Instead they are all rebutted in the literature.

To endorse that the arguments are invalid see the previous sections:

Based on these arguments NASA conclude that environmental impacts would not be significant.

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

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

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

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

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

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

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

After reading the four arguments, if you agree they are invalid and agree with Chester Everline that the Environmental Impact Statement conclusion that the environmental effects would not be significant depends on them, you can endorse:

NASA_4_ARGUMENTS.endorsements

  1. The "Affected range" section of the EIS should be set to global as described in all the previous Mars sample return studies
    - It was inappropriate to restrict consideration to environmental effects in the Utah Test and Training Range (UTTR)
    - based on non peer reviewed arguments in the EIS itself
    - the conclusions of the major studies of a risk of large-scale effects on the environment and public health are never mentioned
    - so this EIS needs to be withdrawn
     
    Endorse - Click here when ready to email your endorsements to me
     
    [it's an inevitable conclusion that the EIS has to be withdrawn if it used an over narrow environmental scope for the Attribution range from the beginning]

    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.

You can also sign / endorse the call to NASA to withdraw the EIS here:

How NASA uses these four arguments to deduce that the environmental effects would not be significant and health impacts negligible

NASA sources these arguments to its own Environmental Impact Statement.

To a reader not familiar with planetary protection, NASA seem to assert a consensus amongst scientists that the meteorite argument especially is valid. To do that they

  • blur the distinction between transfer of rocks from Mars, which is a consensus, and transfer of living organisms from Mars which may never have happened even if there is life on Mars.
  • don't mention any sources that rebut it, even though both of their National Academy of Sciences cites in this paragraph rebut it firmly.

Presumably NASA aren't familiar enough with their own sources to know that they rebut this sentence, the most important sentence in the EIS from the point of view of planetary protection.

This is how they put it.

One of the reasons that the scientific community thinks the risk of pathogenic effects from the release of small amounts ( less than 1 kilogram [ 2.2 pounds ] ) of Mars samples is very low is that pieces of Mars have already traveled to Earth as meteorites. The National Academies of Sciences affirmed the consensus that Martian material travels to Earth when they developed the planetary protection guidelines for sample return from Martian moons, Phobos and Deimos (National Academies of Sciences, ..., 2019) ....
(NASA, 2023, Mars Sample Return FINAL PEIS (NASA, 2023, Mars Sample Return FINAL PEIS : 3–3),

Yet they don't provide any cite to anyone who says the argument is valid.

The issue is that with some scenarios there could be abundant life on Mars that is unable to get to Earth in meteorites because it can't withstand the shock of ejection or the extreme dehydration of space, or it's life that needs the surface conditions on Mars and can't get into the rocks below the surface that are ejected to Earth

NASA confirmed to me in a comment reply that their conclusion that environmental impacts would not be significant is sourced to the (non peer reviewed) Environmental Impact Statement itself and they have no other source to cite for this conclusion.

These are the relevant statements in NASA's final PEIS:

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

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

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

The sentence cited in this comment (“The relatively low probability of an inadvertent reentry combined with the assessment that samples are unlikely to pose a risk of significant ecological impact or other significant harmful effects support the judgement that the potential environmental impacts would not be significant.”) is a NASA conclusion based on the analyses presented in the PEIS—the reference is the PEIS itself. Based on the credible scientific evidence cited in the PEIS (samples are unlikely to pose a risk of significant ecological impact), it is reasonable to conclude that there would be no significant impacts from the Proposed Action. The term “unlikely” accounts for the fact that the risk is not zero.
(NASA, 2023, MSR FINAL PEIS :B-68)  

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

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

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

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

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

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

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

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

[My comments in orange]

NASA's Environmental Impact Statement is NOT peer reviewed as NASA's team confirmed in a reply to me. Our public comments are the only peer review it got.

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

[Confirms that it had no peer review or they would have replied saying it was peer reviewed]

�

As I expect you'll agree, if this argument is valid, it's not clear why NASA are containing the samples at all.

Once we have a possibility of an invasive species from Mars, though the effects could be minor, there is no way to rule out large scale effects in the worst case.

If all species on Mars get here on meteorites we don't need to protect Earth.

NASA try to deduce from a low risk that species from Mars can get here to a conclusion that the outcome from that low risk would not be significant in that reply to my comment in the collapsed section above (NASA, 2023, MSR FINAL PEIS :B-68). But that's not a valid form of reasoning. That's like arguing from a low risk of a house fire to a conclusion that a house fire is not significant.

It's similar for the other arguments.

These four arguments were only previously used in the literature by Robert Zubrin, president of the Mars Society to argue that we should drop all planetary protection for Mars, in a non peer reviewed op ed. which was immediately rebutted by planetary protection experts

The only previous use of these four arguments I can find in the literature (also not peer reviewed) is in an op. ed. by Robert Zubrin, president of the Mars society (Zubrin, 2000, Contamination From Mars: No Threat) with a vigorous response rebutting it from planetary protection experts (Rummel et al., 2000, Opinion: No Threat? No Way : 4 - 7)

NASA likely don't realize what they are doing, but by affirming these four invalid arguments (the Mars meteorite argument and the three arguments in this section) this EIS is effectively endorsing Robert Zubrin's invalid arguments, and supporting him in opposition to their own first planetary protection officer John Rummel and other experts on planetary protection. John Rummel probably has more published on a Mars sample return than any other living author - and Robert Zubrin only has that non peer reviewed op. ed.

By affirming these arguments, NASA are also supporting a line of reasoning that others can use to drop all planetary protection from Mars.

NASA don't go that far in this EIS, but they don't fully explain why they would take precautions at all, if they believed these arguments.

While, if they weren't fully convinced by them they should take precautions as if the samples contain the most hazardous organisms known, not do half-hearted precautions in between no precautions and the level of precautions previously considered necessary.

Though NASA wouldn't go quite that far, to no precautions, if this isn't challenged it opens the door wide open for private space or other countries to argue based on the same arguments that NASA's precautions are meaningless. So they have a broader significance, not just for NASA's mission.

Effect of these four arguments on the EIS - NASA uses them to argue that environmental effects from release of unsterilized materials would not be significant and health impacts negligible when previous studies have said that the Mars Receiving Facility is one of the main challenges to contain the samples

If these arguments are not intended to influence the precautions that NASA takes in any way then it's not clear what their purpose is. But in fact they do directly influence what they do. The main difference is that they clearly feel it removes any need to look at precautions against large-scale effects such as precautions for lab leaks such as quarantine, or potential issues such as escape of an alien biology from the samples into Earth's biosphere.

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

NASA's EIS says they will work out details of the facility in Tier 2 - this means that they see it as of lesser environmental importance - while major studies say a lab leak from a Mars Receiving Facility in the worst case could have global consequences on the environment and human health

However, NASA's Environmental Impact Statement doesn't discuss this facility. All NASA say is that they will work out the details in Tier II (a detailed site specific study).

They refer to two previous EIS's for ordinary BSL-4s as evidence that the risk to the public is negligible, and as a reason not to consider risks of lab leaks in Tier I.

An alternative release path resulting from the contamination of workers leading to direct contact with others (members of the public) was also analyzed . Qualitative risk assessments for this mode of transmission [for the two previous EIS's for ordinary BSL-4 labs] have shown that the risk to the public is negligible (NIH/DHHS 2005, DHS 2008).

.

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

(NASA, 2023, MSR FINAL PEIS :3-14)

For more about the Tiering see the tiering section of my legal discussion below:

NASA relies on the Mars meteorite argument for that simplification - which means if it is invalid - then the whole approach of restricting the consideration of environmental effects to Utah sands for Tier 1 is no longer acceptable and the EIS should be restarted

NASA achieve that simplification using the Mars meteorite argument and three other arguments to come to a conclusion that any health impacts from unsterilized samples would be negligible and any environmental effects not significant.

This means that if this Mars meteorite argument is invalid, along with the other three arguments that support it, so is the whole approach of restricting the consideration of environmental effects to Utah sands on the basis that there is no significant risk of environmental effects later on from lab leaks in the Mars Receiving Facility.

That then would make the entire EIS invalid as that's the basis on which they did the whole thing.

To give an idea of how important the Mars meteorite argument is, let's look at the response of Chester Everline is a co-author of NASA's handbook on probabilistic risk assurance (Probabilistic risk assessment procedures guide for NASA managers and practitioners). He commented on the EIS on the last day of public comments with a critical look at risk assurance, his area of expertise. He didn't find an adequate consideration of risk and his conclusion was that NASA's safety case depends on the Mars meteorite argument.

He said that if the Mars meteorite argument is invalid, NASA should seriously consider not returning the samples using the technology described in the EIS.

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)

...

If the MSR [Mars Sample Return] Campaign can convincingly demonstrate that material returned to Earth by MSR will be subjected to more severe conditions than those transported by natural processes, then MSR poses no greater risk to Earth than we would expect from the next Mars meteorite.

[I.e. if they can convincingly demonstrate that samples are subjected to more severe conditions for life in the sample tubes than in a Mars meteorite ejected from Mars and impacting Earth]

However, if this cannot be convincingly demonstrated the MSR Campaign should seriously consider not returning samples using the technology described in the PEIS [Provisional Environmental Impact Statement] (i.e., transition to a deferred return campaign option).

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

(Chester, 2022, Comment posted December 20th)

.

DISCIPLINE. Endorse :Space Studies Board recommendation for the need for an independent advisory board to help NASA to protect Earth
- and to provide peer review of their plans
- that it is not surprising that members of the public find major issues in NASA's plans when they have nobody on their team with the relevant expertise left
- such reports of mistakes need to be checked
- and just as we wouldn't bo to NASA scientists and engineers for advice on how to contain an Ebola outbreak we need experts from other disciplines and help from other agencies to prepare adequate plans to protect Earth's biosphere and inhabitants from risks in Mars samples

I think it will help to endorse any of these if you feel it is appropriate

. DISCIPLINE_endorsements

  1. Devising methods to protect Earth's biosphere and inhabitants from potential microbes from Mars involves matters well outside of NASA's usual areas of excellence and competence especially after NASA closed the interagency panel and the planetary protection office.
     
    Endorse - Click here when ready to email your endorsements to me
     
  2. We agree with the recommendation by the Space Studies board that NASA should reestablish an independent advisory body and process to help formulate its implementation of planetary protection, and agree that NASA urgently needs external peer review for planetary protection and biosafety
     
    Endorse - Click here when ready to email your endorsements to me  
  3. NASA no longer has the expertise it needed to produce this EIS, so it's not surprising that major mistakes are identified in public comments on their plans.
     
    Endorse - Click here when ready to email your endorsements to me  
  4. These mistakes are not the fault of any authors of the EIS they just reflect this absence of members with the relevant expertise to detect the mistakes (C.1)
     
    Endorse - Click here when ready to email your endorsements to me
     
  5. From 1 - 4, it is credible that members of the public can find mistakes in NASA's plans and in the final PEIS
     
    Endorse - Click here when ready to email your endorsements to me  
  6. Such reports of mistakes should be checked carefully to see if they are indeed valid issues.
       
    Endorse - Click here when ready to email your endorsements to me  
  7. We wouldn't go to NASA for advice on how to manage an outbreak of Ebola and similarly NASA needs experts in disciplines like planetary protection as NASA understood it in the past and human health and related disciplines to draw up adequate plans to protect Earth's biosphere and its inhabitants, human and others, from unknown life in samples from Mars
     
    Endorse - Click here when ready to email your endorsements to me  

Or put it in your own words as you like.

(click to show / hide)

The Space Studies Board said in 2018:

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

The roles of the advisory body include the following:

[other roles] …

Act as a peer review forum to facilitate the effectiveness of NASA’s planetary protection activities.

(Review and Assessment of Planetary Protection … : 61 - 62)

It’s important to recognize that the many mistakes in the final PEIS are not the fault of any authors of the EIS. The Space Studies Board say they need to educate committee members unfamiliar with basic planetary protection concepts.

“ … 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 : 77)

For background see these sections of the open letter

RISK_ASSURANCE. NASA isn't doing risk assurance properly in this Environmental Impact Statement
- we need to look for worst case scenarios (like a house fire)
- not just best case scenarios (all the activities that don't lead to a house fire)
- we need a target level of assurance
- we ARE NOT required to take even low but significant risks with Earth's biosphere in robotic exploration of Mars
- and NASA are mistaken when they say "No outcome in science and engineering processes can be predicted with 100% certainty"
- for instance we can predict with 100% certainty that the "no action" scenario has NO EFFECT ON EARTH'S BIOSPHERE
- searching for life in situ also can never harm Earth's biosphere or inhabitants
- exploring Mars telerobotically from orbit also has zero risk
- sterilizing all samples returned to Earth can also keep Earth 100% safe at the level of no appreciable risk with a high enough level of sterilization
- there are scenarios where we can never return life from Mars and in those scenarios we will have many options to keep Earth 100% safe

Skip to RISK_ASSURANCE.endorsements if ready to endorse

In several places in the EIS, NASA responds to questions from the public by saying essentially that there is no way to keep Earth's biosphere and inhabitants 100% safe as a reason why we have to go ahead with the mission even if they don't have a target risk probability for the safety of Earth's biosphere. They put it like this:

No outcome in science and engineering processes can be predicted with 100% certainty.

(NASA, 2023, Mars Sample Return FINAL PEIS : 4-8)

(NASA, 2023, Mars Sample Return FINAL PEIS : B-38)

(NASA, 2023, Mars Sample Return FINAL PEIS : B-55)

One of NASA's own experts on risk assurance, Chester Everline, said he didn't find a target level of risk and seriously recommended not returning the samples if they can't establish the Mars meteorite argument.

NASA replied explaining they don't have a target probability for the mission, telling him that NASA recommends but doesn't require an overall target and they haven't set one and they don't have an overall target probability for containment for Earth Entry System release and landing either - but they haven't updated the confusing passage he drew their attention to to clarify this for the reader

See:

Here you can endorse statements that there are ways to explore Mars and find out about any life on Mars that involve no risk to Earth's biosphere and inhabitants.

Also that there is no need to take any risk until we can evaluate the level of assurance and decide if we wish to undertake the risk whatever it is. If we can't reduce the risk enough we can defer the mission until we can.

They also look only at best case scenarios throughout. Here you can endorse that we need to look at worst case scenarios for planetary protection

RISK_ASSURANCE.endorsementsThere are many ways to keep Earth 100% safe or with no appreciable risk
 
Endorse - Click here when ready to email your endorsements to me  

    1. no action - just never return anything from Mars to Earth and explore Mars in sit and later explore Mars telerobotically from orbit with high bandwidth telerobotics
    2. sterilize thoroughly all samples returned from Mars
    3. return unsterilized samples to a miniature life detection satellite above GEO or some other location near to Earth but physically separated from our biosphere and never return anything from that satellite to Earth
    4. return unsterilized samples to a miniature life detection satellite
      - and sterilize all samples returned to Earth with very high levels of sterilization
      (no appreciable risk, for instance heat sterilization to levels that would cause all amino acids to vaporize has no appreciable risk, and levels of oxidizing radiation so large that any organic molecules break up into short chains a couple of carbon atoms long would also be safe)
       
  2. We are not required to take any level of risk with Earth's biosphere and inhabitants from samples returned from Mars.

    If we can't set an overall target for risk it is appropriate to defer sample return until we can.
     
    Endorse - Click here when ready to email your endorsements to me  

    See: Your employee Chester Everline
    - one of your experts on probabilistic risk assurance and co-author of your own handbook on the topic,
    - asked if you had an overall campaign wide probability target for containment
    - your team said you don't and are not required to have one
    - but didn't clarify this in the EIS itself
     
  3. It is essential to look at worst case scenarios for life returned from Mars. It is NOT enough to enumerate a large number of best case scenarios to prove that an activity is safe.
     
    Endorse - Click here when ready to email your endorsements to me  

    Examples:
    1. a list oft 10 human pathogens co-evolved with humans does not establish that all diseases co-evolved with humans and the biosafety team missed out many exceptions like Tetanus and Aspergillus fumigatus not adapted to an infectious lifestyle in any organism
       
    2. a list of several extremophiles that only live in extreme conditions does not establish that all extremophiles we find on Mars will only be able to live in extreme conditions on Earth - NASA's team's own cite included a remarkable extremophile found in the Canadian permafrost that shows activity at least down to -25 C that grows all the way up to human blood temperature
       
    3. some people think Mars is uninhabitable, which is a best case for planetary protection, this does NOT mean we should only consider scenarios where Mars is uninhabitable for planetary protection and
      - the best scenario for life detection is that we find present day life in Jezero crater so NASA plans to test samples returned from Jezero crater for life
      - we also need to consider the possibility of life in the samples for the worst case scenarios for planetary protection

      [a-c are from PLAUSIBLE_INVALID. Endorse that these arguments are invalid:
      - NASA's argument that Mars has been uninhabitable for millions of years
      - rebut: NASA will test the returned samples for present day life
      - NASA's argument that Martian life would not be able to grow on Earth because of lack of its required nutrients and condition
      - rebut: their own cite includes a microbe isolated from Canadian permafrost that can grow up to human blood temperature
      - NASA's argument from ten example diseases that human pathogens have to co-evolve with humans giving near zero risk of pathogens from Mars
      - rebut: tetanus and Aspergillus fumigatus are two examples with serious and often fatal effects not adapted to an infectious lifestyle in any organism      ]
       
    4. b. subtilis, a very hardy microbe may be able to get to Earth on rare occasions after ejection by large impacts on Mars, surviving a minimum of months and more likely years in the cold and vacuum of space
      - this is a best case for planetary protection
      - but we need to consider the worst case scenarios for planetary protection of the many terrestrial microbes that would NEVER be able to get from Mars to Earth in this way

    [d is from METEORITES. Endorse that many terrestrial species couldn't survive ejection into space and months in vacuum and cold
    - so we can't know in advance that ANY species of Martian life already got here in meteorites
    - never mind ALL species in all scenarios]]     

SCENARIOS. Endorse scenarios of life based on mirror organics from Mars
- and a novel fungal genus no terrestrial organism has ever encountered similar to Aspergillus
- as scenarios for a small risk of unprecedented harm to the environment or human health,
- similar to the house fire scenarios that give us a reason to fireproof houses and install smoke detectors

At our current state of knowledge:

  1. there are potential scenarios for life on Mars with no common ancestor with terrestrial life - Mars could have astrobiological surprises such as life unrelated to terrestrial life.
     
    Endorse - Click here when ready to email your endorsements to me  

    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).


    See: We need to take great care to protect Earth's biosphere with bonus samples too
    - Mars could have astrobiological surprises as astonishing as the carbon dioxide geysers were for geology
    - like mirror life [IN NEPA BOTH]
     
  2. The scenario of independently evolved mirror life is plausible as an illustrative high consequence likely low risk scenario of unprecedented levels of large-scale harm to our biosphere
     
    Endorse - Click here when ready to email your endorsements to me  
     
    The specific scenario I developed used a Martian analogue of Chroococcidiopsis that evolved independently from mirror organics. This is a blue-green algae that would be able to live anywhere on Mars with access to basalt and liquid water and can grow almost anywhere on Earth too, in or soils, oceans, rocks, even in the human microbiome and 10 meters below the Atlantic sea bed

    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.

    1. Chroococcidiopsis, a highly resilient blue-green algae does well in Mars simulation chambers (… Chroococcidiopsis sp. Exposed To a Mars-Like Near Space Environment) and is able to repair extensive DNA damage including double strand breaks, taking about 12 hours to repair the damage, with no significant loss of viability even after revival after the equivalent of 20 million years of surface ionizing radiation on Mars (Role of DNA repair pathways in the recovery of a dried, radioresistant cyanobacterium exposed to high-LET radiation: implications for the habitability of Mars : 9 - 10)
       
    2. It can find all its nutritional 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 or hydrogen. It's found even 10 to 750 meters below the Atlantic sea bed using an alternative metabolic pathway to metabolize hydrogen and with nothing else except gabbro to live on (Recycling and metabolic flexibility dictate life in the lower oceanic crust : 3). It is able to live there in small populations by using carbon and nitrogen found in small quantities in the basalt - though it can also use photosynthesis to add to the carbon when it has access to sunlight and can do nitrogen fixation to add to the nitrogen when it has access to nitrogen.
       
    3. Chroococcidiopsis is an ancient polyextremophile with numerous alternative metabolic pathways that strains of this genus can use, including nitrogen fixation, methanotrophy, sulfate reduction, nitrate reduction etc (Metabolic pathways – Chroococcidiopsis thermalis). An alien microbe from Mars based on mirror life might be just as versatile, accumulating many pathways over billions of years of evolution on Mars. That would help it to radiate through our biosphere even if we return only one species from Mars.
       
    4. this is a scenario we need to protect against just as we do for house fire scenarios for smoke detectors
       
    5. it is impossible to evaluate how likely or unlikely mirror life on Mars is
       
    6. if nearly all terrestrial planets have life, and life evolved on Mars independently, there may be as much as a 50-50 chance that any independently evolved life on Mars is mirror life
       
    7. if life evolves very easily Mars may even have several types of life co-existing which have no common origin with each other because it has often had potential habitats where life could evolve that are reasonably biologically isolated from the rest of Mars, e.g. after meteorite impacts on ice or volcanic activity that melts ice
       
    8. if evolution of life is very rare the nearest mirror life planet might be 1000 light years away or even in another galaxy

      See:

      Illustrative worst case scenario for effects on Earth's biosphere: INDEPENDENTLY EVOLVED MIRROR LIFE: according to one theory - punctuated chirality - there's a 50 - 50 chance that independently evolved life on Mars arose from a network of mirror organics interacting with each other - and still uses mirror organics
      Detailed illustrative mirror life scenario
      - an analogue of the blue-green algae chroococcidiopsis
      - one of our best candidates for a Mars analogue organism
      - can find all its nutritional requirements in basalt or gabbro, also sea water, fresh water and soil with strains found almost everywhere on Earth
      - and a mirror life analogue on Mars would likely be adapted to metabolize normal organics because of infall from space [IN NEPA BOTH]
       
  3. Mars could also have distantly related terrestrial life with new species, genera, all the way up to a new domain of life or multiple new domains of life at the same level as three terrestrial domains of the archaea, bacteria and eukaryotes
     
    Endorse - Click here when ready to email your endorsements to me  
  4. There is a plausible high consequence likely low risk scenario of a novel fungal genus from Mars similar to Aspergillus but which we have no adaptations to.
     
    Endorse - Click here when ready to email your endorsements to me  

    This shows how aspergillus fumigatus infects the lungs. First the wild fungus produces spores. The spores settle in the lungs. They then penetrate the lungs with hyphae (tendrils) which extract organics. It protects itself with chemical barriers and produces branching networks of these tendrils which then break up and spread through the body.

    Text on graphic. The way a fungus infects us is very straightforward - insert tendrils (hyphae) to extract organics. Even an alien fungus with no adaptations to terrestrial life could do this. Uses chemicals to attack tissues. Also protects itself with chemical barriers.

    Graphic from: (Aspergillosis - Creative Biolabs)

The basics of the way a fungus like Aspergillus fumigatus attacks us is so general, not based on specific adaptations or indeed really, anything about human biology it might also work for alien life and alien biology. See below:

STERILIZE, Endorse that the alternative to sterilize all the samples (suggested by many members of the public) does have potential to protect Earth
- sterilization differs from NASA's plan and has potential to keep Earth 100% safe or at least no appreciable risk
- sterilization has potential for more science return than "no action" and needs to be considered (also proposed by several others during the public comments)

Skip to STERILIZE.endorsements if ready to endorse

That alternatives that keep Earth 100% safe are reasonable alternatives under NEPA to "no action" and the mission plans, even if they lead to some reduction in science return - e.g. to sterilize all samples

The Council on Environmental Quality ruled 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)

STERILIZE.endorsements

  1. The alternative to sterilize all samples has potential to keep Earth's inhabitants and biosphere 100% safe, or at least, safe to the level of no appreciable risk and needs to be evaluated even if there seems a possibility it might lead to reduced science return

    [NASA found that 35% of the total proposed scientific analyses and 60% for search for life would be compromised by sterilization. (MSR FINAL PEIS B-42)]
     
    Endorse - Click here when ready to email your endorsements to me  
  2. Sterilizing all the samples may have no effect on science return for the Perseverance samples
     
    Endorse - Click here when ready to email your endorsements to me  
     
    because of
    1. the expected levels of organics sent to Mars from Earth of 8.1 ppb throughout the samples and 0.7 ppb per biosignature
    2. the high ionizing radiation doses the Perseverance samples have already encountered for either geology or astrobiology
      [minimum sterilization dose for Curiosity is 80 million years of surface ionizing radiation for the most recently exposed sample measured for exposure age]

IN_SITU. Endorse that Chester Everline's alternative of a deferred return
- to leave samples on Mars for now and focus on in situ life detection missions to Mars
- keeps Earth 100% safe as we find out more about Mars
- and is a reasonable alternative to consider

  1. Chester Everline's alternative to leave the samples on Mars for now and instead focus on in situ life detection missions to Mars until we find out more will keep Earth 100% safe with some science return because of the in situ life detection and so also counts as a reasonable alternative
     
    Endorse - Click here when ready to email your endorsements to me  

    NASA say that this is the same as "no action" but it isn't. A deferred mission alternative would say specifically that the mission is deferred until some specific criteria can be met. E.g.:

    Deferred mission alternative

    The mission is deferred until in situ studies on Mars establish that samples can be returned with a risk of harm of less than 1 in [target probability] and meanwhile in situ studies are prioritized

    See: Chester Everline suggested a deferred action alternative in his public comment on the EIS
    - to search for life in situ on Mars first and return the samples only once any risk is well understood
    - in situ study on Mars achieves 100% certainty that Earth is not harmed since no material is returned to Earth
     
  2. New missions to Mars for in situ life detection have higher value for astrobiology than returning the Perseverance samples
    [Endorse this too if this is your personal view - several astrobiologists expressed this view in a paper to the decadal review in 2012
    see: ( Bada et al., 2009,. Seeking signs of life on Mars: In situ investigations as prerequisites to a sample return mission ) ]
     
    Endorse - Click here when ready to email your endorsements to me  

See my responses to NASA's replies to Chester Everline's comments:

.

IN_SITU_STRATEGY. Endorse that we need to be able to
- have the capability to test many samples from identical seeming locations
- as life in extreme conditions on Earth is often patchy and localized.
- be able to drill at least 2 meters
- search for salts
- search for caves
- visit representative locations for all the proposed microhabitats to see if they exist
- look for nitrogen rich organics
- access recently excavated craters
- especially craters excavated since photographs of Mars began
- visit locations where impacts throw up ice boulders from below the surface
- It IS NOT currently practical to do sample return missions to all the regions of interest on Mars even just to return a few samples from each
- it IS practical to send large numbers of miniature sterilized probes to visit them and communicate with them via radio or optically

 

You can endorse all of these or any individually by number. The general picture is that we need to explore everywhere interesting on Mars - and we need in situ searches because otherwise we'd need to do dozens of sample return missions just to return a few samples from each location:

IN_SITU_STRATEGY.endorsements

  1. have the capability to test many samples from identical seeming locations
    - as life in extreme conditions on Earth is often patchy and localized.
     
    Endorse - Click here when ready to email your endorsements to me  
  2. be able to drill at least 2 meters  
    Endorse - Click here when ready to email your endorsements to me  
  3. search for salts  
    Endorse - Click here when ready to email your endorsements to me  
  4. search for caves
     
    Endorse - Click here when ready to email your endorsements to me  
  5. visit representative locations for all the proposed microhabitats to see if they exist
    (many already suggested)
     
    Endorse - Click here when ready to email your endorsements to me  
  6. look for nitrogen rich organics
     
    Endorse - Click here when ready to email your endorsements to me  
  7. access recently excavated craters
     
    Endorse - Click here when ready to email your endorsements to me  
  8. especially craters excavated since photographs of Mars began
     
    Endorse - Click here when ready to email your endorsements to me  
  9. visit locations where impacts throw up ice boulders from below the surface
     
    Endorse - Click here when ready to email your endorsements to me  
  10. It IS NOT currently practical to do sample return missions to all the regions of interest on Mars even just to return a few samples from each
     
    Endorse - Click here when ready to email your endorsements to me  
  11. Once we have 100% sterile probes it WILL be practical to send large numbers of miniature cube sat sized sterilized probes to visit all the regions of interest and communicate with the probes from Earth via radio or optically  
    Endorse - Click here when ready to email your endorsements to me  

The reason to look for nitrogen rich organics is because though there are many abiotic ways to get carbon compounds, Mars has very little by way of nitrates, so if we find nitrogen rich organics it may be more likely to be from life, though we then need to go on to look for amino acids, amino sugars and other small molecules likely to be diagnostic of life. Amino acids occur naturally in meteorites (for instance) but then we'd notice if they all are in the same chiral form (of the same symmetry, mirror or normal organics)

Many astrobiologists recommend in situ study in PREFERENCE to a sample return for their discipline
- including a white paper by Bada et al submitted to the same decadal review that decided on this mission
- in my literature study I found no papers more recent than 2002 recommending a Mars sample return first
- the decadal review decided instead to use this old paper from 2002 as the basis for their decision
- instead of this white paper submitted directly to them by experts
- this 2002 paper is the reason they gave for a sample return mission rather than in situ missions
- but even the 2002 "Safe on Mars" paper you cited said that in situ studies are better than a sample return once we have the capabilities (which we now have)
- the issue is life on Mars is likely to be hard to detect and require examining a lot of material before we find our first living cell or our first clear evidence of past life
- this is far easier with instruments on Mars where the material to study is essentially unlimited as Chester Everline put it in his comment
- so Everline was correct and you are mistaken in your response to him with no awareness of many papers supporting his suggestion

IN_SITU_INSTRUMENTS. - to endorse
- a long list of miniaturized life detection instruments suitable for use in situ on Mars
- or for use in a small life detection lab above GEO
- NASA's Mars Sample Return team are unaware these exist
- as they don't mention them in their evaluation that there is no potential for in situ instruments on Mars
- NASA's EIS is based on an out of date source iMost (written in 2017)
- which was also incomplete at the time it was written,
- didn't mention astrobionibbler, UREY, LDCHIP, microfluidics, or polyclonal antibodies
- and too early to mention the Europa Lander report which added many new ideas for instruments

This is the background, about why NASA's team was not aware of the existence of these instruments in the EIS. They used an out of date cite from 2009 and a more recent cite from 2022 that doesn't discuss in situ instruments. See:

Please endorse that actually many instruments are available at various stages of technological readiness with potential to be ready to fly by 2033 if they are prioritized

You can also endorse individual instruments as of interest.

IN_SITU_INSTRUMENTS.endorsements
  1. We have many instruments we can send to search for life in situ elsewhere in our solar system with potential to fly by 2033 if they are prioritized
     
    Endorse - Click here when ready to email your endorsements to me  

    These could be used
    1. to Mars
    2. to Ceres, Europa, Enceladus / Titan etc
    3. these can also be used in a miniature life detection lab above GEO

The Europa Lander report required their instruments to be dual-purpose - able to provide valuable information about geology or chemistry as well as biology

"Life-detection experiments should provide valuable information regardless of the biology results"

These are some of their dual purpose instruments.

  1. Several instruments suggested for Europa,
     
    Endorse - Click here when ready to email your endorsements to me  
    1. Superresolution optical microscopy, which can go beyond the usual optical resolution limit of 200 nm to observe nanobacteria
    2. Raman microspectroscopy synchronized with visible light can do a chemical analysis of the microbes directly
    3. fluorescent dyes that bond to specific macromolecules such as lipids, proteins and nucleic acid.
    4. natural fluorescence, aromatic amino acids (incorporating a ring of six carbons) fluoresce when stimulated with deep UV at wavelengths less than 250 nm. Chlorophyll and some other biological organics also autofluoresce.
    5. autofluorescence to look directly for swimming microbes
      (Hand et al., 2017, Report of the Europa Lander Science Definition Team : xi).
    2. [this list isn't complete, do say if you want to endorse some other instrument mentioned in that report and I'll add it to the list]

However if we are going to do a thorough in situ search for life on Mars, we need to get away from this limitation to use only dual purpose instruments.

  1. Lifeless habitats on Mars are also interesting
    - we need to find out why they are lifeless, and how far chemistry got on the way to evolving life, if it did get anywhere
    - so we should treat non detection of life as an observation
    - rather than a failure of the instruments to find anything of interest
     
    Endorse - Click here when ready to email your endorsements to me  

    Although Mars sample return and rover missions are strongly focused on finding evidence for life, lifeless samples returned from Mars will yield important constraints on the extent of habitable conditions and whether those environments were inhabited.

    The scenarios discussed here show that it is critical to acquire many samples. Multiple samples must be obtained from each locality, from similar (paleo)environments elsewhere across Mars, and from different potentially habitable environments in multiple locations across Mars for the scenarios presented here to be disentangled and the reasons for lifeless samples ascertained.

    (Cockell et al., 2017, Lifeless Martian samples and their significance).

  2. Although there are many instruments that are dual purpose some of the most sensitive instruments can only be used for life detection and we should send these to Mars.
     
    Endorse - Click here when ready to email your endorsements to me  
     
    They also will help confirm presence of any life in situ suspected from other measurements, these include:
    1. tests for respiration
    2. tests for metabolism
    3. culture experiments to see if we can get something to grow from the samples
       
  3. For a rapid preliminary survey of Mars for life we need ultrasensitive life detection instruments as life may be present in very low numbers in some locations
     
    Endorse - Click here when ready to email your endorsements to me
     
    - we can send dozens of miniature probes, landers, rovers to the surface
    - then can hone in on those locations for further study
    - even if most of the probes / landers / rovers turn up null results for life

For the satellite above GEO, if the funding is available (and bearing in mind launch costs are likely to continue to fall)

  1. we can send multi-ton payloads to above GEO
     
    Endorse - Click here when ready to email your endorsements to me
     
    1. so can send large instruments that are not yet miniaturized sufficiently to send further afield to Ceres, Mars, or the icy moons of Jupiter and Saturn
        
      Endorse - Click here when ready to email your endorsements to me
       
    2. do follow on experiments using new instruments selected or even constructed specifically based on what we found out previously

       
      Endorse - Click here when ready to email your endorsements to me
       
    3. return materials back to Earth sterilized for further analysis
       
      Endorse - Click here when ready to email your endorsements to me 

Other miniaturized instruments, all with target mass at most a few kilograms, you can endorse these as instruments that it's reasonable we could send to a telerobotic lab above GEO or to Mars by the early 2030s if they are prioritized:

  1. Life Marker Chip LDChip300 which detects biosignatures using ultra sensitive polyclonal antibodies, almost sent on Exomars but descoped which
    LDChip was able to discover a previously undetected microhabitat in the Atacama desert
    (Parro et al, 2011 A microbial oasis in the hypersaline Atacama subsurface discovered by a life detector chip: implications for the search for life on Mars)

    Target mass of less than 1 kg (Life Marker Chip)
     
    Endorse - Click here when ready to email your endorsements to me  
     
  2. the gene sequencer SETG designed to do end to end sequencing on Mars from sample collection all the way through to outputting the gene sequence to send back to Earth. By 2016 it reached the capability to detect 10 ppb of DNA. It would be able to detect 400 highly conserved “universal genes” such as ribosomal DNA which
    It could establish whether Martian life is related to terrestrial life, perhaps by meteorite transfer, or is independently evolved (Mojarro et al, 2016, SETG: nucleic acid extraction and sequencing for in situ life detection on Mars)

    The main challenge is to develop a maintenance free replacement for the organic nanopores that need to be replaced every few weeks. It would use nanogaps instead of nanopores and would even be able to do protein sequencing (Maggori, 2023, Life detection and taxonomic characterization with MinION sequencing in Mars and icy worlds analogue environments : 230).

    NASA are in the process of getting SETG ready to do gene sequencing in the oceans of icy moons like Europa and Enceladus, and Mars. (Carr et al., 2020, Nanopore sequencing at Mars, Europa, and microgravity conditions). We don't have a completion date but there seems some potential for it to be ready before the samples return in 2033. If not we can still send organic nanopores up to the satellite above GEO and do gene sequencing for a few weeks at a time.
     
    Endorse - Click here when ready to email your endorsements to me  
  3. astrobionibbler which uses microfluidics and is exquisitely sensitive, able to detect a single amino acid in a gram
    (Searching for Organics in a Nibble of Soil )
    (Noel et al., 2016, In Situ Microfluidic Subcritical Water Extraction of Amino Acids)
    (Elleman, 2014, Path to Discovery)
     
    Endorse - Click here when ready to email your endorsements to me  
  4. a chiral version of the Viking labeled release experiment, feeds organics of both symmetries and detects if life has a preference for one or the other
    (Anbar et al., 2012, A Chiral Labeled Release Instrument for In Situ Detection of Extant Life)

    [N.B. not sure what happens in the situation here life already has the isomerases to flip organics of the opposite symmetry to make it digestible - life on Mars may have these isomerases in order to cope with the organic infall from space]
     
    Endorse - Click here when ready to email your endorsements to me
      
  5. Similar experiments could label the organic "food" with non radioactive isotopes of nitrogen, hydrogen, sulfur etc and the headspace gases analysed in a preliminary way with a mass spectrometer
    - for the life detection lab in orbit the headspace gases could also be returned to Earth for more sensitive analysis,
    see: iMost propose to redo the Viking labeled release experiment
    - but with far more sensitive measurements available today and labeling hydrogen (with deuterium) and nitrogen (with nitrogen 17) as well as the carbon
    - some of this could be done in orbit
    - some would need analysis back on Earth but perhaps the experiment itself can be done in orbit
     
    Endorse - Click here when ready to email your endorsements to me  
  6. An off-axis holographic microscope to let the focus be adjusted after the image is taken making it easier to image individual microbes in a liquid medium (Lindensmith et al, 2016, A submersible, off-axis holographic microscope for detection of microbial motility and morphology in aqueous and icy environments)

    "Extremely small, robust, low-power microscopes have been constructed using light-emitting diodes in an in-line DIHM geometry. This type of design is lensless and may be coupled to microfluidics to create compact on-chip systems. The advantages of this approach are very low mass and low power, insensitivity to alignment, and lack of mechanically sensitive optics. Field of view is also decoupled from resolution because there is no objective lens.

    The field of view is 24 mm2 without scanning and the entire instrument weighs < 100 g ..

    Super-resolution has been achieved in these systems using LEDs arrays where each is sequentially illuminated ... and a corresponding frame of data captured. In this case, the image from each LED is a slightly shifted hologram; the Fourier representations may be summed to achieve ~800 nm spatial resolution."

    Nadeau et al., 2018. Imaging technologies and strategies for detection of extant extraterrestrial microorganisms : 235)
    �
    Endorse - Click here when ready to email your endorsements to me  
  7. Test for redox reactions directly by measuring the electrons and protons they liberate. This is sensitive to small numbers of microbes and has the advantage that it could detect life even if not based on carbon or any form of conventional chemistry we know of
    (Ximena et al, 2010, Microbial fuel cells applied to the metabolically based detection of extraterrestrial life)
     
    Endorse - Click here when ready to email your endorsements to me  
  8. A miniature variable pressure electron microscope that combines imaging with chemical analysis
    (Gaskin et al, 2012, Miniature variable pressure scanning electron microscope for in-situ imaging & chemical analysis)  

    This would be especially useful if we have already identified life with the other instruments and can bring candidates into the field of view of the microscope, or can cultivate martian life

    "Sample throughput is a major drawback of electron microscopy – the imaged volume is so small that it would not be useful for the ‘search’ part of a life detection instrument, though if candidate objects could be identified and brought into the field of the EM it could be valuable for evaluation of features indicative of life."
    Nadeau et al., 2018. Imaging technologies and strategies for detection of extant extraterrestrial microorganisms : 237-8)
    ��
    Endorse - Click here when ready to email your endorsements to me  

Please do let me know via email of any other instruments for life detection in situ or above GEO to add to this list.

The reason NASA missed ALL these instruments in the Environmental Impact Statement is that they used out of date cites on the capabilities of in situ instruments in "2.3.1 Programmatic Alternative Screening Criteria".

The International Mars Architecture for the Return of Samples Working Group, in 2008, evaluated the overall goals and objectives of Mars exploration and determined that, given the scope of what is realistically achievable via in situ exploration technology, a significant fraction of these investigations could not be meaningfully advanced without returned samples for the following reasons (iMARS Working Group 2008, Meyer et al. 2022):
(NASA, 2023, Mars Sample Return FINAL PEIS 2-24),

Their 2008 cite (MARS Working Group, 2008, Preliminary Planning for an International Mars Sample Return Mission : 9) has only a short one page summary, with a strong geology focus and doesn't mention any of the types of measurement of interest for astrobiology or any of the instruments specifically developed by astrobiologists. It also predates all the more modern in situ instrument designs.

Back in 2008, the only instruments in development were UREY for Exomars, which had to be removed when NASA withdrew from the partnership with NASA, and Sample Analysis at Mars (SAM) which eventually flew on Curiosity and didn't have the capability to search for present day or past life but did have the capability to do some interesting work on organics on Mars (Botta et al., “Strategies of Life Detection”: Summary and Outlook).

Their 2022 cite (Meyer et al, 2022, Final Report of the Mars Sample Return Science Planning Group 2 (MSPG2) ) doesn't have any section discussing in situ instruments, and the citation list doesn't include any of the recent literature on instruments designed for in situ use on Mars, Europa etc.

This seems to be another of their many mistakes where they add a cite that isn't relevant to the sentence it is attached to. This is the only mention of "in situ" in this cite:

All systems need to work together to result in the convergence at the OS of an SRW cache, currently defined as:

(i) distinct sample suites or individual samples selected to represent the diversity of the exploration area and address the science objectives of MSR described by iMOST, in general, and the astrobiological potential, geologic history, and evolution of Mars as reflected in the Jezero Crater region, in particular;

(ii) availability of in situ data and other information to understand the geological and environmental context of the returned samples, and;

(iii) inclusion of one and preferably two, witness samples (CSSC, 2021).

(Meyer et al, 2022, Final Report of the Mars Sample Return Science Planning Group 2 (MSPG2) : S-9)


NASA was alerted to the existence of modern in situ instruments in the attachment 8 of (Walker, 2022, Comment posted December 20th) but NASA dismissed this attachment as nonsubstantive and likely never read my long list instruments we can use to search for life in situ on Mars or in the telerobotic laboratory

Text on graphic: Instruments for lab above GEO, lab leak issues, quarantine issues for human technicians etc.

By dismissing my attachment 8 as "Nonsubstantive" your team excluded the material needed to evaluate the suggested reasonable alternative of a miniature lab above GEO.

See (Walker, 2022, NASA and ESA are likely to be legally required to sterilize Mars samples to protect the environment until proven safe : 210), the section titled: "Modern miniaturized instruments designed to detect life in situ on Mars - could also be used to examine returned samples in an orbital telerobotic laboratory"

.CLEAN. Endorse that the 8.1 ppb of terrestrial contamination throughout the returned samples and 0.7 ppb for the most abundant biosignature makes the samples most likely of virtually no interest to astrobiology
- so that bonus samples in clean samples have a high potential to transform this mission from one of likely no interest to astrobiology
- to one that makes the first step of likely many missions involving a great deal of in situ study to find out if Mars had past life and if so its capabilities and where to look for it
- and the second step (after Viking) of likely many to find out if Mars has a present day biosphere and if so what forms of life inhabit it and where they live

Do suggest any other points to add here.

CLEAN.endorsements

  1. For samples with an exposure age of at least 80 million years, the 8.1 ppb of terrestrial organics and up to 0.7 ppb per biosignature throughout the returned rock and dirt samples are levels so high for astrobiology that it's unlikely we'd detect any traces of past life biosignatures even if the samples originally contained life 3 billion years ago
    � 
    Endorse - Click here when ready to email your endorsements to me
     
    See: The Perseverance samples will almost certainly be valueless for past life searches (and likely for present-day life too)
    - 8.1 ppb of terrestrial organics seems low compared to 100 ppb until you realize that the ionizing radiation leaves < 0.1 ppb of recognizable organics
    - astrobiologists want to send instruments to Mars able to detect a single amino acid in a gram
    - [IN NEPA BOTH - the < 0.1 ppb figure is NEW]
     
  2. It would greatly enhance the potential for astrobiology value to return samples of past organics from a recently excavated crater excavated to a depth of at least 2 meters, especially if a young crater is found only a few tens of thousands or hundreds of thousands of years old.
    � 
    Endorse - Click here when ready to email your endorsements to me
     
    Pavlov et al suggested looking for recent impact craters and rocks exposed by rapid wind erosion or perhaps in a deep valley for these reasons .
    (Pavlov et al., 2022, Rapid Radiolytic Degradation of Amino Acids in the Martian Shallow Subsurface: Implications for the Search for Extinct Life : page 113)
     
  3. It would greatly enhance the astrobiology value to return samples in clean containers with NO contamination of past rock samples with organics in them and this is true even if the samples are returned from a young crater excavated to a depth of 2 meters or more
     
    Endorse - Click here when ready to email your endorsements to me
     
  4. Signals such as biosignatures of past life on Mars are likely to be hard to detect
     
    Endorse - Click here when ready to email your endorsements to me
     
  5. We shouldn't present this mission as a mission that will resolve the question of whether Mars had life in the past - rather it should be presented as an important first step of many that may well yield no information about past life on Mars or results as ambiguous as for the structures in the Mars meteorite ALH84001
     
    Endorse - Click here when ready to email your endorsements to me
     
  6. We need to see this as a preliminary for future in situ missions that will let us intelligently select samples to return. It is most likely little more than a technology demo for astrobiology.
     
    Endorse - Click here when ready to email your endorsements to me
     
  7. Early samples of past organics from Jezero crater are unlikely to resolve central questions of astrobiology for past life
     
    Endorse - Click here when ready to email your endorsements to me
     
  8. If we can return past organics containing nitrogen, this is of especial interest for past life searches
     
    Endorse - Click here when ready to email your endorsements to me
     
  9. If we can return present day salts this is of especial interest for present day or recently alive life
     
    Endorse - Click here when ready to email your endorsements to me
     
  10. A large sample of wind blown dust has potential to reveal evidence of present day life if there is life on the surface even in distant parts of Mars
     
    Endorse - Click here when ready to email your endorsements to me
     
  11. If Mars does have extant life, it might have adapted to spread in dust storms as propagules spores, or biofilms, which would make samples of dust of especial interest
     
    Endorse - Click here when ready to email your endorsements to me
     
  12. There is great interest in returning a compressed clean sample of atmosphere to search for trace levels of gases of astrobiological interest such as methane
     
    Endorse - Click here when ready to email your endorsements to me
     
  13. It would be of especial interest if we could return multiple samples of atmosphere collected at different times of the year for seasonal analysis of variations in any gases.
     
    Endorse - Click here when ready to email your endorsements to me
     
  14. For present day life also it's important to present this mission as only the second step after Viking in a vigorous exploration that's likely to require dozens to hundreds of in situ probes to adequately make a start at exploring Mars
     
    Endorse - Click here when ready to email your endorsements to me
     
  15. With our modern understanding of Mars it is far more complex to study astrobiologically than it was as understood a couple of decades ago
    - with a surface area as large as the land area of all the terrestrial continents and islands and
    - many parts of the surface potentially biologically isolated for most species even if some can be transferred in dust storms
    - and with a great diversity of potential habitats to explore including many impossible to detect from orbit
     
    Endorse - Click here when ready to email your endorsements to me
     

JEZERO_MICROHABITATS. There is some potential for microhabitats in Jezero crater accessible to native martian life adapted to conditions there for billions of years
- caves
- micropores in salt
- the ultracold brines Curiosity found made more habitable with biofilms
- melting frosts even though only microns thick
- unexpected new microhabitat

Example microhabitats we might discover in Jezero crater include

JEZERO_MICROHABITATS.endorsements

  1. Caves - In the conference report from 2019, caves were one of the four top priorities for a search for extant (i.e. current) life on Mars (Mars Extant Life: What's Next? Conference Report. (html) : abstract). - Mars has the full variety of caves that can form on Earth as well as some novel types of cave such as caves from subliming carbon dioxide impossible on Earth (Location, location, location! Lava caves on Mars for habitat, resources, and the search for life) - and Mars has had active surface geothermal processes perhaps as recently as in the last 20 million years for the steam explosions recorded in the rootless cones (Interactions between Athabasca Valles Flood Lavas and the Medusae Fossae Formation (Mars): Implications for Lava Emplacement Mechanisms and the Triggering of Steam Explosions) and there is evidence of explosive volcanism 53 to 210 thousand years ago by crater counting (Evidence for geologically recent explosive volcanism in Elysium Planitia), so it's plausible there could be subsurface geothermal heating not far from the surface which we couldn't detect
     
    Endorse - Click here when ready to email your endorsements to me
     
    For caves, the main question relevant to the Perseverance samples would be if this would eject life on the surface occasionally for us to detect in dust spread in the winds - maybe fungal spores uplifted in thermals? or as a result of explosive volcanism

    (Mars Extant Life: What's Next?... :10)
    [relevant to Jezero crater]
     
  2. Water condensing on microbes inside micropores in salts (from the Atacama desert Mars analogues)
    : ( Wierzchos, et al., 2012, Novel water source for endolithic life in the hyperarid core of the Atacama Desert) (Vitek et al., 2012, Microbial colonization of halite from the hyper-arid Atacama Desert studied by Raman spectroscopy) (Davies, 2014, The key to life on Mars may well be found in Chile)
    [relevant to Jezero crater]
     
    Endorse - Click here when ready to email your endorsements to me
     
  3. ultracold brines found by Curiosity might be habitable to martian life that has found a way to retain water through to the warm midday temperatures in a biofilm or by other methods
    (Martínez et al, 2013, Water and brines on Mars: current evidence and implications for MSL) relevant to Jezero crater by (Chevrier et al., Global Temporal and Geographic Stability of Brines on Present-day Mars : Figure 7). ]
     
    Endorse - Click here when ready to email your endorsements to me
     
  4. Fresh water as melting frosts - fresh water is stable against freezing and boiling over 29% of the Martian surface but isn't stable against boiling because the air is too dry - if frost melts faster than its evaporation rate, the melt water can be briefly habitable in “slopes facing the sun, under clear sky and calm wind conditions, at locations with low surface albedo and low soil conductivity” (Water and brines on Mars... : section 2.1). Some experiments suggest this could happen even with frosts in Jezero crater a few 10s of microns thick which may be habitable for a few hours in the morning (Experimental Investigation of the Atmosphere-Regolith Water Cycle on Present-Day Mars). There are possible direct detections of frosts in Gale crater a few microns thick (Possible Detection of Water Frost by the Curiosity Rover) but the daytime temperature was too cold for the frosts to melt
    [potentially might be relevant to Jezero crater]

      Endorse - Click here when ready to email your endorsements to me
     
  5. Recurring Slope Lineae [uncertain]
    [most of those are likely caused by dust processes according to the latest research, but there is still the potential for liquid water to be involved in the process so they remain uncertain habitats - may need in situ studies to confirm (Kurokawa et al,, 2022, (Can we constrain the origin of Mars' recurring slope lineae using atmospheric observations?) ]
    [potentially might be relevant to Jezero crater as some potential RSLs were found in Gale crater]
     
    Endorse - Click here when ready to email your endorsements to me
     
  6. Endorse that there is significant potential to find a novel microenvironment in Jezero crater (similarly to Curiosity's surprise discovery of the ultracold surface brines)
     
    Endorse - Click here when ready to email your endorsements to me  

Do mention any other suggestion for a microhabitat relevant to Jezero crater.

DISTANT_MICROHABITATS. Microhabitats in distant parts of Mars that
- might be sources for propagules and biofilm fragments blown in the wind
- including scenarios for Martian life that has had billions of years of evolution to develop protection for transport in dust storms
- some distant habitats involve fresh liquid water such as the cryoconite holes (melt holes around sun warmed dust with an ice lid) and subglacial melt in polar regions

The experiments by Billi et al on survival of biofilms in the dust storms raises the possibility that native Martian life, adapted to be resistant to UV and other stresses over billions of years might be capable of long distance travel similarly to terrestrial microbes - with adaptations such as extra coatings to protect them from UV and reactive chlorates and chlorites. See my:

Yes perchlorates in the dust are bacteriocidal for b. subtilis when irradiated with UV
- but the effects are far less at lower temperatures or when mixed with dirt or dust
- a shadow under a rock or a few microns of dirt eliminates most of the UV
- a microbe imbedded in a crack in a grain is also more protected
- UV is reduced up to 97% during dust storms
- winds continue at night
- the organic plastic compounds exuded by biofilms (EPS) and other modifiers would protect microbes
- for instance EPS could protect microbes against oxidants like chlorates, and chlorites, or indeed hydrogen peroxide
- and Martian life is likely to have evolved extra protective layers
- or coated itself with iron oxides
- or evolve special biomaterials to protect itself against UV and oxidants

If native martian life can be transported thousands of kilometers in duststorms and still be viable, very distant habitats may be relevant to the potential for viable microbes in the samples maybe at very low numbers

  1. Droplets of salty water should form wherever salt lies on top of ice - the proposed mechanism for the Phoenix leg droplets Video: How liquid water forms on Mars paper: ( Experimental evidence for the formation of liquid saline water on Mars).
     
    Endorse - Click here when ready to email your endorsements to me
     
  2. Fresh water in cryoconite holes (tiny melt holes in the McMurdo Dry Valley Mars analogue habitats formed by dirt warmed by the sun which sinks below the surface, ice forms over them making a miniature greenhouse with fresh water in it) (Microorganisms on comets, Europa, and the polar ice caps of Mars) (The search for a signature of life on Mars: a biogeomorphological approach : 14)

     
    Endorse - Click here when ready to email your endorsements to me
     
  3. Fresh water as subsurface melt water in polar regions (this is the main way melt water forms in Antarctica and calculations suggest layers of 10s of cms thick of trapped fresh water should form over large areas of the polar regions about 5 cms below the surface wherever there is optically clear ice, even with surface temperatures on Mars as low as 180 °K (-93 °C) (Water and brines on Mars... : sections 2.2.2 and 3.1.2).
     
    Endorse - Click here when ready to email your endorsements to me
     
  4. Flow-like features in Richardson crater which extend at meters per day in spring time
    [features confirmed, likely to involve fresh water by modeling]
    [Both models for the flow-like features in Richardson crater involve fresh liquid water in some form. These features are often confused with the northern hemisphere flow-like features - similar in appearance and the same name but modeled by dust flows] (Water and brines on Mars: current evidence and implications for MSL: section 3.1.2)

    I couldn’t find any animated gifs for these. I couldn't find any animated gifs for these. Since the images are taken centered at different points on the Mars surface, it is impossible to line up all the features exactly between the images. I've aligned the flow like features in the vertical center of the image by preference. Higher resolution version: (Flow-like features)  

     
    Endorse - Click here when ready to email your endorsements to me
     
  5. Liquid water might form briefly from any exposed ice in the Hellas basin where even fresh water might be stable for up to a few hours. In Hellas basin the atmospheric pressure by one model it is 12.4 millibars and water would boil at 10°C (Making a Splash on Mars (about how water is unstable over most of Mars and close to boiling point of water in the Hellas basin))
     
    Endorse - Click here when ready to email your endorsements to me
     
  6. fumaroles that are currently inactive or hidden by ice towers but may be sporadically active: fumarole ice towers would be up to 30 meters high in the low Martian gravity. The terrestrial towers often collapse and reform over a timescale of decades (Volcano-ice interaction as a microbial habitat on Earth and Mars)

    Fumarole ice chimney on mount Erberus (GOLF 4-3-9 Antarctica Expedition 2012). Hoffmann et al. suggest its Mars analogue could be up to 30 meters high and up to 100 meters in diameter in Martian gravity and may be hard to spot because the ice would mask its thermal signature from orbit (The ice towers of Mt. Erebus as analogues of biological refuges on Mars).
     
    Endorse - Click here when ready to email your endorsements to me
     
  7. Temporary habitats in ice boulders in low latitudes thrown onto the surface after recent impacts that remain on the surface for several years before they are completely gone

    (JPL, 2022, NASA’s InSight Lander Detects Stunning Meteoroid Impact on Mars)

    Video: Flyover of Mars Impact Using HiRISE Data (Animation)

    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., 2002 . Amazonis Planitia: The role of geologically recent volcanism and sedimentation in the formation of the smoothest plains on Mars)
       
    Endorse - Click here when ready to email your endorsements to me
     

Do mention any other microhabitats to mention that are relevant for transport of life via the atmosphere

BONUS. Endorse Robert Walker's suggestion for a reasonable alternative
- as interesting enough to need evaluation:
- to add bonus samples of dust, salts, dirt, a compressed sample of atmosphere
- and a pebble or several pebbles collected by Marscopters
- ideally returned from a young crater excavated to at least 2 meters
- and containing organics
- returned in CLEAN containers
- to a miniature life detection lab above GEO
- similar to the Europa Lander life detection lab
- all the Perseverance geological samples are sterilized without opening them
- before they contact Earth's biosphere
- with ionizing radiation levels similar to levels already exposed to on Mars
- and the bonus sample are analysed in the miniature life detection lab above GEO
- in a Mars simulation chamber using natural sunlight similar to BIOMEX
- but with a centrifuge for artificial Mars gravity
- to attempt to replicate martian conditions for growth if there is any viable life in the samples
- and with enough gravity for instruments that can't function in microgravity
- this suggestion has potential for MORE science return at lower cost with many co-benefits

Skip to BONUS.endorsements if ready to endorse

Can you endorse any of these as PLAUSIBLE ENOUGH TO NEED EVALUATION?. I am not asking experts to second guess the outcome of any evaluation but just to say the proposal does need to be evaluated and these points considered.

By clean sample containers here I mean containers with no organics left or virtually no organics left, cleaned through an Ultra Cleaning Technique. We can do that by using pre-sterilization as for Perseverance or Viking, followed by ultra cleaning techniques such as carbon dioxide snow to remove any remaining traces of organics

The most promising candidate as Ultra Cleaning Technique appears to be the CO2 Snow Cleaning: this process removes micron and submicron particulates and hydrocarbon-based contamination by means of a snow stream confined in a N2 jet, impinging onto the surfaces to be cleaned. It is non-destructive, nonabrasive, residue-free, based upon the expansion of either liquid or gaseous carbon dioxide through an orifice. The contamination layer is removed by means of the synergic effects of the nucleation of small dry ice particles and a high velocity gas carrier stream. Upon impact with a dirty surface, the dry ice media removes particles by momentum transfer, local sublimation of CO2 snow which traps and carries away the contamination and also thanks to the thermal tension induced by the CO2 snow jet, which freezes the contamination layer. Finally, the high-velocity gas blows the contaminants away.

Giuliani et al.,, 2009. Contamination Control Approach for Exomars Mission

BONUS.endorsements

  1. With modern technology we can prepare containers and a simple scoop that are ultra clean with no or virtually no organics left - at far better than Viking level of sterilization - and protect them from contamination, and then open them on Mars
     
    Endorse - Click here when ready to email your endorsements to me
     
  2. Samples returned in ultraclean containers are of high value for astrobiological investigations of past or present day life on Mars
     
    Endorse - Click here when ready to email your endorsements to me
     
  3. Samples returned in ultra clean sample tubes with no or virtually no contamination from Earth, has potential for greatly increased science return for astrobiology (with the bonus samples) compared to the current mission only returning samples with an estimated 8.1 ppb of terrestrial organics and up to 0.7 ppb per biosignature
     
    Endorse - Click here when ready to email your endorsements to me
     

In my suggested alternative, all samples returned to Earth are sterilised. So these statements are about the science value of sterilized samples. The background here is that Perseverance is not attempting to target recently exposed rocks on Mars.

  1. WORTH EVALUATION:sterilization levels of ionizing radiation likely has no significant impact on most geological studies unless the samples were exposed to the surface very recently (e.g. recovered from a recently excavated crater)
     
    Endorse - Click here when ready to email your endorsements to me
     
  2. WORTH EVALUATION: sterilization levels of ionizing radiation likely won't lead to noticeable geological changes
     
    Endorse - Click here when ready to email your endorsements to me
     
     
  3. WORTH EVALUATION: less risk of impact on timelines and mission completion dates with the proposed alternative
     
    Endorse - Click here when ready to email your endorsements to me
     
  4. WORTH EVALUATION: likely to have widespread public support as a way to keep Earth 100% safe if explained carefully with good communicators on the team
     
    Endorse - Click here when ready to email your endorsements to me
     
  5. WORTH EVALUATION: return to a miniature life detection lab above GEO would lead to significant cost saving relative to a properly constructed fully telerobotic biosafety laboratory

    See: Because of quarantine issues
    - unsterilized samples have to be returned to a telerobotic facility until we know what's there
    - but likely costs well over half a billion dollars
    - and many issues with a ground based facility
    - including end of life sterilization for mirror life
    - nobody has done this before
    - and it also has to take account of accidents and criminal damage (for high levels of assurance)
     
    Endorse - Click here when ready to email your endorsements to me
  6. WORTH EVALUATING: return to a miniature life detection lab above GEO would likely cost less in the 2020s and similar cost overall to the current mission concept
    (just based on costs of a BSL-4 laboratory with no extra level of precautions to return Mars samples and not certified to contain ultramicrobacteria, or gene transfer agents)

    For my preliminary reasoning about costs see: This keeps Earth 100% safe with virtually no loss to science and little change in NASA’s budget
    – adds the cost of a Sample Sterilizing Satellite but saves on the mass of the aeroshell and the cost of a Sample Receiving Facility
     
    Endorse - Click here when ready to email your endorsements to me
     
  7. WORTH EVALUATION: significant cost saving especially in the 2020s even relative to NASA's own mission plans
     
    Endorse - Click here when ready to email your endorsements to me
     

If you want to say something stronger such as that you are confident that one or more of these points are valid do say in a personal statement or video

STIMULATE. Endorse that Robert Walker's suggested alternative of a miniature life detection lab above GEO has potential to stimulate instrument development for in situ searches on Mars and the importance of in situ searches

Here you can endorse that the miniature lab above GEO has a lot of potential that is worth exploring.

STIMULATE.endorsements
  1. Potential to encourage scientists to make instruments that we need for in situ searches on Mars
     
    Endorse - Click here when ready to email your endorsements to me
     
  2. Potentially can lead to space certification of these instruments tested in Mars simulation conditions including Mars gravity near to home where it's easy to send a replacement to fix issues or refine its capabilities
     
    Endorse - Click here when ready to email your endorsements to me
     
  3. We need these in situ instruments for a proper biological exploration of Mars which would require dozens or even hundreds of small surface probes, landers etc
     
    Endorse - Click here when ready to email your endorsements to me
     

ABOVE_GEO_ADVANTAGES.Endorse that Robert Walker's suggested alternative of a miniature life detection lab above GEO
- has many potential advantages over your current mission plan to explore
- to retain your world leading role in planetary protection
- be a good example for other nations to follow
- be the potential start of an international collaboration similar to the ISS in miniature
- also such a miniature life detection lab above GEO would be of great value
- for future astrobiological exploration of other locations in the solar system too
- such as to study samples returned from Ceres, Europa's ocean, Enceladus, Titan and so on
- excellent Mars simulation chamber
- and so on

Robert Walker's proposed reasonable alternative of a miniature life detection lab above GEO and sterilizing samples returned to Earth has many advantages that are worth exploring in an analysis comparing it with your current mission plan.

ABOVE_GEO_ADVANTAGES.endorsements

  1. retains NASA's world-leading role in planetary protection,
     
    Endorse - Click here when ready to email your endorsements to me  
  2. be an excellent example that’s easy for other space agencies and private space to follow to keep Earth 100% safe - they can either just sterilize their samples - or they can return to a satellite above GEO like you
     
    Endorse - Click here when ready to email your endorsements to me  
     
  3. It could be the seed of a growing “miniature space station” but of small modules a few meters across staffed by small telerobotic handlers and miniature instruments rather than humans
     
    Endorse - Click here when ready to email your endorsements to me  
     
  4. It could include a very excellent Mars simulation chamber using a centrifuge to simulate Martian gravity with windows that let in appropriately filtered sunlight, simulating a day night cycle inside which could be used for testing terrestrial organisms in Mars surface conditions or reproduce Mars surface conditions to try to get returned life to grow in the satellite.
     
    Endorse - Click here when ready to email your endorsements to me
     
  5. likely has less upfront cost this decade - no BSL-4 and this suggestion - and it may not even add to the mass for the Earth Return System - electropropulsion is ideal for minimum energy transfer orbits it needs only a few meters per second delta v for capture by the Earth Moon system, and move to the Earth Sun L2, the Earth Moon L2 and then more delta v to get to its final orbit - but this saves on the aeroshell and the fuel to ship the aeroshell to Mars and back
     
    Endorse - Click here when ready to email your endorsements to me
     
  6. adds the cost of a small satellite in a safe orbit above GEO in the 2030s (when launch cost to GEO will likely be greatly reduced)
     
    Endorse - Click here when ready to email your endorsements to me
     
  7. with a suggestion for small bonus samples gathered by the ESF rover in a clean container that would greatly enhance the science return for astrobiology.
     
    Endorse - Click here when ready to email your endorsements to me
     
  8. Achieves more science return, especially for astrobiology
     
    Endorse - Click here when ready to email your endorsements to me
     
  9. Has less legal complexity and can be done with a simple NEPA statement similarly to your sample returns from asteroids and comets
     
    Endorse - Click here when ready to email your endorsements to me
     
  10. Stimulates universities and other research institutions to work on novel miniature life detection instruments such as SETG to be space certified and send to the orbital telerobotic lab - which will then be exceptionally useful for in situ exploration on Mars - these instruments are also likely to have many terrestrial applications
     
    Endorse - Click here when ready to email your endorsements to me
     
  11. Prepares the way for future inspiring missions to Mars
     
    Endorse - Click here when ready to email your endorsements to me
     
  12. Also of great value for future astrobiological exploration of other locations in the solar system
    - such as to study samples returned from Ceres, Europa's ocean, Enceladus, Titan and so on
     
    Endorse - Click here when ready to email your endorsements to me
     

QUARANTINE. Endorse need for precautions to respond to lab leaks in any Mars Sample Receiving Facility
- but quarantine of human technicians can't keep out lifelong symptomless carriers like Typhoid Mary
- or many human diseases like Carl Sagan's example of Leprosy, latency period can be 2 decades
- or fungal diseases of vulnerable humans, crops or other organisms
- or life based on mirror chemicals that is pre-adapted to also use normal organics from infall from space
- and that Robert Walker's scenario of a miniature life detection lab above GEO solves all human quarantine problems
- at likely lower cost than a fully telerobotic biosafety laboratory without even small risks of escapes
- due to terrorism, criminal damage, plane crashes, inexperienced operators and other issues

Skip to QUARANTINE.endorsements if ready to endorse

Any biosafety laboratory with human technicians has to have emergency procedures in place for lab leaks.

Even the most well prepared laboratory may experience unintentional or intentional incidents or emergencies despite existing prevention or risk control measures.

(WHO, 2020, World Health Organization Laboratory biosafety manual, 4th edition : 87)

Carl Sagan talked about the “vexing question of the latency period” which is over decade for Leprosy

There is also the vexing question of the latency period. If we expose terrestrial organisms to Martian pathogens, how long must we wait before we can be convinced that the pathogen-host relationship is understood? For example, the latency period for leprosy is more than a decade.

(Sagan, 1973, The Cosmic Connection – an Extraterrestrial Perspective : 130)

We now know that leprosy can take 20 years or more to show symptoms (WHO, 2019, Leprosy, Key facts,)

In the Apollo era, NASA knew that they couldn't use quarantine to keep out an alien or novel pathogen of unknown properties with quarantine.

Richard Bryan Erb was the manager of the Lunar Receiving laboratory from 1969 to 1970 (Carroll, 2019, The Early History of Canadian Planetary Exploration). He explained that the Apollo quarantine procedures were just intended to try to stop a pathogen with a short incubation period of less than 3 weeks

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.

(Butler, 1999, Edited Oral History Transcript).

They couldn't guarantee to keep out a disease that was fast acting and lead to symptoms within 3 weeks either. as their plan was to rush anyone to hospital if they got seriously sick.

If a technician or astronaut 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:

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 [Lunar Receiving Laboratory] to a hospital, regardless of quarantine requirements

(Meltzer, 2012, When Biospheres Collide : 229).

So even if there was a rapidly acting pathogen and all the technicians got seriously ill quickly, they’d have been rushed to hospital, in an authorized breach of quarantine, so it wouldn’t have worked that well as a way to protect human health. That then risks Hospital-acquired infections (nosocomial infections) which are often the main way an infectious disease spreads, for instance this is one of the main ways MERS spreads.

Nosocomial outbreaks have been a hallmark of MERS-CoV infections, and account for roughly a third of MERS-CoV cases reported globally.

(Hui et al., 2018, Middle East respiratory syndrome coronavirus: risk factors and determinants of primary, household, and nosocomial transmission)

As Richard Erb put it in his oral history transcript:

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. So the quarantine issue has already been discussed again.

(Butler, 1999, Edited Oral History Transcript).

But NASA aren't thinking through the same decisions again with the Mars sample return mission. Instead, in this EIS, NASA has bypassed any need to look at this "vexing issue of the latency period" by not mentioning quarantine. There is only one use of the word quarantine in the EIS

The MSR Campaign is the first sample return mission to be classified as Restricted Earth Return, since the term was defined. (The Apollo 11, 12, and 14 missions were subjected to quarantine upon return until lunar samples were assessed and found to pose no hazard.)

(NASA, 2023, Mars Sample Return FINAL PEIS : 3-15)

I drew NASA's attention to this omission. In the final PEIS, they responded by saying that they would work out what to do based on established protocols used by biosafety labs in consultation with the CDC and NIH (i.e. in tier 2). But those labs of course have no established protocols for alien biology (such as mirror life) or a novel pathogen of unknown capabilities from another planet (such as a novel genus of fungal pathogen from Mars or even an alien life pathogen).

Also the history here is that NASA closed down their interagency panel, which had scientists from the CDC and NIH against repeated recommendations of the Space Studies Board. This isn't promising for their ability to coordinate with those agencies on management of a biosafety lab.

Robert Walker:

NASA's final PEIS has no mention of quarantine or other precautions for accidental release on Earth - just sterilization of the landing site. They don't consider issues of quarantine of technicians or of anyone contaminated during sample retrieval. There is an extensive literature on the topic. Then they just say (NASA, 2022eis: S-11): "Tier II analyses for determination of impacts associated with health and safety would consider the location of the proposed facility and surrounding community/land use type, health and safety system requirements associated with a BSL-4 equivalent facility, and risk analysis involving failure of containment systems that results in a release."

Indeed, the final PEIS is inconsistent on this topic. It mentions potential for health issues as a reason not to retrieve the sample to an orbital space station and yet they don't consider health issues for technicians within the facility on Earth. Yet once the sample reaches Earth, they decontaminate the landing site with chlorine dioxide and aldehydes and that is it by way of precautions, they only consider a possibility of hazards around the landing site. The Apollo mission used quarantine of technicians who were exposed to lunar samples in the sample receiving laboratory - and though they mention this they don't discuss it as a possibility for the Mars sample return

(NASA, 2023, Mars Sample Return FINAL PEIS : B-59)

NASA: Refer to the previous response for HS-007.

That leads to this reply:

Agger:

What would society do, for instance, if researchers in a Utah lab or research astronauts in a biosafety 4 lab on the Moon, were in a lab accident? What could be done for them and ethically with them? Bring them back to earth and/or let them out of the lab, potentially contaminating our biosphere?

NASA: (HS-007)

High-containment laboratories around the world have existing protocols for maintaining staff safety and addressing possible exposures to known infectious substances.

The MSR program would develop specific plans and procedures for safe handling of the Mars samples based on these protocols and related lessons learned—including what to do in the case of breach of containment—in close consultation with experts at organizations such as the Centers for Disease Control and the National Institutes of Health.

These plans will prioritize staff health and safety, and open communications with local, state, and federal organizations, as well as with the general public. NASA is not addressing the topic of astronaut contamination at this time, as it is out of scope for the current robotic MSR mission

(NASA, 2023, Mars Sample Return FINAL PEIS : B-30)

[So NASA say to leave it to them, they will work out what to do based on consulting experts at the CDC and NIH based on biosafety protocols already in use for biosafety laboratories

But we have no existing protocols for lab quarantine for a lab leak of mirror life or some novel fungal pathogen from Mars or even an alien life pathogen. See:

Also, NASA's MSR team have shown no understanding of public health, see for instance their answer on HEPA filters.

HEPA. Endorse that
- HEPA filters are not certified to achieve 100% containment of particles at all sizes from 0.05 microns upwards
- as recommended by the European Space Foundation to contain ultramicrobacteria
- 100% in this requirement means 100% also at the maximum penetrating size
- HEPA filters are only certified to achieve 99.97%
- NASA does need to provide an analysis of their plan to contain them with HEPA filters
- it is not sufficient to reply to a comment alerting them to this potential issue
- by just saying they don't concur that it is an issue
- the technology to achieve this level of containment doesn't seem to exist yet
- Robert Walker's suggested alternative has potential to protect Earth 100% from organisms of any size since all samples returned to Earth are sterilized

Also they closed down the interagency panel in 2006 turning it into a planetary protection subcommittee which they closed down in 2016 because their scientists weren't listening to them so they ceased to function

NASA has been world leading in planetary protection - but since early this century it moved the other direction against the advice of the Space Studies Board [NEW]

- so how can they be expected to work well with the CDC and NIH?]

So, I'm asking for endorsements to say that NASA has to consider this issue.

Do endorse anything here you agree on, even if it's just that NASA should discuss lab leaks and quarantine in this EIS.

My suggested alternative for a miniature life detection lab above GEO is one way that NASA could resolve this, playing to their strengths, without the need for a NASA run biosafety program to protect Earth or biosafety lab. If you agree that it has potential to resolve these issues, you can also endorse that as a reasonable alternative - NASA is legally required to look at reasonable alternatives submitted under NEPA in a timely fashion.

QUARANTINE.endorsements

If Mars samples are contained like risk group 4 organisms ( Mars Sample Return backward contamination–Strategic advice and requirements : 24) or are treated as having potential for large-scale harm to human health ( Assessment of planetary protection requirements for Mars sample return missions : 48)

  1. NASA does need to discuss lab leaks for unknown life and quarantine at tier 1 as a major issue not left to detailed discussion at tier 2 for site specific plans.

     
    Endorse - Click here when ready to email your endorsements to me
     
  2. There needs to be a way to ensure any Mars sample Return facility has precautions in place for a lab leak of potentially alien biology like life based on mirror organics, or novel or distantly related life
     
    Endorse - Click here when ready to email your endorsements to me
     
  3. Issues with quarantine for unknown microbes of unknown biology and capabilities form Mars are different from those for a biosafety lab containing human diseases which we already know a lot about.
     
    Endorse - Click here when ready to email your endorsements to me
     
  4. Some diseases such as Leprosy have an incubation period of decades and can't be contained with any practical quarantine period.<
     
    Endorse - Click here when ready to email your endorsements to me
     
  5. There have been life-long symptomless carriers for some human diseases such as Typhoid Mary for typhoid - which shows that it is impossible to keep out organisms with unknown capabilities using quarantine of human technicians
     
    Endorse - Click here when ready to email your endorsements to me
     
  6. There is no known method using human quarantine to keep out fungi or any other form of microbe that can set up home in a human microbiome unless we already have a known treatment available to eliminate it - for instance many opportunistic fungal pathogens are harmless in most people but cause severe allergic reactions in some people who are immunocompetent, and serious diseases of the lungs in others with weakened immune systems - if the technicians aren't affected they won't even show any symptoms and could harbour the fungus indefinitely
     
    Endorse - Click here when ready to email your endorsements to me
     
  7. In particular, if alien life, for instance, based on mirror organics is able to set up home in the human microbiome it would be impossible to use quarantine to keep it out
     
    Endorse - Click here when ready to email your endorsements to me  
    1. any mirror life on Mars is likely to be adapted to use normal organics because of infall of organics in meteorites and comets of mixed chirality from space, using isomerases to flip them to mirror life
    2. Life on Mars may well be adapted to take advantage of warm conditions since it may well spend time in warm refugia in underground caves, hydrothermal processes when surface conditions over part or all of Mars are less habitable.
       
  8. Based on these and any other examples you like to add, it seems to be impossible to use quarantine to contain potential risk group 4 organisms from Mars after a lab leak, when we don't know yet if there is life in the samples, or its capabilities if present, or its biological basis
     
    Endorse - Click here when ready to email your endorsements to me
     
  9. It may be possible to use a fully telerobotic facility as telerobots can be sterilized after a lab leak
    [Do say if you know of any other solutions]
     
    Endorse - Click here when ready to email your endorsements to me
     
  10. We have no experience of operating a fully telerobotic biological safety laboratory
     [Unless of course there is an example like this that I have missed?]
     
    Endorse - Click here when ready to email your endorsements to me
     
  11. The minimum cost of such a facility is likely to be well above half a billion dollars in 2015 US dollars (an estimate for the designs submitted to NASA a decade and a half ago, one of them fully robotic) - those designs didn't use the higher ESF requirement of 100% containment at 0.05 microns.

    See: Because of quarantine issues
    - unsterilized samples have to be returned to a telerobotic facility until we know what's there
    - but likely costs well over half a billion dollars
    - and many issues with a ground based facility
    - including end of life sterilization for mirror life
    - nobody has done this before
    - and it also has to take account of accidents and criminal damage (for high levels of assurance)
     
    Endorse - Click here when ready to email your endorsements to me
     
  12. From the point of view of public health, Robert Walker's suggestion
    - to study any unsterilized samples in a miniature telerobotic life detection lab above GEO
    - and to sterilize all materials returned to Earth's biosphere
    - has potential to eliminate all these quarantine issues as no human goes near the satellite
    - so there is no possibility of a lab leak contaminating human technicians
     [not asking to endorse the life detection science here, just endorse that this suggestion has potential to solve the quarantine issues from the point of view of public health]
     
    Endorse - Click here when ready to email your endorsements to me
     
    13. [ito endorse the life detection science, go to BONUS. Endorse Robert Walker's suggestion for a reasonable alternative ... (below)]
     
  13. The views expressed in the Mars sample return studies by the European Space Foundation and by the National Research Council count as major points of view on the effects on human health of a Mars sample return

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

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

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

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

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


     
    Endorse - Click here when ready to email your endorsements to me
     
  14. from the point of view of public health these views are not identical to the views expressed by NASA in the final PEIS that the effects of any lab leak would be negligible
     
    Endorse - Click here when ready to email your endorsements to me
     

I covered these and several other quarantine issues in attachment 8 for (Walker, 2022, Comment posted December 20th). However NASA's team dismissed this attachment as "nonsubstantive" in the second round of public comments and presumably also in the first round (NASA, 2023, MSR FINAL PEIS :B-28)

Text on graphic: Instruments for lab above GEO, lab leak issues, quarantine issues for human technicians etc.

By dismissing my attachment 8 as "Nonsubstantive" your team excluded the material needed to evaluate the suggested reasonable alternative of a miniature lab above GEO.

I covered many issues with quarantine of technicians in these sections of attachment 8 (Walker, 2022, NASA and ESA are likely to be legally required to sterilize Mars samples to protect the environment until proven safe) :

  • 119: Public health challenges responding to release of an extraterrestrial pathogen of unfamiliar biology
  • 121: Failure modes for sample containment
  • 122: Complexities of quarantine for technicians accidentally exposed to sample materials
  • 123: Vexing issue of authorizations to remove technicians from quarantine to treat life threatening medical incidents in hospital
  • 124: Example of a technician in quarantine with acute respiratory distress and symptoms similar to Legionnaires’ disease – a disease of biofilms and amoebae that adventitiously infects humans – and sometimes mentioned in planetary protection discussions
  • 126: Arbitrariness of technician’s quarantine period for an unknown pathogen – Carl Sagan gives the example of leprosy which can take 20 years or more to show symptoms
  • 127: How do you quarantine a technician who could be a life-long symptomless super-spreader of an unknown Martian pathogen?
  • 128: Martian microbes could participate harmlessly or even beneficially in the human microbiome but harm other terrestrial organisms when the technician exits quarantine - example of wilting Zinnia on the ISS
  • 130: What if mirror life becomes part of the technician’s microbiome?
  • 131: Potential for mirror life on Mars and survival advantages of mirror life competing with terrestrial life that can’t metabolize mirror organics
  • 133: Similar considerations apply to astronauts returning from Mars - in some scenarios such as mirror Martian life, astronaut quarantine would be insufficient to protect Earth’s biosphere
  • 134: A laboratory with the samples handled telerobotically as a solution to all these human quarantine issues – however the other problems remain and the safest way to do telerobotics is in an orbital facility with the robotics controlled remotely from Earth

FUNGAL. Endorse a novel fungal genus from Mars as a potential scenario for large-scale risk of harm to humane health, wild birds, pets and livestock

  1. If we return a novel fungal genus from Mars with similar properties to Aspergillus fumigatus this could be a serious health risk for humans, wild birds, pets like parrots, and poultry like turkeys
     
    Endorse - Click here when ready to email your endorsements to me
     
  2. We can't rule out a likely low risk of unprecedented harm to humans, wildlife or livestock
    [similar to the house fire scenarios for fireproofing a house and smoke detectors]
     
    Endorse - Click here when ready to email your endorsements to me
     

ALIEN. This is for scenarios where we return a new type of alien life which finds Earth as habitable as Mars or more habitable than Mars
- we do not know that life with a different basis from DNA or different amino acids would be harmless to humans or our biosphere
- we need a respect for the unknown as NASA's first planetary protection officer John Rummel put it
- Joshua Lederberg said "Whether a microorganism from Mars exists and could attack us is more conjectural.
- "If so, it might be a zoonosis [infectious disease that jumps to humans] to beat all others."
- we don't have the answers here
- though at first it seems unlikely
- there may be some scenarios where returning alien life from Mars leads to large-scale or unprecedented harm to human health

Skip to ALIEN.endorsements if ready to endorse

It seems important to consider this topic when returning samples from Mars. Could alien pathogens of an alien biology harm us, and if so, how?

However as far as I know in the entire planetary protection literature, it's only been touched on briefly in two papers by Joshua Lederberg from 1999, in a section of a few paragraphs in each paper. Joshua Lederberg got his Nobel prize for discovering bacterial sex in 1946 (Joshua Lederberg on Bacterial Recombination) (Joshua Lederberg The Nobel Prize in Physiology or Medicine 1958 ), and was a key figure in early work on planetary protection, first developing an interest in it in the late 1950s (How the Cold War Created Astrobiology, Life, death, and Sputnik). He said

"Whether a microorganism from Mars exists and could attack us is more conjectural. If so, it might be a zoonosis [infectious disease that jumps to humans] to beat all others.

Quote from: (Parasites face a perpetual dilemma)

Longer quote to put it in context:

Whether a microorganism from Mars exists and could attack us is more conjectural. If so, it might be a zoonosis [infectious disease that jumps to humans] to beat all others.

On the one hand, how could microbes from Mars be pathogenic for hosts on Earth when so many subtle adaptations are needed for any new organisms to come into a host and cause disease? Dozens if not hundreds of bacterial genes need to work in concert to enable a microorganism to be a pathogen. On the other hand, microorganisms make little besides proteins and carbohydrates, and the human or other mammalian immune systems typically respond to peptides or carbohydrates produced by invading pathogens.

Thus, although the hypothetical parasite from Mars is not adapted to live in a host from Earth, our immune systems are not equipped to cope with totally alien parasites: a conceptual impasse.

Quote from: (Parasites face a perpetual dilemma)

From the context it's clear he is not implying that there are vertebrate animals on Mars. He just means an organism from Mars that is able to infect humans (a non standard use of the word "zoonosis" which is often used in a loose way, or a metaphor).

Given the potential for unprecedented harm for human health if it turns out to be a "zoonosis to beat all others", I felt it was important to look at it more closely. I worked up some preliminary scenarios for this. From these, it seems that alien pathogens could harm us in some scenarios. These are for the next section.

For instance the way a fungus like Aspergillus attacks us is very straightforward in principle and could be used by an alien fungus not even adapted to a pathogenic lifestyle in alien life.

John Rummel, NASA;s first planetary protection officer, said people have to have respect for the unknown.

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)

Based on Joshua Lederberg's points, any thoughts on the example scenarios I found, any other scenarios you think of, and your own expertise, this is the general point to endorse (if you agree):

ALIEN.endorsements

  1. We do not know that an organism not based on DNA would be harmless for human health
     
    Endorse - Click here when ready to email your endorsements to me
     
  2. It seems possible that there could be (likely rare) scenarios where alien life would risk unprecedented levels of harm to human health, wildlife, pets or livestock
    [Similar to house fire scenarios again]
     
    Endorse - Click here when ready to email your endorsements to me
      
  3. We do need respect for the unknown when devising methods to protect human health, wildlife, pets, and livestock, from alien life not based on terrestrial biology
     
    Endorse - Click here when ready to email your endorsements to me
     
  4. It may be impossible to reverse the process of accidentally introducing an alien biology to the terrestrial biosphere.
     
    Endorse - Click here when ready to email your endorsements to me
     
  5. This would make it a change for all future time.
     
    Endorse - Click here when ready to email your endorsements to me
     
  6. If alien biology is similar in capabilities to terrestrial life it may eventually be able to live everywhere terrestrial life exists
     
    Endorse - Click here when ready to email your endorsements to me
     
  7. The alien biology might eventually become pervasive and abundant everywhere terrestrial life is found, though it might take months, years, decades, centuries or longer depending how much adaptation is needed
     
    Endorse - Click here when ready to email your endorsements to me
     
  8. If we introduce a novel biology to Earth's biosphere the result is likely to be complex and hard to predict.
     
    Endorse - Click here when ready to email your endorsements to me
     
  9. An alien biology may be totally beneficial to Earth's biosphere, but it could also be harmful or mixed in its effects, beneficial to some organisms and ecosystems, harmful to others
     
    Endorse - Click here when ready to email your endorsements to me
     

ALIEN_SCENARIOS. Specific scenarios for harm to human health from alien life
- likelihood of any of these rare and these need peer review
- just to give an idea of the breadth of the field we need to consider
- alien fungi that invade our lungs similarly to Aspergillus
- with neutral cell walls resembling eukaryote cells so we have no broad spectrum protection
- and no specific pattern recognition of the novel fungus
- potential for allergic reactions to alien life
- pathogens based on alien life may be hard to diagnose
- alien life that doesn't notice terrestrial biology might still lead to harmful effects
- similarly to the blood clots and other effects of nanoplastics and microplastics
- these only show up with large quantities of microplastics but may be an issue if we have similar numbers of terrestrial and alien microbes
- potential to misincoprorate amino acids causing protein misfolding and neurological diseases like Lou Gehrig's disease which afflicted Stephen Hawking
- alien bioactive compounds could be beneficial in many ways but also harmful in many ways
- alien life in the human microbiome could affect digestion, or tooth decay and other features of our microbiome

I have found no research on the potential for pathogens based on a completely alien biology except Lederberg's two papers in 1999 where it is mentioned in one section in each paper. Very interested if anyone knows of any research on this topic. I cover some of what I did here:

The whole topic of the potential for harm from alien biology is unexplored territory, terra incognito in the literature (again do say if you know of anything published on it).

You can endorse:

ALIEN_SCENARIOS.endorsements

  1.  There is some potential that completely alien life based on a different biology could harm us.

    Joshua Lederberg, winner of a Nobel prize in 1958 for his discovery of bacterial sex.

    "Whether a microorganism from Mars exists and could attack us is more conjectural. If so, it might be a zoonosis [infectious disease that jumps to humans] to beat all others. "

    Quote from: (Parasites face a perpetual dilemma : 79 - Contemplating interplanetary zoonoses).

    ��
    Endorse - Click here when ready to email your endorsements to me
     
  2. There is some potential for developing specific analogues for alien life such as alien fungi based on extrapolations of modes of action for terrestrial life and the behaviour of our immune system.
     
    Endorse - Click here when ready to email your endorsements to me
     
    Here I can' t refer to the peer reviewed literature as there seems to be no peer reviewed literature on potential for alien pathogens either way, about whether it's possible or not, apart from Joshua Lederberg's two papers which would suggest it is possible.

    I cover various potential scenarios for alien life in my preprint which are more specific and detailed, but it's not peer reviewed yet.

    I cover some of those scenarios here which I'll include as it gives an idea of the breadth of this unexplored field though none of these are yet peer reviewed. If you have a relevant field of expertise and wish to endorse any of these as plausible based on your own understanding then feel free to do so.

    The gnarly question of our vulnerability to a completely alien biology     - “Whether a microorganism from Mars exists and could attack us is more conjectural. If so, it might be a zoonosis [infectious disease that jumps to humans] to beat all others” - Joshua Lederberg (discoverer of bacterial sex and pioneer in planetary protection)
    1. Scenario of alien fungal analogues with neutral cell walls - they would evade the broad-spectrum anti-bacterials like terrestrial fungi - and fungi also have a straightforward mode of infection, inserting tendrils into a cell from outside to extract organics which alien life could use
       
      Endorse - Click here when ready to email your endorsements to me
       
    2. Scenario where our immune system provides no protection against an alien fungus
      - we are protected from fungi such as Aspergillus by specific adaptations of our immune system to recognize this genus (PAMPS)
      - without these patterns our bodies might ignore a novel fungal genus of either terrestrial or alien biology it has never encountered before
      - and there might be no anti-fungals available that work with it

       
      Endorse - Click here when ready to email your endorsements to me
       
    3. Potential for allergic reactions to a novel fungal genus or an alien biology
      - without the fine tuned balance between allergic reactions and immune defences for diseases it already encountered
      - we are protected from a fungal genus like Aspergillus not just by the PAMPS to recognize it
      - we also need Treg cells and DAMPS to dampen down the immune response to prevent overreacting if it is noticed
      - without this fine tuned balance we may have allergic reactions or we may not be defended adequately

       
      Endorse - Click here when ready to email your endorsements to me
       
    4. A novel fungal disease based on an alien biology might be hard to diagnose
      - it be hard to spot if it resembles tuberculosis in its effects on our lungs as with Aspergillus
      - it might be months to years we have antifungals that target the cellular processes of an alien biology that are also safe for humans to use
      - it is typically 12 years from discovery to dispensing medication for a novel antifungal
      - though this would surely be accelerated in an emergency situation as for COVID
       
      Endorse - Click here when ready to email your endorsements to me
       
    5. Nanoplastics and microplastics as an analogue of alien life that doesn't even notice terrestrial life but still gets through our skin and lungs into our blood stream which then covers them in plasma coronas that stick together in blood clots
       
      Endorse - Click here when ready to email your endorsements to me
       
    6. Totally alien life could cause allergic reactions or sterile inflammation similarly to silicosis - analogy of microplastics and nanoplastics
       
      Endorse - Click here when ready to email your endorsements to me
       
    7. Alien life with a different vocabulary of amino acids to make its proteins could lead to protein misfolding as a result of alien amino acids getting attached to transfer RNA in our cells - similarly to BMAA which causes protein misfolding and is neurotoxic and may be a contributing cause for neurodegenerative diseases such as the one Steven Hawking suffered from
       
      Endorse - Click here when ready to email your endorsements to me
       
  3. Alien life could also produce products that are accidentally toxic.
     
    Endorse - Click here when ready to email your endorsements to me
     
    1. Accidental toxins similarly to Tetanus
    2. Secondary metabolites, e.g. that inhibit the growth of other organisms
    3. protoxins which our biology turns into a toxin, similarly to the way methanol is toxic for humans
    4. The chemistry itself may be toxic, e.g. for the salty water that fills cells, Martian life could use perchlorates or a mix of salts internally instead of chlorides, and these may be toxic to humans
    5. waste products of alien life may also be accidentally toxic, protoxins, or allergens.
  4. Alien life that sets up home in the human microbiome could influence our ability to digest food or affect our health
     
    Endorse - Click here when ready to email your endorsements to me
     
    1. scenario of alien life in the gut microbiome can impact on our ability to digest food, byproducts of that digestion and human health
    2. alien life in other regions of the human microbiome could affect our health, e.g. involved in tooth decay, in our sinuses or on the skin.

For more about 3 and 4 see : An unrelated exobiology may produce many novel bioactive compounds which could be of great benefit, but the difference in biochemistry could also lead to more accidental toxins than terrestrial life, and in some scenarios, the internal chemistry of an unfamiliar exobiology could be accidentally toxic

These are from my section here:

.

HEPA. Endorse that
- HEPA filters are not certified to achieve 100% containment of particles at all sizes from 0.05 microns upwards
- as recommended by the European Space Foundation to contain ultramicrobacteria
- 100% in this requirement means 100% also at the maximum penetrating size
- HEPA filters are only certified to achieve 99.97%
- the technology to achieve this level of containment doesn't seem to exist yet
- this is a substantial issue that needs to be addressed in the EIS itself
- not a minor detail to be left to later when the facility is built
- Robert Walker's suggested alternative
- to study any unsterilized samples in a miniature telerobotic life detection lab above GEO and to sterilize all materials returned to Earth's biosphere
- has potential to protect Earth 100% (no appreciable risk) from organisms regardless of any size limit
- since all samples returned to Earth are sterilized

Skip to HEPA.endorsements if ready to endorse

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

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

This new size limit was the result of new science which revealed that some microbes, the ultramicrobacteria, can be long and thin, and remain still viable after passing through 0.1 micron nanopores. This makes them far smaller than was realized to be possible when the previous limit of 0.2 microns was set in 1999 (Ammann et al., 2012, Mars Sample Return backward contamination–Strategic advice and requirements : 15).

The European Space Foundation cited two studies that established this, in freshwater from Greenland (Detection and isolation of ultrasmall microorganisms from a 120,000-year-old Greenland glacier ice core) and 20 different sites in Switzerland (Quantification of the filterability of freshwater bacteria through 0.45, 0.22, and 0.1 μm pore size filters and shape-dependent enrichment of filterable bacterial communities).

This result about the viability of ultramicrobacteria after passing through 0.1 micron nanopores has been confirmed many times since then and the ultramicrobacteria that got through have also been imaged using electronmicroscopes (they are far too small to be seen with optical microscopes even at the highest optical resolution possible of 0.2 microns).

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

ESF limit = ~⅛ of the wavelength of violet light

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)

violet bar for shortest wavelength of violet light (380 nm or 0.38 microns)

Mars might well have tiny microbes because

  • very small cells can escape grazing by larger grazing amoebas which don’t notice them
  • very small cells have a larger surface area to volume ratio, so can use nutrients better in nutrient poor conditions

See: (Ghuneim et al., 2018, (Nano-sized and filterable bacteria and archaea: biodiversity and function)

So this is a major issue.

Although I alerted NASA to this issue in both rounds of public comments they have never mentioned it in the EIS. On the final PEIS they at last replied only to say that they don't agree with me when I say that this is beyond the capabilities of a BSL-4 (NASA, 2023, MSR FINAL PEIS : B-62)

So NASA are not challenging the recommendation. They simply believe that they can use a BSL-4 with HEPA filters to contain 100% of particles at 0.05 microns and upwards.

This is one of many examples that show we are not dealing with anyone there with basic knowledge of public health.

So, I'm looking for endorsements by experts that HEPA filters are not able to meet this requirement and that it is a significant challenge that should be looked at at an early stage in an Environmental Impact Statement and not left to Tier 2 as detail to be worked out later.

For more details about the ESF requirements and about how HEPA filters can't meet them expand the section below:

This is what the ESF recommend:

The European space foundation said we have to contain ultramicrobacteria and gene transfer agents - well beyond the capabilities of a BSL-4 - based on the science of 2012 - the ESF in 2012 updated this 1999 requirement to 1 in a million containment for a single particle of 0.01 microns or larger, and 100% containment for 0.05 microns or larger (Ammann et al., 2012, Mars Sample Return backward contamination–Strategic advice and requirements : 48).

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 10 -6 .

…

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

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

Screenshots from (Ammann et al., 2012, Mars Sample Return backward contamination–Strategic advice and requirements : 21 and: 48).

A HEPA filter is not able to fulfill this requirement.

Text on graphic: ESF study requires at most a one in a million chance of a single particle released from the facility of ANY SIZE above 0.01 microns and 100% CONTAINMENT AT ANY SIZE 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.

For details see

So - this is what I'm asking for experts to endorse :

HEPA.endorsements

Based on the recommendation by the European Space Foundation, which NASA do not contest, that a sample receiving facility has to contain ultramicrobacteria and gene transfer agents, with 100% containment at 0.05 microns upwards and only 1 chance in a million of release of a single particle at 0.01 microns and upwards for the entire lifetime of the facility ( Mars Sample Return backward contamination–Strategic advice and requirements : 21, 48).

.

  1. The ESF requirement that "The release of a single unsterilized particle larger than 0.05 μm is not acceptable under any circumstances " is not fulfilled by the HEPA specification of 99.97% containment at the maximum penetrating particle size, but would need 100% containment at all the sizes within range of testing for a HEPA filter
     
    Endorse - Click here when ready to email your endorsements to me
     
  2. The technology currently used for HEPA filters can't achieve 100% containment of particles at all sizes from 0.05 microns and larger and can't achieve 1 in a million chance of release of a single particle for the entire lifetime of the facility at all sizes from 0.01 microns and larger.
     
    Endorse - Click here when ready to email your endorsements to me
     

    NASA essentially don't see this requirement as a challenge, they think HEPA filters can already achieve it.

    NASA is aware of the ESF Mars Sample Return backward contamination study. NASA does not concur that 0.05-micron (50 nm) particles cannot be managed; standard High Efficiency Particulate Air (HEPA) filters like those used in biosafety facilities are tested for effectiveness at or near the Most Penetrating Particle Size (MPPS), which is typically 0.12 micron. (Perry et al, 2016, (Submicron and nanoparticulate matter removal by HEPA- rated media filters and packed beds of granular materials).“Particles both larger and smaller than the MPPS (including bacterial spores and viruses) are removed with greater efficiency.”
    (NASA, 2023, MSR FINAL PEIS :B-62)
    [In some scenarios martian ultramicrobacteria would be imbedded in cracks in dust grains and based on potentially more resilient non terrestrial biology, making them especially hard to contain]
     
  3. Even the more stringent ULPA standard ("Ultra-low Penetration Air (filter)") still lets some particles through. ULPA level 17 filters are rated to filter out 99.999995 percent of particles (BS, 2009, High efficiency air filters (EPA, HEPA and ULPA), Part 1: Classification, performance testing, marking : 8) in the range 0.12 microns to 0.25 microns ((BS, 2009, High efficiency air filters : 4) according to BS EN 1822-1:2009, the British implementation of the European standard. This means they can still let through 1 in every 20 million particles which is not enough for "The release of a single unsterilized particle larger than 0.05 μm is not acceptable under any circumstances"
     
    Endorse - Click here when ready to email your endorsements to me
     
  4. Not aware of any proposals to develop a capability to contain 100% of particles at 0.05 microns and upwards
    [Unless any endorser knows of such a proposal?]
     
    Endorse - Click here when ready to email your endorsements to me
     
  5. The is a substantial issue that needs to be addressed in the EIS itself and not a minor detail that can be left to be decided later at Tier 2 when a biosafety laboratory is designed and built.
     
    Endorse - Click here when ready to email your endorsements to me
     
  6. By the ESF's recommendation 8 in 2012 to do a review of the size limit and level of assurance on a regular basis
    - we need a new review of the size limit and level of assurance
    - before we can design a terrestrial facility that risks exposing samples to contact with Earth's biosphere.
     
    Endorse - Click here when ready to email your endorsements to me
     

    7. 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

    (Ammann et al., 2012, Mars Sample Return backward contamination–Strategic advice and requirements : 48).


     
  7. From the point of view of public health Robert Walker's suggestion
    - to study any unsterilized samples in a miniature telerobotic life detection lab above GEO
    - and to sterilize all materials returned to Earth's biosphere
    - has potential to protect Earth 100% (no appreciable risk) from organisms regardless of any size limit
    - since all samples returned to Earth are sterilized

    This proposal seems to have potential as a reasonable alternative to deal with the issue of the inadequacy of HEPA filter    s to contain such small particles and needs to be recognized as an alternative and looked at in a valid EIS  
     
    Endorse - Click here when ready to email your endorsements to me
     
  8. The view expressed in the Mars sample return study cited here by the European Space Foundation counts as a major point of view on precautions needed to protect Earth's biosphere and inhabitants from the environmental and public health effects of a Mars sample return that should be discussed in an EIS for a Mars sample return mission,
     
    Endorse - Click here when ready to email your endorsements to me
     
  9. From the point of view of public health the European Space Foundation recommendations are not identical to the proposal to use many of the principles of a BSL-4 in the EIS
     
    Endorse - Click here when ready to email your endorsements to me
     

I alerted NASA to this issue in both rounds of public comments but they never mentioned my comment or the issue in the final PEIS.

They didn't mention this issue in the final PEIS either but they at last responded to my comment alerting them to this issue. They don't contest the ESF recommendation. They just say that they don't concur with me when I say it goes beyond the capabilities of a BSL-4 with HEPA filters.

NASA seem to either not understand how NEPA filters work or not understand the ESF requirement.

.

This is what I said to NASA:

Robert Walker

final PEIS OMITS the 2012 European Space Foundation study which reduced the size limit to 0.05 microns from the previous value of 0.2 microns – a serious omission since containment at 0.05 microns is well beyond the capability of BSL-4 facilities
...
ESF study: “the release of a particle larger than 0.05 μm in diameter is not acceptable in any circumstances”

(NASA, 2023, MSR FINAL PEIS 3–3),

I.e. the ESF requires 100% CONTAINMENT AT ALL SIZES FROM 0.05 MICRONS UPWARDS.

NASA's reply is they don't concur with me that a BSL-4 using HEPA filters can't achieve containment at 0.05 microns.

NASA

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

(NASA, 2023, MSR FINAL PEIS : B-62)

Their reply must be based on a misunderstanding of either the ESF requirement or how HEPA filters work.

  • HEPA filters always have a Most Penetrating Particle Size, as NASA themselves say. The key word there is penetrating. The MPPS is the size of particle that penetrates the HEPA filter most often. This concept is based on the idea that some particles get through. It's only 99.97% containment and doesn't comply with the ESF 100% standard.
     
  • The ESF requires 100% containment which means NO PENETRATING PARTICLES. The ESF's text makes it very clear.

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

I have come across this confusion about what the ESF recommendation means before. It might be that NASA read the recommendation as

“the release of a particle of exactly 0.05 μm in diameter is not acceptable in any circumstances”

rather than what it actually says:

“the release of a particle larger than 0.05 μm in diameter is not acceptable in any circumstances”

(Ammann et al., 2012, Mars Sample Return backward contamination–Strategic advice and requirements : 48).

The filters are thought to achieve almost 100% containment at 0.05 microns though this is hard to measure as it's hard to actually see test aerosols this small when they are illuminated as they are only an 8th of the wavelength of violet light.

But even if the only aim was to contain ultramicrobacteria we'd need to contain them within water droplets, imbedded in cracks in dust grains or clumped together. Also the ESF's requirement was for ultramicrobacteria as just the smallest size of microbe to contain.

In my literature survey I haven't found any filters that satisfy this capability. Actually even at 0.05 microns it's only contained probabilistically as those particles are far smaller than the gaps between the fibers and they contain the particles by brownian motion, the jostling by air molecules. So even at 0.05 microns a few particles get through.

See:

EURO-CARES is the only Mars Sample Receiving Facility design I've found that cites the ESF recommendation is the EURO-CARES design. This deals with the ESF recommendation by using ULPA filters but due to an unfortunate typo targets a 1 in a million chance of containment at 0.1 microns instead of 0.01 microns and doesn't consider the requirement for 100% containment of all particles of 0.05 microns and greater.

Also they may not have appreciated that the ESF 1 in a million figure is for the probability of release of a single particle of 0.01 microns and larger during the entire lifetime of the facility, rather than a million-fold reduction of 0.01 micron particles.

Unlike HEPA filters ULPA filters can achieve more than a million-fold reduction in particles, but but those aren't sufficient for the ESF recommendations either.



(Hutzler et al., 2017, EURO-CARES Extraterrestrial Sample Curation Facility: Architecture as an enabler of science : 5)
 

SAFETY. It will be impossible to do safety testing with the Perseverance samples
- the high levels of forwards contamination means that all the samples will go to hold and critical review with false positives
- the genetic inventory can't be used with even 1196 genera with two few reads to identify out of 98 swabs
- it's impossible to prove that samples are lifeless by attempting to cultivate life from them
- and even for the bonus samples it will be impossible to prove they are lifeless to a high degree of assurance
- given the potential for ultra low populations
- possibly as few as one viable cell in the samples brought in the dust or in a local microhabitat
- this also makes it impossible to use returned samples to prove that it is safe to send humans to Jezero crater
- there is no substitute for Carl Sagan's "vigorous programmed of unmanned exobiology" with this as the second step after Viking
- out of dozens or even hundreds of landers needed before we can be well informed about whether Mars has a biosphere
- and whether it is safe to let the biospheres of Earth and Mars to mix freely if it does have one.

This is the reasoning I give to the conclusion that due to the high level of contamination, it's impossible to do safety testing with the samples returned by Perseverance, so they will all go to hold and critical review and can't be released until we learn more about Mars and if it has life and what its capability is if there is life there.

It also leads to the conclusion that even for the bonus samples collected in 100% sterile and clean containers, it's still impossible to do safety testing to a high level of assurance as there could be a viable microbe in a crack in a dust grain even if all except 1 milligram of a 1 gram sample was destructively tested to search for life.

It also leads to the conclusion that it's impossible to use the Perseverance samples with or without bonus samples to prove that it is safe to send humans to Jezero crater. This is not given as a need in the EIS but has been stated as a need in a recent paper

The only way to find out if there is life on Mars and to learn about its capabilities is to do Carl Sagan's vigorous program of unmanned exobiology. This is also the only way to make a start on an evaluation of the effect of mixing life from the two biospheres if Mars does have a biosphere or the effect of introducing the anthropocene on Mars if Mars has uninhabited habitats.

So - this is for you to endorse part or all of this reasoning.

If you have other ideas about all this do say, and I can add other points to represent the diversity of views on the topic.

SAFETY.endorsements

  1. Endorse the COSPAR finding that we have only limited capability to predict the effect of introducing new species from Mars to our biosphere, so the only practical form of safety testing at present is to show that there are no Martian organisms in the samples (until we know a lot more about what life there is on Mars if any)
     
    Endorse - Click here when ready to email your endorsements to me
     

    .Unfortunately, we have only a limited ability to predict the effects of terrestrial invasive species, emerging pathogens, and uncultivated microbes on Earths' ecosystems and environments. This is true even for cultured and fully genome-sequenced terrestrial organisms and more so for potential extraterrestrial life. Thus, conducting a comprehensive sample safety assessment with the required rigor to predict harmful or harmless consequences of potential martian life for Earth is currently not feasible.

    ...
    Conducting a comprehensive safety assessment with the required rigor to predict harmful or harmless consequences for Earth is not feasible. Therefore, the scope of the SSAF is limited to evaluating whether the presence of martian life can be excluded in the samples. Any possible hazard is only considered in the sense that if there is no martian life, there is no extraterrestrial biological hazard in the samples.

    (COSPAR Sample Safety Assessment Framework (SSAF) | Astrobiology)

    2. . 

  2. It will not be possible to use the inventory of microbial life from cleanroom swabs from the Perseverance clean room to distinguish terrestrial contamination from potential martian life with a common ancestry, with 1250 genera found in 98 swabs, only 54 of them with enough read to identify the genus with 1196 distinct and unidentified genera, and 4 of the identified species with < 98.7% similarity with the closest terrestrial species.
     
    Endorse - Click here when ready to email your endorsements to me
     
    The iMost team suggested using a genetic inventory to distinguish between terrestrial contaminates and indigenous martian life.(Beaty et al., 2018 : 94). However this didn't work out in practice because there was so much variation from swab to swab from the 98 swabs found, and so many genera that couldn't be read (Hendrickson et al., 2021, Clean room microbiome complexity impacts planetary protection bioburden).

    For details see: No way to reliably distinguish terrestrial and martian biosignatures
    - the attempt at a genetic inventory turned up 1196 distinct genera with too few reads to identify them
    - and amongst the 54 genera that could be identified
    - four species with less than 98.7% resemblance to the closest known species
     
  3. Endorse the COSPAR statement that it is not possible to prove that the samples are free of any martian life by attempting to cultivate life from them as many terrestrial microbes that do well in the wild can't be cultivated in the laboratory and similarly there could be martian life in the samples that could survive in the wild but can't be cultivated in the labs.
     
    Endorse - Click here when ready to email your endorsements to me
     

    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]
    (Kminek et al, 2022,     COSPAR Sample Safety Assessment Framework (SSAF) )


  4. From 1-3, all the samples returned from Jezero crater will go to hold and critical review and can't be released unsterilized, a possible consequence of terrestrial biological contamination that was recognized in the COSPAR study that the EIS relies on for safety testing.
       
    Endorse - Click here when ready to email your endorsements to me
     

    One complication is that terrestrial biological contamination would impact the specificity of the test, that is, leading to a false positive.

    ...

    (for step 7)

    It is expected that this step could lead to a number of positive events that are likely associated with terrestrial contamination. However, until any evidence for life can be clearly associated with terrestrial contamination, the conservative assumption (positive hypothesis) is that it could be martian biology

    (Kminek et al, 2022, COSPAR Sample Safety Assessment Framework (SSAF) ) 

  5. So the safety testing in the Needs section of the Environmental Impact Statement serves no purpose for the Perseverance samples and it is improper to use this as a requirement to exclude reasonable alternatives such as sterilizing samples before they are returned to Earth's biosphere.
     
    Endorse - Click here when ready to email your endorsements to me
     
  6. By the 2015 Space Studies Board review of SR-SAG2, if there is viable life in Jezero crater, it could occur in very low numbers such as just a few viable cells or only one viable cell per gram, either because it is only found localized in rare microhabitats, or because it gets there through atmospheric transport in dust storms.
     
    Endorse - Click here when ready to email your endorsements to me
     
  7. As a result, even with bonus samples in clean containers of dust, dirt or salts, it will be impossible to prove an absence of life in the samples to a level of assurance acceptable if we need a high level of assurance that the unsterilized samples are safe for Earth.
     
    Endorse - Click here when ready to email your endorsements to me
     

    The COSPAR Sample Safety Assessment Framework (SSAF) refers to this problem that there is no guarantee that any Martian life has got into the subsamples examined.:

    There is also another complication: even if there is life somewhere in the sample tube, there is no guarantee that there will be life in the subsamples that are examined.

    (Kminek et al, 2022, COSPAR Sample Safety Assessment Framework (SSAF) )

    This issue could be very acute in some scenarios

    • Scenario of life in the Martian dust at low concentrations, a few viable cells per gram or less, brought to Jezero crater from distant locations on Mars.

See also this response I did to NASA's replies to public comments:

.

HOTTECH. Although there is no way to establish that Mars is safe for humans with a sample return mission
- as a result of recent advances in high temperature electronics, video cameras and other electronics capable of functioning at oven temperatures
- we now have the technological capability to make 100% sterile probes to send to Mars
- that can sterilize themselves with a small heater to heat up to 300�C for a few minutes or more before their mission starts on Mars
- we can likely soon have 100% sterile Marscopters and perhaps even rovers in the near future, by the 2030s
- we already have fully specified probes able to survive on Venus at 500�C for months
- so we know how to build simple probes already and this is a far lower requirement
- for instance silicon on insulator technology provides fast commercial 0.35 micron resolution electronic chips able to function indefinitely at 300°C
- We can aim for 100% sterile cave bots, moles, aerobots, marscopters, landers and eventually rovers
- an investment for the future that will help with astrobiological exploration throughout the solar system
- and enable us to complete an initial survey in Carl Sagan's "vigorous program of unmanned exobiology" on Mars far faster

For the background here see:
The best way to follow up from this mission to complete Sagan's "vigorous program of unmanned exobiology" is to use dozens or hundreds of 100% sterile landers and rovers on Mars
- and we have the technology now to do it with HOTTech

HOTTECH.endorsements

  1. The astrobiological exploration of Mars is currently severely hampered by the requirement to keep missions sterilized to the same levels as Perseverance to regions of Mars that are ice free and with low likelihood that terrestrial life can get established there
     
    Endorse - Click here when ready to email your endorsements to me
     
  2. It will greatly enhance our ability to do an astrobiological exploration of Mars once we have 100% sterile probes that can be sent anywhere on Mars with no risk of forward contamination
     
    Endorse - Click here when ready to email your endorsements to me
     
    See: The best way to follow up from this mission to complete Sagan's "vigorous program of unmanned exobiology" is to use dozens or hundreds of 100% sterile landers and rovers on Mars
    - and we have the technology now to do it with HOTTech
     
  3. 300�C for a few minutes is enough to sterilize a probe completely as most amino acids vaporize at those temperatures
     
    Endorse - Click here when ready to email your endorsements to me
     
    see: The specification for a Marscopter that can be heat sterilized before it lands on Mars is far simpler than for a Venus probe - components need to function at normal temperatures after brief heating for a few minutes at 300°C and don't even need to function at 300°C never mind 500°C
     
  4. The technology already exists for a 100% sterile probe in the form of the Venus lander probe able to withstand months at 500 C.
     
    Endorse - Click here when ready to email your endorsements to me

    see: The specification for a Marscopter that can be heat sterilized before it lands on Mars is far simpler than for a Venus probe - components need to function at normal temperatures after brief heating for a few minutes at 300°C and don't even need to function at 300°C never mind 500°C
     
  5. Once we can sterilize miniature probes, a single mission could disperse large numbers of cube-sat sized probes over the surface of Mars
     
    Endorse - Click here when ready to email your endorsements to me
     
  6. We can aim for 100% sterile cave bots, moles, aerobots, marscopters, landers and eventually rovers
     
    Endorse - Click here when ready to email your endorsements to me
     
  7. This technology is an investment for the future which could be used throughout the solar system
     
    Endorse - Click here when ready to email your endorsements to me
     
  8. Once the technology is available, it won't add much to per mission costs to specify that all components must be capable of heating for a few minutes or hours to 300 C.
     
    Endorse - Click here when ready to email your endorsements to me
     
  9. It is essential to establish broadband communications with Mars, for instance with optical laser communications, to take full advantage of any assets we send to Mars
     
    Endorse - Click here when ready to email your endorsements to me
     
    10. See: Broadband communications with Mars will make a huge difference
    - it would be like turning NASA's HiRISE satellite which can take photos from orbit with a resolution of less than a meter into 18 satellites with the same capability
    - and our rovers would be like several rovers each
    - we currently operate them in the same way we would operate a rover as far away as Pluto!

    Meanwhile using artificial real time from computer games and fast bandwidth communications from Mars we can explore Mars from our own homes on Earth as if we were there
    - even look at rocks with a hand lens based on a virtual 3D world built up from gigapixel streaming video from Mars
     
  10. All these miniature spacecraft on Mars and the broadband communications to them will be of great interest for humans to use once they are in orbit around Mars
     
    Endorse - Click here when ready to email your endorsements to me
     
    11. See: For astronauts in orbit around Mars it would be not unlike playing a game of "civilization" with many semiautonomous rovers on the surface, driving by themselves with assistance from Earth already

FUTURE. We don't know what we will find on Mars by way of astrobiology
- we need to plan our missions in a way that is flexible enough to accommodate all possibilities
- including futures where it is not possible for human astronauts to ever land on Mars and return
- it is too soon to mae mission plans orientated for particular goals such as to land human astronauts on the surface of Mars
- we first need to understand Mars far better
- whether it has a biosphere and if so
- whether it is safe for the Martian biosphere to mix with Earth's biosphere
- and even if it has no biosphere but has prebiotic chemistry with the very earliest steps towards evolution of life
- it is a decision for our civilization and not just for NASA whether we introduce the anthropocene irreversibly
- to the only other terrestrial planet within light years of Earth

  1. There are potential scenarios for Mars such as mirror life where humans can never safely land on Mars and these scenarios would likely add to rather than diminish public interest in human exploration of space and exploration of Mars from orbit
     
    Endorse - Click here when ready to email your endorsements to me
     
  2. In other scenarios where humans do land on Mars these assets would also be of great value to human astronauts.
     
    Endorse - Click here when ready to email your endorsements to me
     
  3. If Mars has uninhabited habitats for terrestrial life that have interesting prebiotic or abiotic chemistry we need to consider carefully whether to start the anthropocene on Mars
     
    Endorse - Click here when ready to email your endorsements to me
     
    This is a decision not only for us but for all future generations and if we introduce terrestrial life to an uninhabited but habitable planet then we lose the opportunity to study chemical processes, possibly prebiotic processes and even the very first tentative steps at the evolution of life on a terrestrial planet with no other such planet open for us to study within light years.

    So this is a decision for us as a civilization as a whole.

    See: Mars is the only terrestrial analogue of Earth within light years
    - if it has interesting prebiotic or abiotic chemistry
    - such as flipping chiral networks
    - terrestrial contamination would make it impossible to study this in action
    - the order we introduce microbes might also matter for colonization
     
  4. If we do decide we want to start the anthropocene on Mars then the order in which we introduce terrestrial microbes to Mars is likely to have significant effects on the composition of the resulting biosphere and an unfortunate introduction in the wrong order could have effects such as turning subsurface aquifers to cement, or introducing secondary consumers that would remove methane if we want to warm the planet up using methanogens and so on
     
    Endorse - Click here when ready to email your endorsements to me
     
  5. In some scenarios where it's impossible to land humans safely on Mars and return to Earth such as a planet with biology based on mirror organics, or a planet which harbours some immensely precious and vulnerable novel biology, humans in orbit might still be able to grow crops on the surface since seeds can be sterilized and grow in sterile aquaponics
     
    Endorse - Click here when ready to email your endorsements to me
     
    See: If the colonization enthusiasts are right they get a "pass" and have much broader backing because the rest of our civilization knows they are right
    - hardly interrupting their plans- and if they have to stay in orbit
    - they can use those assets to exploit Mars and even set up robotic farms on the surface which would work even on a mirror life planet because seeds can be sterilized unlike humans
  6. Mars is not going to be easy for humans to get to safely and we have much by way of exploration to do on the Moon first - to endorse Chris Hadfield's statement:
     
    Endorse - Click here when ready to email your endorsements to me
     
    The Moon is hard to get to and far more interesting than we realized in the 1960s and 1970s - many adventures there before we go further
    - Chris Hadfield
    - former commander of the ISS thinks ultimately we will be living on the Moon for a generation before we go to Mars
    - "It’s as if you and I were in Paris, paddling around in the Seine in little canoes saying, 'We’ve got boats, we’ve got paddles, let’s go to Australia!' Australia? We can barely cross the English Channel."
    [IN NEPA BOTH]"

    [Do feel free to say if you think he is wrong]
     
  7. We have a choice as a civilization about whether to continue forward in a way that maintains 100% protection of both Earth's biosphere and any Martian biosphere until we are in a position to know more about the consequences of our actions, or to move in the direction of less protection and eventually no protection leading to a merge of any Martian biosphere with ours with consequences we are unable to predict in advance on the basis of the knowledge we have to date.
     
    Endorse - Click here when ready to email your endorsements to me
     
    I believe the general public needs to be aware we have this choice as a civilization
    - and the decision needs to be made on a broader basis than internal technical discussion within NASA
    - to find a way forward that is better for NASA, for the general public, for planetary science, for your reputation
    - and good for space colonization enthusiasts too whatever their views on the need for planetary protection
     
  8. We don't know which of these futures we face:
     
    Endorse - Click here when ready to email your endorsements to me
     
    1. SAFE for humans to explore the surface of Mars in person with no precautions needed in either direction
      (such as no life or mutually benign life on Mars)
       
    2. WITH LIMITED QUARANTINE and other measures for travel between the planets to keep out certain invasive species that would harm Earth’s biosphere, humans, or agriculture.
       
    3. NEVER SAFE for humans to explore Mars in person - or at least, never return to Earth after doing so
      (such as life based on mirror organics on Mars)
       
  9. We need to have open flexible plans for our future for human astronauts and robots that will let us accommodate any scenario for life on Mars and not only plans that depend on us finding familiar life that can be mixed safely with Earth's biosphere or no life or harmless or beneficial life
     
    Endorse - Click here when ready to email your endorsements to me
     
  10. It is too soon to set particular goals such as to land human astronauts on the surface of Mars - we first need to understand Mars far better and find out if it has a biosphere and if it does, whether it is safe for the biospheres of Earth and Mars to mix or whether humans must explore Mars from orbit for our own safety
     
    Endorse - Click here when ready to email your endorsements to me
     

NOT_READY_TO_FINALIZE. This Environmental Impact Statement fails several central requirements under NEPA rules
- lacks scientific integrity for the most important planetary protection sentences
- uses inappropriate tiering, postponing the Sample Receiving Facility to internal discussions at tier 2
- tier 1 considers only local effects on the Utah sands missile range and only effects of release of any particles from the returned capsule
- doesn't consider potential for global effects of a lab leak from the Mars Receiving Facility
- though sample return studies stress the potential of large-scale effects
- and major issues to resolve for the Mars Receiving Facility
- prescreens alternatives to narrow criteria that only their current mission plan satisfied
- as a result only has the "no action" alternative with no mention of several reasonable alternatives submitted by the public
- nobody on their team with the necessary disciplines to prepare a biosafety plan for Earth's biosphere and inhabitants
- this is clear from the numerous mistakes in comments such as
- - not appreciating the difference between 99.97% containment at 0.3 microns (HEPA) and a requirement for 100% containment at all sizes above 0.05 microns (ESF requirement)
- - not responding adequately to questions by one of NASA's own experts on risk assurance
- - never noticing that their most important planetary protection sentence, the meteorite argument, is rebutted on page 5 of its main cite
- this is also confirmed by the way NASA ignored repeated requests from the Space Studies Board to put mechanisms in place to get peer review from experts in relevant disciplines and other agencies
- they don't consider opposing views (e.g. on the Mars meteorite argument where the consensus is that it is invalid)
- - never mind adequately
- they don't mention the consensus view that there is a low risk of large-scale harm to human health and the environment
- - never mind consider all major points of view on environmental effects
- instead they present their own views as a scientific consensus, though only previously found in a non peer reviewed op ed by Robert Zubrin
- you can endorse that this final Environmental Impact Statement is not ready to be finalized on July 8th, 2023
- or you can endorse that this EIS must be withdrawn

Skip to NOT_READY_TO_FINALIZE.endorsements if ready to endorse

NASA is due to finalize this EIS on July 8th. The most important priority right now is to draw NASA's attention to the inadequacy of this EIS under NEPA rules.

If you agree that it is not ready to be finalized, please endorse that this Environmental Impact Statement fails many of the most important requirements under NEPA on an Environmental Impact Statement.

The simplest way to endorse this section is to add your signatures to this page. You need to give a reason to endorse, and can select any of them or all.

I'm no NEPA lawyer, not a lawyer at all but it isn't about subtle issues. These are very very clear violations of many central requirements under NEPA.

You can also endorse any of these particular points about NASA's requirements under NEPA that they haven't complied with in which case I'll add your name to the relevant point (or endorse them all):

NOT_READY_TO_FINALIZE.endorsements

  1. The most important planetary protection sentences in this final PEIS ALL fail the NEPA requirement to maintain scientific integrity

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

      
    Endorse - Click here when ready to email your endorsements to me  

    1. The Mars Meteorite argument is refuted by its own main cite. See:
       
      METEORITES.       Endorse that many terrestrial species couldn't survive ejection into space and months in vacuum and cold
      - so we can't know in advance that ANY species of Martian life already got here in meteorites
      - never mind ALL species in all scenarios
      - and endorse that NASA's meteorite argument is rebutted by its own main cite
    2. The argument that Mars has been uninhabited for millions of years is cited to a source about searching for present day habitats on Mars and is inconsistent with NASA's own plans to test the samples to see if they can get any life to grow from them
       
    3. The argument from 10 example diseases to conclude that Mars has near zero possibility of life that can harm humans misses counterexamples that are easy to find in either the literature on human health (e.g. tetanus) or the planetary protection literature
       
    4. The argument that extremophiles from Mars wouldn't be able to live in less extreme conditions on Earth has a counterexample in its own cite

      For b to d see: PLAUSIBLE_INVALID. Endorse that these arguments are invalid:
      - NASA's argument that Mars has been uninhabitable for millions of years
      - rebut: NASA will test the returned samples for present day life
      - NASA's argument that Martian life would not be able to grow on Earth because of lack of its required nutrients and conditions
      - rebut: their own cite includes a microbe isolated from Canadian permafrost that can grow up to human blood temperature
      - NASA's argument from ten example diseases that human pathogens have to co-evolve with humans giving near zero risk of pathogens from Mars
      - rebut: tetanus and Aspergillus fumigatus are two examples with serious and often fatal effects not adapted to an infectious lifestyle in any organism

       
    These are the four main arguments leading to NASA's conclusions that environmental effects would not be significant and that public health effects would be negligible.

    If any of these four arguments were valid they would be major new findings in planetary protection. But these arguments are not found in the planetary protection literature.

    The Environmental Impact Statement is NOT peer reviewed as NASA's team confirmed in a reply to me. Our public comments are the only peer review it got.
    NEPA does not require a “peer” review prior to release. The purpose of releasing the Draft PEIS is to allow the public, agencies, and other interested parties to review the document and provide substantive comments on the alternatives and/or analyses presented
    (NASA, 2023, MSR FINAL PEIS :B-71)
    �
    I know of only one previous occurrence of these arguments, in a non peer reviewed op ed. by Robert Zubrin (Zubrin, 2000, Contamination From Mars: No Threat) with a vigorous response rebutting them in the next edition of the Planetary Report from planetary protection experts John Rummel, Margaret Race and Kenneth Nealson (Rummel et al., 2000, Opinion: No Threat? No Way : 4 - 7).
     
  2. Inappropriate tiering
    - Tier 1 for this mission, which should cover the effected area for all major effects on the environment
    - only considers local environmental effects of the return of the capsule to the Utah sands
    - all the major peer reviewed studies say the potentially effective area is global
    -, with a low risk of large scale (global) effects on the environment
    - and large scale (global) effects on human health
    - all the large studies give most attention to the major challenge of containment of the samples in a Sample Receiving Facility
    - damage to the capsule before it reaches a lab is highly unlikely and is barely mentioned
    - a Mars Receiving Facility requires new technology never attempted before
    - such as a triple wall facility to keep samples clean and technicians safe even without lab leak issues
    - then in the older studies, private discussions for Apollo, and informed comment after Apollo
    - the most major challenge of all is how to handle lab leaks
    - when there is no known effective quarantine period for unknown diseases,
    - Carl Sagan refers to the "vexing question of latency period" which for Leprosy is over a decade
    - this issue hasn't been resolved, and we also have no way to contain fungi or symptomless spreaders or mirror life with quarantine

    Release of the samples can affect Earth's entire biosphere and all human inhabitants in the low likelihood worst case scenarios. It wasn't appropriate to describe the affected area as only the Utah test range where the samples will hit the ground and leave the rest of the analysis to tier 2 for such matters as lab leaks and quarantine.

    This is especially important since discussion of Apollo quarantine has shown that it was inadequate to contain potential extraterrestrial pathogens e.g. what Carl Sagan called the "vexing question of the latency period" which is over a decade for Leprosy. See discussion of the Apollo quarantine and quarantine generally above in the intro to: QUARANTINE. Endorse need for precautions to respond to lab leaks in any Mars Sample Receiving Facility ...

    § 1502.15 Affected environment.

    The environmental impact statement shall succinctly describe the environment of the area(s) to be affected or created by the alternatives under consideration, including the reasonably foreseeable environmental trends and planned actions in the area(s).


    Endorse - Click here when ready to email your endorsements to me
     
    Reasonably foreseeable environmental trends include global spread of alien biology in the worst case. Later in the section,

    NEPA clarifies that reasonably foreseeable in section 1502 does include low likelihood events with catastrophic consequences, and a low likelihood of harm to the entire biosphere of Earth or to human health globally counts as catastrophic consequences

    (d) For the purposes of this section, “reasonably foreseeable” includes impacts that have catastrophic consequences, even if their probability of occurrence is low, provided that the analysis of the impacts is supported by credible scientific evidence, is not based on pure conjecture, and is within the rule of reason.

    § 1502.21 (c) and (d)


    NASA describes the affected location as "Affected Location: Utah Test and Training Range (UTTR), Utah" rather than "global".

    The Council on Environmental Quality explains that tiering is appropriate when it helps the lead agency to focus on the issues which are ripe for decision and exclude those that re not yet ripe for decision or already decided.
    (b) From an environmental impact statement on a specific action at an early stage (such as need and site selection) to a supplement (which is preferred) or a subsequent statement or analysis at a later stage (such as environmental mitigation). Tiering in such cases is appropriate when it helps the lead agency to focus on the issues which are ripe for decision and exclude from consideration issues already decided or not yet ripe.
    (CEQ, 2007,     A citizen’s guide to the NEPA: Having your voice heard : 49)

    But the question about lab leaks in a Mars Receiving Facility is ripe for decision now, because it affects whether such a facility can be built at all and whether a lab with human technicians can handle the sample or whether it needs telerobotics.

    Also potential effects of release from the Mars Receiving Facility are global, while the Utah sands retrieval handles the samples enclosed in a container that is unlikely to be breached and with a low risk of any Martian particles that gets to the outside of it. So the highest level of risk from potential impacts may well be from lab leaks from the Mars Receiving Facility after the capsule is opened, rather than the Utah sands.

    So it wasn't appropriate to restrict tiering to the Utah test range and exclude from the Environmental Impact Statement all discussion of how to handle the samples later in a Mars Receiving Facility.

    In addition, a Mars Receiving Facility has unique requirements that make it inappropriate to use tiering to restrict the scope to the Utah test range
    1. The European Space Foundation study set a requirement to contain 100% of all particles of 0.05 microns and upwards. A BSL-4 can't achieve this using HEPA filters.

      The technology doesn't yet exist for filters to contain particles at all sizes down to 0.05 microns. We can't defer decision for a Sample Receiving Facility when the technology to build it doesn't exist yet.
      The only Mars Sample Receiving Facility design I've found that cites the ESF recommendation is the EURO-CARES design. This deals with the ESF recommendation by using ULPA filters but due to an unfortunate typo targets a 1 in a million chance of containment at 0.1 microns instead of 0.01 microns and doesn't consider the requirement for 100% containment of all particles of 0.05 microns and greater.

      Also they may not have appreciated that the ESF 1 in a million figure is for the probability of release of a single particle of 0.01 microns and larger during the entire lifetime of the facility, rather than a million-fold reduction of 0.01 micron particles.

      Unlike HEPA filters ULPA filters can achieve more than a million-fold reduction in particles, but but those aren't sufficient for the ESF recommendations either.



      (Hutzler et al., 2017, EURO-CARES Extraterrestrial Sample Curation Facility: Architecture as an enabler of science : 5)

      Their cite 10 is the ESF study which shows 0.01 micron for 1 in a million containment and 100% containment for all sizes from 0.05 microns upwards. Possibly they were confused by the use of a comma instead of a decimal point for the 0,01 instead of 0.01 especially since use of , or . for decimal point isn't consistent through the report.



      NASA didn't concur with my comment saying that a HEPA filter can't fulfill the ESF recommendation to contain all samples from 0.05 microns upwards.

      However this is clearly based on a misunderstanding of either the requirement or how HEPA filters work, as HEPA filters always have a Maximum Penetrating Particle Size, as NASA themselves say. The key word there is penetrating. The MPPS is the size of particle that penetrates the HEPA filter most often. This concept is based on the idea that some particles get through, it's only 99.97% containment and doesn't comply with the ESF 100% standard.

      Also this isn't an appropriate way to respond to a member of the public who raises a serious issue, just to say that they don't concur that it is an issue without mentioning it or analysing it in the EIS.
      For details see:

      HEPA. Endorse that
      - HEPA filters are not certified to achieve 100% containment of particles at all sizes from 0.05 microns upwards
      - as recommended by the European Space Foundation       to contain ultramicrobacteria
      - 100% in this requirement means 100% also at the maximum penetrating size
      - HEPA filters are only certified to achieve 99.97%
      - NASA does need to provide an analysis of their plan to contain them with HEPA filters
      - it is not sufficient to reply to a comment alerting them to this potential issue
      - by just saying they don't concur that it is an issue
      - the technology to achieve this level of containment doesn't seem to exist yet
      - Robert Walker's suggested alternative has potential to protect Earth 100% from organisms of any size since all samples returned to Earth are sterilized

    2. NASA haven't presented protocols for lab leaks for alien life to the public, and this is something has to be decided at tier 1 given the unprecedented nature of the material to be contained. See:

      QUARANTINE. Endorse need for precautions to respond to lab leaks in any Mars Sample Receiving Facility
      - but quarantine of human technicians can't keep out lifelong symptomless carriers like Typhoid Mary
      - or many human diseases like Carl Sagan's example of Leprosy, latency period can be 2 decades
      - or fungal diseases of vulnerable humans, crops or other organisms
      - or life based on mirror chemicals that is pre-adapted to also use normal organics from infall from space
      - and that Robert Walker's scenario of a miniature life detection lab above GEO solves all human quarantine problems
      - at likely lower cost than a fully telerobotic biosafety laboratory without even small risks of escapes
      - due to terrorism, criminal damage, plane crashes, inexperienced operators and other issues
       
    3. The complexity and cost of the Mars Receiving Facility is also important for adequately evaluating the reasonable alternatives. NASA glosses over this point by saying it would be like biosafety labs already built, but previous sample return studies including NASA's own previous tender for designs for a Mars Receiving Facility have made it clear that nothing like this has ever been built before.

      1. One estimate for the timeline to build the facility is 11 years with an extra two years to train technicians (Uhran et al., 2019, Updating Planetary Protection Considerations and Policies for Mars Sample Return)
      2. The 2010 decadal review estimated the cost of the Mars sample receiving facility as $471 million in 2015 dollars (Mattingly , 2010, Mission Concept Study, Planetary Science Decadal Survey, MSR Orbiter Mission (Including Mars Returned Sample Handling)) or $659 million dollars today.
        Others estimate over half a billion dollars in 2015 dollars (The Plan to Bring Mars Down to Earth).
         
      3. The only designs looked at so far are based on the 1999 size limit, essentially a BSL-4 but with the challenge that the samples need to be kept free of terrestrial contamination requiring a clean room inside a BSL-4, a BSL-4 inside a clean room or a novel double wall construction, all of which are new technology (Carrier et al., 2019, Science-Driven Contamination Control Issues Associated with the Receiving and Initial Processing of the MSR Samples : Figure 4).


        The three main designs of sample receiving facility consist of (Uhran et al, 2019):

        The last of those three is the only one that protects both the personnel and the samples optimally and involves a novel triple wall structure.
        the three ways of containing a returned sample.

        This shows how the inner double wall of the triple wall system works: schematic illustration of double wall system to both isolate and contain the sample, Credit NASA / FLAD (Hsu, 2009, Keeping Mars Contained, NASA Astrobiology Magazine)

        As examples of these types of design:

      4. However these designs don't take account of the need to contain the samples for lab leaks and the quarantine issues.

        The only terrestrial design that wouldn't need lab leak provisions at least within the facility is the LAS fully robotic design.


        the LAS fully robotic floor plan for a Mars sample receiving facility.

        Credit NASA / LAS (Hsu, 2009, Keeping Mars Contained, NASA Astrobiology Magazine)

        Nobody has ever built such a facility.

        Discussion of whether any of these designs is suitable and which would be used and how it would contain an alien biology belongs in tier 1.
         

      5. There may be other unique issues identified in a detailed study of the requirements. For example, one possibility is that the samples contain life based on mirror organics. How do you decommission a laboratory that has been used to study an alien biology which might still have mirror life in the building which can never be released under any circumstances for all future time? This is a question that needs to be looked at in tier 1.
         
  3. Fails NEPA requirement to provide rigorous analysis of reasonable alternatives

    Has to evaluate reasonable alternatives and briefly discuss reasons for elimination of any alternatives eliminated from detailed study

    § 1502.14 Alternatives including the proposed action.

    The alternatives section should present the environmental impacts of the proposed action and the alternatives in comparative form based on the information and analysis presented in the sections on the affected environment (§ 1502.15) and the environmental consequences (§ 1502.16). In this section, agencies shall:

    (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 -

    This has to include a summary that identifies all the alternatives submitted by public commenters.

    The final environmental impact statement shall include a summary that identifies all alternatives, information, and analyses submitted by State, Tribal, and local governments and other public commenters for consideration by the lead and cooperating agencies in developing the final environmental impact statement.
    § 1502.17


     
    Endorse - Click here when ready to email your endorsements to me
     

    The relevant section in the EIS is 2.3.1.1 Programmatic Alternatives (NASA, 2023, Mars Sample Return FINAL PEIS : 2-25)

    NASA don't consider these three reasonable alternatives submitted by the public.

    1. Sterilize all sample returned to Earth
       
    2. Search for life in situ and defer return of the samples until we can do risk assurance better
       
    3. Return samples to a miniature life detection lab above GEO

    When asked by the public why these alternatives aren't mentioned, NASA refer us to section:"2.3.1 Programmatic Alternative Screening Criteria".

    There we discover that NASA pre-screened them and removed them without mentioning them.
     
  4. NASA Improperly prescreens to remove any alternative unless it fits narrow criteria that can only be satisfied by their current mission plan
    - this goes against core requirements of NEPA as clarified by the Council on Environmental Quality and various court cases

    NASA's prescreening is not permitted under NEPA because they set narrow criteria based on their own mission plan.

    This prevented them from considering reasonable alternatives that differed from their plan in substantial ways such as by sterilizing all samples returned to Earth or by looking for signs of life in orbit or on Mars.

    The Council on Environmental Quality says an agency has to consider alternatives that don't fully meet all its goals.

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

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

    �
    Endorse - Click here when ready to email your endorsements to me
     
    All three of these reasonable alternatives fit that description in one way or another.

    .

    1. Sterilize all sample returned to Earth
      - doesn't meet all the listed goals but better protects Earth's inhabitants and the biosphere so better meets policies and requirements of NEPA
       
    2. Search for life in situ and defer return of the samples until we can do risk assurance better
      - achieves the astrobiology goals in a different way and astrobiologists have said in many papers that their goals are better served by in situ searches than samples returned from Mars. So it likely achieves MORE science return for astrobiology than the mission plan.
       
    3. Return samples to a miniature life detection lab above GEO
      1. The miniature lab above GEO also provides MORE science return though in a different way from the way envisioned in NASA's mission plan by adding those bonus samples in clean containers
         
      2. It retains virtually all the geology since the sample tubes are just sterilized and returned to Earth unopened and all, or almost all have already received - much more than a sterilizing dose of ionizing radiation on Mars
        the main geological alterations of rock samples such as colour changes of halite crystals from clear to blue and quartz crystals from clear to brown and changes in thermoluminescent properties happen after 0.3 Mrad, only 3 million years of ionizing radiation (Allen et al., 1999. Biological sterilization of returned Mars samples)
      3. Perseverance has no way to measure exposure ages and so is unlikely to return samples with a young enough exposure age to be affected noticeably
        - the youngest exposure age measured by Curiosity is 80 million years (Pavlov et al., 2022 . Rapid Radiolytic Degradation of Amino Acids in the Martian Shallow Subsurface: Implications for the Search for Extinct Life : 1100 – 1101)
      �

    As the CEQ says, The rule of reason continues to guide decision making in such contexts.

    A properly drafted purpose and need statement should lead to consideration of the reasonable alternatives to the proposed action, consistent with NEPA's requirements. See 42 U.S.C. 4332(2)(C), 4332(2)(E). CEQ disagrees with commenters assertions that consideration of alternatives that do not meet an applicant's goals or cannot be implemented by the applicant will always waste applicant or agency resources or result in delays. There may be times when an agency identifies a reasonable range of alternatives that includes alternatives—other than the no action alternative—that are beyond the goals of the applicant or outside the agency's jurisdiction because the agency concludes that they are useful for the agency decision maker and the public to make an informed decision.

    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)

    The revision clarifies that agencies have discretion to consider a variety of factors when assessing an application for an authorization, removing the requirement that an agency base the purpose and need on the goals of an applicant and the agency's statutory authority

    However they can't restrict the purpose to exclude "truly" reasonable alternatives. They can't use this to make the EIS incompatible with NEPA requirements.

    It is contrary to NEPA for agencies to “contrive a purpose so slender as to define competing `reasonable alternatives' out of consideration (and even out of existence).” Simmons v. U.S. Army Corps of Engineers, 120 F.3d 664, 666 (7th Cir. 1997) (citing 42 U.S.C. 4332(2)(E)).

    Constricting the definition of the project's purpose could exclude “truly” reasonable alternatives, making an EIS incompatible with NEPA's requirements. Id. See also, e.g., Nat'l Parks & Conservation Ass'n v. Bureau of Land Mgmt., 606 F.3d 1058, 1070 (9th Cir. 2010) (“Agencies enjoy `considerable discretion' to define the purpose and need of a project. However, `an agency cannot define its objectives in unreasonably narrow terms.'” (internal citations omitted)).'
    (CEQ, 2022, National Environmental Policy Act Implementing Regulations Revisions - a rule by the CEQ on 4/20/2022)

    The CEQ also clarified that the requirement to consider reasonable alternatives persists even after its narrowing of scope in its 2021 revision of NEPA (CEQ, 2020, National Environmental Policy Act Implementing Regulations Revisions – Supplementary information).

  5. NASA required all alternatives to be able to prove that it is safe to release samples from the labs unsterilized
    - even though this makes no sense for any of those three alternatives as they keep Earth safe by NOT returning unsterilized samples
    - and even though NASA's own mission plan won't be able to prove that it is safe to release the samples unsterilized either
    - so they can't satisfy their own prescreening criterion strictly interpreted
    - this improperly excludes all three alternatives proposed by the general public  

    Endorse - Click here when ready to email your endorsements to me
      

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

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

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

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

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

    This improperly removes from consideration all three of those reasonable alternatives

    No safety testing is needed for samples returned sterilized or unsterilized samples studied on Mars or unsterilized samples studied above GEO.

    In addition we see from that passage that their prescreening requirement is that the alternatives must "definitively determine if the samples collected are of sufficiently low risk so as to alter the "Restricted Earth Return" mission planetary protection designation"

    It turns out that NASA's own mission plan is guaranteed to fail that prescreening requirement, so, strictly interpreted, they should eliminate their current plan from consideration too by that same prescreening criterion.

    The reason is that NASA's biosafety testing is guaranteed to fail     with all samples going to hold and critical review indefinitely because of
    1. the high levels of terrestrial contamination,
    2. the impossibility of an adequate inventory of terrestrial life
    3. and the potential for ultra low levels of present day life, even just a few viable microbes in the entire collection,
    as described above in: SAFETY. It will be impossible to do safety testing with the Perseverance samples ...

    So NASA's Needs and purpose section not only improperly rules out all three alternatives by requiring them to be able to prove that it is safe to return the samples to Earth unsterilized

    It also sets a requirement for the alternatives to fulfill that NASA's own mission plan can't fulfill either as there is no way that NASA will be able to prove that it is safe to release the samples unsterilized with even very weak levels of assurance.
     
  6. NASA also prescreens the alternatives with a requirement to be able to to test unsterilized samples for present day and past life in a terrestrial laboratory
    - NASA relies on an out of date cite from 2008 which doesn't adequately describe the capabilities of modern in situ instruments
    - NASA rejected my own attachment 8 as "nonsubstantive" which has a long list of modern in situ instruments for my proposed alternative for a miniature life detection lab above GEO
    - this also improperly excludes all three alternatives proposed by the general public in a different way
     
    Endorse - Click here when ready to email your endorsements to me
     
    "Given the needs above, Mars sample processing and analysis cannot be sufficiently conducted in situ ..."
    (NASA, 2023, Mars Sample Return FINAL PEIS : 2-25)

    NASA's summary of the capabilities of in situ instruments is based on a limited literature search that only turned up information 14 years out of date, and ignoring a comment from the public that provided them with the up to date information.

    I gave a long list of these instruments in my attachment 8 of the final comment but NASA dismissed this attachment as "nonsubstantive" and so didn't consider that list.

    I've already covered this in detail with cites, so see the end of: IN_SITU_INSTRUMENTS ... - a long list of miniaturized life detection instruments suitable for use in situ on Mars (above).
     
  7. NASA hasn't involved the public early on or developed tools to communicate risk with the public
    - this is a central requirement in all the main Mars Sample Return studies
    - goes against the NEPA Requirement to use an interdisciplinary approach integrating the natural and the social sciences    .
    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 (section 102(2)(A) of NEPA).
    § 1507.2
    �
    Endorse - Click here when ready to email your endorsements to me
     

    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. This relates to the rule for integrated use of social sciences

    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).

    This wasn't done.

    The public weren’t involved early on in that way.

    No    r is there any suggestion in the EIS to set up such fora or methods of communication with the public.

    I drew NASA's attention to this in a public comment. They didn't understand the request

    See:

    This low risk of large-scale harm must be acknowledged and addressed both for scientific credibility, under NEPA requirements, and for credibility and building trust with the public
    - the general public can see there is a risk of large-scale harm from returning unknown life from another planet that needs to be considered in an EIS
    - the peer reviewed large scale studies also back this up and show your four main arguments are invalid as we saw
    - the public need to know you also can see large scale harm as a possibility or there is no way they can be expected to trust NASA on this topic

    Mars Sample Return Studies emphasize the need to involve the public early on
    - this corresponds to what the NEPA requirements call the integrated use of the natural and social sciences and the environmental design arts
    - and this should be integrated with your team so that you are prepared and able to respond appropriately to public questions     .
  8. NASA didn't ensure that the disciplines of the preparers were appropriate to the scope of the Environmental Impact Statement
    - NASA did the opposite, closed down the planetary protection office, closed down the interagency panel, and it's clear there is nobody there familiar with the basics of risk assurance from the responses to comments by one of their own experts on risk assurance Chester Everline.
    - it is clear throughout the report that the public were talking to people with no familiarity with the planetary protection literature
    - they didn't even have enough familiarity with the literature to know that BOTH their National of Academy cites rebutted the Mars meteorite argument
     
    Endorse - Click here when ready to email your endorsements to me
     
    The disciplines of the preparers shall be appropriate to the scope and issues identified in the scoping process

    § 1507.2
    Either the scoping process wasn't adequate to identify the required disciplines or the preparers didn't match the requirements. What is clear from the report itself is that this is a team without the most basic knowledge of the planetary protection literature. Mistakes like this would be impossible if they had a basic familiarity:

    See: First clear example of the lack of anyone from the discipline of planetary protection (at least as normally understood)
    - your most important planetary protection sentence, presenting the Mars meteorite argument,
    - was proved invalid long ago, for instance in the National Academy of Sciences 2009 study
    - and your 2019 National Academy of Sciences cite also says this argument does NOT apply to samples from Mars

    Many of the errors I found show you haven’t followed an interdisciplinary approach. Your decision to close down the interagency panel Review and Assessment of Planetary Protection Policy Development Processes : page 26) and your planetary protection office (With planetary protection office up for grabs, …), against the recommendation of the Space Studies Board (Review and Assessment of Planetary Protection … : 61 - 62) surely contributed to this lack of a sufficiently broad interdisciplinary approach.

    We see this throughout the responses to the public comments.

    See: Dear NASA, your final PEIS for samples returned from Mars and replies to public comments show
    - for all your excellence on space science
    - your team is unfamiliar with essential planetary protection concepts
    - for example, your Mars meteorite argument is central to this EIS
    - but your own National Academy of Sciences cite for this argument rebuts it!
    - one of numerous basic mistakes in the EIS itself and responses to public comments
    - this needs to be tackled at a higher level than your Mars Sample Return team
    - you are correct to tell me NEPA doesn't require peer review
    - but NEPA does require scientific integrity and expertise in the relevant disciplines, in this case planetary protection
    - my suggested alternative is one solution that plays to your strengths as an organization
    - a miniature life detection lab above GEO based on NASA's Europa lander proposal, with all samples returned to Earth sterilized
  9. The final PEIS doesn't identify responsible opposing views such as that the meteorite argument is invalid or that the other three main arguments used in the EIS are invalid even though alerted to this in public comments and even though the consensus in the peer reviewed literature is that all these arguments are invalid and NASA's own cites for the meteorite argument rebut it.
     
    Endorse - Click here when ready to email your endorsements to me
     
    At appropriate points in the draft statement, the agency shall discuss all major points of view on the environmental impacts of the alternatives including the proposed action.

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

    § 1502.9

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

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

    Both the sources from the National Academy of Sciences used by NASA to support this argument actually rebut it.

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

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

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

    See: METEORITES. Endorse that many terrestrial species couldn't survive ejection into space and months in vacuum and cold
    - so we can't know in advance that ANY species of Martian life already got here in meteorites
    - never mind ALL species in all scenarios
    - and endorse that NASA's meteorite argument is rebutted by its own main cite
     
    and PLAUSIBLE_INVALID. Endorse that these arguments are invalid:
    - NASA's argument that Mars has been uninhabitable for millions of years
    - rebut: NASA will test the returned samples for present day life
    - NASA's argument that Martian life would not be able to grow on Earth because of lack of its required nutrients and condition
    - rebut: their own cite includes a microbe isolated from Canadian permafrost that can grow up to human blood temperature
    - NASA's argument from ten example diseases that human pathogens have to co-evolve with humans giving near zero risk of pathogens from Mars
    - rebut: tetanus and Aspergillus fumigatus are two examples with serious and often fatal effects not adapted to an infectious lifestyle in any organism
     

  10. The EIS doesn't discuss any major point of view in the literature on large-scale effects but instead
    - only presents NASA's own non peer reviewed view that the Mars meteorite argument and the other arguments are invalid and
    - that any environmental effects would not be significant
    - and presents its own non peer reviewed views on these matters as a scientific consensus
    - Neither the draft nor the final PEIS mentions the consensus view in the peer reviewed literature that the likely low risk worst case scenario is large-scale harm to human health and the environment
    - and that the samples should be contained as if they were the most hazardous Earth organisms known, risk group 4
    -     high individual and community risk
    - and "hardly manageable or predictable" (ESF)
     
    Endorse - Click here when ready to email your endorsements to me
     

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

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

    § 1502.9

    The ESF Mars Sample Return Study puts it like this in 2012:


    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)

    To put this in perspective - we wouldn't know the species, genus even the domain of life and it might also be a new form of biology never identified before and we are not yet sure how it reproduces or how it retains genetic information. We have never had to respond to a pathogen like that in all of human history so it would be unprecedented with no relevant previous experience to draw on. Testing for the pathogen and diagnosis would likely be especially challenging.

    This is where my two concrete scenarios of mirror life and a novel fungal genus as well as various alien life scenarios of pathogens not familiar with terrestrial biology may help space agencies drawing up Environmental Impact Statements like this to get a better perspective on how little we know.

    Those few words by the ESF "unknown mechanisms" refer to a breadth of possibilities that may not occur to framers of an EIS like this one.
    See: SCENARIOS. Endorse scenarios of life based on mirror organics from Mars
    - and a novel fungal genus no terrestrial organism has ever encountered similar to Aspergillus
    - as scenarios for a small risk of unprecedented harm to the environment or human health,
    - similar to the house fire scenarios that give us a reason to fireproof houses and install smoke detectors

    This view that there is a low risk of large-scale harm to humans and the environment is more than a major point of view. It is affirmed in all the large peer reviewed studies such as the NRC Mars sample return study in 2009 (Assessment of planetary protection requirements for Mars sample return missions : 48), the ESF Mars sample return study in 2012 (Mars Sample Return backward contamination–Strategic advice and requirements : 28) and indeed the entire body of the previous planetary protection literature to date including the views of Carl Sagan (Sagan, 1973, The Cosmic Connection – an Extraterrestrial Perspective :) and Joshua Lederberg (Parasites face a perpetual dilemma), American pioneers in planetary protection from the late 1950s onwards.

    This is a consensus indeed in all the Mars sample return reports. This is far more than a major point of view. It is NASA's view in this EIS is the outlier, never expressed before in any of these reports. NASA's EIS is not required to be peer reviewed and they confirmed in a comment reply that it's not peer reviewed (they would have surely replied saying it was if it was when challenged on the topic) (NASA, 2023, MSR FINAL PEIS :B-71). See:

    Yes you are correct to tell me NEPA doesn't require peer review for an EIS
    - but it does require scientific credibility
    - NEPA also requires you have members on your team in the appropriate disciplines
    - one way to achieve this is with peer review
    - as well as dialog with experts on public health and other topics outside the usual province of NASA's expertise

    When I challenged them for a source for their statement that the environmental effects from a Mars sample return would not be significant, they said their own EIS is the source (NASA, 2023, MSR FINAL PEIS :B-68). This means it is based on the Mars meteorite argument and those three other invalid arguments.

    Then they explain in that comment reply that they got to the final judgement that the environmental effects would not be significant as a deduction from a low likelihood of significant environmental effects.

    That is not a valid inference as you can see by substituting "house fire" for "significant environmental effects". A low likelihood of a house fire can't be used to infer a judgement that a house fire would not be significant.

    These are clearly authors not used to reasoning about such topics. It isn't their fault. It's just that NASA has removed everyone from their team in the necessary disciplines to consider such issues.

    See: You do have to consider worst-case scenarios for Earth's biosphere that are scientifically credible
    - a low likelihood of large-scale effects does NOT support the judgement that potential environmental effects would not be significant
    - the analogy of a house fire may help you to understand this distinction
      
  11. NEPA requires agencies to consider "impacts that have catastrophic consequences"
    - even if low probability
    - provided analysis is supported by credible scientific evidence
    - not based on pure conjecture, and within rule of reason
    - NASA didn't consider low risk catastrophic consequences covered in peer reviewed literature
    -     and don't mention possibility of large scale harm to health or the environment or risk group 4 organisms
    - as a result also don't consider many executive orders and federal laws they should consider for large-scale harm
     
    Endorse - Click here when ready to email your endorsements to me
     

    (c) If the information relevant to reasonably foreseeable significant adverse impacts cannot be obtained because the overall costs of obtaining it are unreasonable or the means to obtain it are not known, the agency shall include within the environmental impact statement:

    (1) A statement that such information is incomplete or unavailable;

    (2) A statement of the relevance of the incomplete or unavailable information to evaluating reasonably foreseeable significant adverse impacts on the human environment;

    (3) A summary of existing credible scientific evidence that is relevant to evaluating the reasonably foreseeable significant adverse impacts on the human environment; and

    (4) The agency's evaluation of such impacts based upon theoretical approaches or research methods generally accepted in the scientific community.

    (d) For the purposes of this section, “reasonably foreseeable” includes impacts that have catastrophic consequences, even if their probability of occurrence is low, provided that the analysis of the impacts is supported by credible scientific evidence, is not based on pure conjecture, and is within the rule of reason.

    § 1502.21 (c) and (d)

     
    NASA's team responded to my comment alerting them to the discrepancy between their statement and the statements by the ESF and the National Research Council in a reply that doesn't recognize the difference between a low risk of large scale effects and a low risk of small scale effects

    The sentence cited in this comment (“The relatively low probability of an inadvertent reentry combined with the assessment that samples are unlikely to pose a risk of significant ecological impact or other significant harmful effects support the judgement that the potential environmental impacts would not be significant.”) is a NASA conclusion based on the analyses presented in the PEIS—the reference is the PEIS itself. Based on the credible scientific evidence cited in the PEIS (samples are unlikely to pose a risk of significant ecological impact), it is reasonable to conclude that there would be no significant impacts from the Proposed Action. The term “unlikely” accounts for the fact that the risk is not zero.
    (NASA, 2023, MSR FINAL PEIS :B-68)
    This also makes it clear NASA are using their own Environmental Impact statement as the source for their conclusion that potential environmental impacts would not be significant - which as we see relies on those four invalid arguments with the most important one, the Mars meteorite argument, rebutted by their own sources.

    Everyone agrees the risks are likely low.
    What NASA's team failed to mention in the EIS is that it is about a low risk of large-scale effects

    This distinction between a low risk of small scale effects and a low risk of large-scale effects has many implications for an EIS.

    For instance if they had said in the EIS that there is a low risk of large-scale effects this means they need to consider effects on the Great Lakes, on agriculture, on fisheries, on public health globally, and many other topics that are not considered in this EIS. They are required to consider them by various presidential executive orders.

    This is from NASA's guidelines for new facilities, which a new Sample Receiving Lab would certainly be.

    Here are some relevant executive orders and federal laws NASA must consider in this EIS once they say in it that there is a potential for large-scale effects on the environment and on human health (NASA, 2012, NASA Facilities Design Guide) .

        EXECUTIVE ORDERS
    1. 13112 Invasive Species Federal agencies are to prevent the introduction of invasive species, to provide for their control, and to minimize the economic, ecological, and human health impacts that invasive species cause
       
    2. 13158 Marine Protected Areas Federal agency actions are to avoid harm to the natural and cultural resources that have been designated a Marine Protected Area (MPA).
       
    3. 13186 Responsibilities of Federal Agencies to Protect Migratory Birds In their land management and environmental quality planning, Agencies are to avoid/minimize adverse impacts on and to prevent/abate pollution or detrimental alteration of the environment of migratory bird resources.
      [migratory birds could be affected by environmental changes from introduction of mirror life, or by novel diseases such as a novel fungal genus]
       
    4. 13547 Stewardship of the Ocean, Our Coasts, and the Great Lakes Federal Agencies are to exercise stewardship of oceans, coasts, and the Great Lakes by protecting, maintaining, and restoring their health and biological diversity.
       
    5. Endangered Species Act Through federal action and by encouraging the establishment of state programs, the 1973 Endangered Species Act provided for the conservation of ecosystems upon which threatened and endangered species of fish, wildlife, and plants depend
      [effects of introduced microbes from Mars on ecosystems would not be possible to predict]
       
    6. 13486 Strengthening Laboratory Biosecurity in the United States Facilities that possess biological select agents and toxins are to have appropriate security and personnel assurance practices to protect against theft, misuse, or diversion to unlawful activity of such agents and toxins.

      FEDERAL LAW
    7. Migratory Bird Treaty Act Act for the protection of migratory birds.
       
    8. Safe Drinking Water Act This Act regulates drinking water systems
      [microbial life from Mars could potentially have effects on drinking water]
    This list is not likely to be complete. The authors of that list wouldn't consider the executive orders relevant to, say, effects of releasing life based on mirror organics on the environment.

    Also classifying the Mars samples as risk group 4 and with potential for large-scale effects has impact on their partner ESA, and their obligations under the Espoo convention, Biosafety Convention and EU directive

    See: Based on what the European Space Foundation Sample Return study of 2012 says about a low risk of large-scale effects
    - this mission also has international implications for ESA member countries, and the EU and also internationally
    - including obligations under EU Directive 2001/42/EC, the Espoo convention and the Biodiversity Convention

    NASA intends to use a tiering system with the Mars Receiving Facility deferred to tier 2.

    However large-scale effects by definition are not localized to particular facilities and would have to be considered at tier 1 and not deferred to a later tier:

Email endorsements to me

You can send an email to Robert Walker, robert@robertinventor.com with the statements you want to endorse
(if you've checked them, just copy / paste from the list below)

Show all the statements whether endorsed or not

So far you have chosen to endorse:

[nothing selected yet]

Or you can fill in this form which most browsers will make into an email ready for you to send using mailto. It will just bring up a new email with a list of all the statements you've endorsed and the other details.

I use the primitive mailto approach so you see what you are going to send instead of sending the email for you on the server side.

It also gives an idea of what you need to say in your email.

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

Personal message:
 

 
Email:
 
You can also add your signature to the page calling on NASA to defer or withdraw the EIS

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
No call to NASA
 

It's a great help if you can also add a video endorsement, just briefly saying who you are, your expertise, what you endorse etc (then can expand on it after if you wish to). See next section:

If you select the Call to NASA radio buttons to defer or withdraw, I'll add you name to this letter too.

Do say in your email if you wish to add a personalized message for your call to defer or withdraw (unless you have already filled in the form on that page).

Personal endorsements
- do share a video or a text to accompany your endorsements if you wish to
- this will be a great help

The simplest way to endorse is to just give me a list of the statements you are willing to add your name to and your relevant field of expertise. See:

It is a great help if you can add a personal message to NASA or best of all a video. I'll add any endorsements like that to this page (or in a separate page if the list is very long)

Personal endorsements can help show NASA and others who see the open letter and this endorsements page that these are scientists making personal endorsements about matters they have given thought and attention to. It is also an opportunity to expand on what you say.

The endorsement can be as short or as long as you like. Very short endorsements are also welcome, a minute or less just saying in your own words what you endorse

In any video I think it will help to make it clear at the start (in any order)

  • that it is an endorsement for Robert Walker's open letter for NASA's Environmental Impact Statement.
     
  • what it is that you are endorsing
     
  • Give your name, affiliation (or former affiliation e.g. if retired) and area(s) of expertise

As for the content remember you are talking to people who though they may be brilliant scientists or engineers are not familiar with the basics of planetary protection, or biosafety, and who may have come to a conclusion long ago that nothing there can harm us or our biosphere in any way.

  • State what your assessment is as an expert, clearly and simply
     
  • There is no need to try to convince skeptics
     
  • E.g. if you are saying the Mars meteorite argument is invalid (at our current stage of understanding of Mars)
    - there is no need to try to win over firm believers in the Mars meteorite argument
  • Just share your expertise and that's the most we can do
     
  • it's a great help.

I find what Dr Mike Ryan said in a video a couple of years ago very helpful in working out how to handle this situation: For any who don't know, he is the executive director of the World Health Organization's Health Emergencies Programme.

This is an extract from a WHO live social media Q/A where Mike Ryan gave useful tips on how to handle this situation most of us meet every day where you can easily get caught up in what he calls a “slugfest” of firing facts at each other.

Dr Mike Ryan says there is a better way of doing it involving listening to concerns, helping them to access good information, and gentle persuasion, gradually flooding the space with good information. Maybe you “win” fewer arguments this way - but does that really matter?

See also Short list of main points to endorse

Graphics summarizing my positive vision for 100% planetary protection both ways - leading to an inspiring future for human space exploration no matter what we find on Mars even if it is a mirror life planet indeed more likely to get public enthusiasm to explore a mirror life planet from orbit

Here is a new version of that abstract

Text on graphic: Mars may be like Earth's driest deserts, with small niches for life adapted to extreme environments, perhaps only habitable at microbial scales.

Sample Cache Rover (Perseverance) - ESA Fetch rover - Mars ascent vehicle - samples have too much terrestrial contamination for astrobiology.

ESA sends small sterile containers on its lander to return salts, dirt, atmosphere, dust from its surroundings.

If possible, the ESA lander also sends a Mars copter to travel to a nearby young crater to return a small pebble with young exposure age

No risk to Earth's biosphere. - Above GEO.

Scientist say we can do in situ life detection as far away as Jupiter's moon Europa - Europa lander life detection lab

All returned samples are sterilized - humans go nowhere near the satellite

Sample retrieval lander mission (launch 2028) Earth Return Orbiter mission (launch 2028) samples returned 2033
Graphic obtained by modifying the ESA graphic, (Oldenburg , 2019, , Mars Sample Return overview infographic )

It's based on

Europa Lander life detection lab

NASA;s idea for Jupiter's moon Europa

Europa lander: total mass 42.5 kg

My suggestion: return samples to a miniature lab like this (adds centrifuge for artificial gravity)

But above GEO

Keeps Earth 100% safe from Mars microbes

Graphic from (NASA, 2017, Europa Lander Study 2016 Report)

And the satellite itself with the centrifuge:

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. Illustration shows:

  • Chiral labeled 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 (Mojarro et al., 2016, SETG: nucleic acid extraction and sequencing for in situ life detection on Mars). Astrobionibbler from (Elleman, 2014, Path to Discovery) ISS centrifugal motor for plant experiments, dialable to any level from microgravity to 2g (Centrifuge Rotor [biology experiment on the ISS])

It would use a very safe orbit in the inclined Laplace plane above GEO.

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 (Rummel et al., 2000, Opinion: No Threat? No Way : 5)

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

(Smoke detector graphic from The EnergySmart Academy)

I myself am very keen on human exploration in space and eventually likely settlement (though I think it's likely harder and may take longer than many space colonization enthusiasts expect)

But like Carl Sagan I also value Earth's biosphere and inhabitants hugely, value essentially infinite.

Text on graphic: Carl Sagan (pioneer in planetary protection - first paper in 1960)
[his first paper is (Biological contamination of the Moon)]

“I, myself, would love to be involved in the first manned expedition to Mars. But an exhaustive program of unmanned biological exploration of Mars is necessary first.

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

[quote from: (Sagan, 1973, The Cosmic Connection – an Extraterrestrial Perspective)]
[I provide text captions for the graphics in this open latter for visually impaired readers]

It is clear that this is a widespread view amongst the public too from the public comments on the endorsements.

It may well be a majority view though this is not a poll it is certainly the top concern of commentators. Also most people, farmers, fishermen, doctors, nurses, i asked to balance a small risk of large scale harm to human health or the environment that in worst case, could be unprecedented with a possibility that by dropping all planetary protection we might send humans to Mars a few years earlier - they would likely have no hesitation in which they choose.

This is just not a sustainable path.

Also the mission has suffered scientifically from the lack of expertise on planetary protection as the samples have too much terrestrial contamination for meaningful astrobiology (virtually certain)

This is based on rather out of date findings from 2014 which relied on earlier research.

See in the open letter::

and:

.

Text on graphic: What we need to prevent in 2033 - NASA’s mission plans - NASA’s future science credibility - Public and scientific opinion - No scientifically credible plans to protect Earth - Samples likely valueless for astrobiology because of permitted contamination by Earth life

(Stöwer Titanic)

(NASA logo )

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

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

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

Endorsements as a way to get attention of rocket scientists and administrators to recognize a possibility that NASA needs other areas of expertise that they don't have themselves - the issue is systemic as it can be traced all the way back to the Apollo missions

We read in the final PEIS that, NASA's Mars Sample Return team are confident any environmental effects would not be significant and any effects from lab leaks would be negligible,

Many enthusiasts for humans to Mars believe that scientists have already established that any life on Mars that could get to Earth in their sample tubes has already got to Earth in a Mars meteorite. NASA's final PEIS says the same thing, that there is a scientific consensus in support of this argument. But for those familiar with the planetary protection literature you just need to read NASA's own cite to see that it rebuts the sentence they attached it to. If you can endorse that this argument is invalid, it's one of the most important sections to endorse:

NASA's stated aim is to pave the way to humans to Mars and they want other agencies to follow their lead here.

This isn’t the Planetary Protection of the past — we are doing things differently. ... There’s still a lot of work to go as we start to pave the way to humans on Mars ... we need that collective agency support to do that.

( SMA Leadership Profile: Nick Benardini)

NASA excel at engineering, and rocket science. But they have not been set up to establish expertise in public health, diseases of humans and animals, impacts on wildlife and the environment and so on. They did have an interagency panel and a somewhat independent planetary protection office which gave them the expertise they need for an EIS like this, but they closed them down. This is against repeated recommendations by the Space Studies Board to reverse these decisions.

The end result of all this is that the NEPA public comments get assessed by engineers and mission planners at NASA who are confident that the Mars meteorite argument is a scientific consensus and are confident that their plans to protect Earth's biosphere and human health do not need any input from experts on human health, from experts on agriculture, or environment, or their former planetary protection experts

Experts on human health can help greatly by endorsing statements in this section and the following section:

NASA are required under NEPA to consider any major issues raised in a timely fashion during the comments period as mine were, and to look at major points of view on environmental effects, and to consider reasonable alternatives also submitted in a timely fashion as mine were. For my summary of their requirements under NEPA relevant to this EIS and my public comments as best I understand them, see this separate page::

With this background, NASA can't be expected to read my detailed reasoning and careful use of cites in the planetary protection literature. There is nothing new here. This was the view of Vishniac of the National Academy of Sciences on the plans to open the Apollo 11 capsule door and exit into a dinghy in the open sea:

Opening and venting the spacecraft to Earth’s atmosphere after splashdown would, in his view, make the rest of Apollo’s elaborate quarantine program pointless.

(Meltzer, 2012, When Biospheres Collide : 452).

Something very similar is happing in NASA today. When you look closely at their decisions to close down the interagency panel and the planetary protection subcommittee it's clear they had already stopped functioning before they were closed down as nobody was listening to them.

The main difference from Apollo is that NASA now have a legal obligation to listen they didn't have with Apollo. Also there is far more public awareness of the need to take care with actions with potential for large-scale effects on human health or the environment.

So it's a tricky situation. I eventually went with the idea of an open letter, and endorsements as part of a larger strategy to appeal to their interests in humans in space (which I also share).

Our first experiments in space settlement will surely be on the Moon
- a Medvac of over a year for a spacecraft leaving Earth for Mars is a far larger step up from a Medvac of several days than the step up from a Medvac of hours to days when we return to the Moon
- we have plenty of time to be well on the way to completing a first rapid biological survey of much of the surface of Mars by the time humans get to Mars orbit to complete it
- to do this we need to prioritize development of 100% sterile landers that we can send safely to anywhere on Mars
- the technology already exists for our first probes and much of the rest can be developed soon

The retired Canadian astronaut Chris Hadfield, former commander of the ISS, interviewed by New Scientist, put it like this:

"I think ultimately we’ll be living on the moon for a generation before we get to Mars. If the world and the moon were threatened and the only way to preserve our species was to launch from Earth, we could go to Mars with yesterday’s technology, but we would probably kill just about everybody on the way."

(Klein, 2017, (Chris Hadfield: We should live on the moon before a trip to Mars)

It’s as if you and I were in Paris, paddling around in the Seine in little canoes saying, “We’ve got boats, we’ve got paddles, let’s go to Australia!” Australia? We can barely cross the English Channel.

Frame from 28 seconds into this ESA video: Moon Village

See:

We can speed up exploration of Mars with 100% sterile landers - this is the main thing that is holding us back.

Text on graphic: 100% planetary protection both ways, even if Mars has vulnerable early life, prebiotic chemistry, or mirror life.
Using NASA’s remarkable Venus HOTTECH technology, all these surface assets can be built to withstand months at 500°C, and so are easily sterilized with a few minutes of heating on the journey out.

Main image: “Safely tucked inside orbiting habitat, space explorers use telepresence to operate machinery on Mars, even lobbing a sample of the Red Planet to the outpost for detailed study." (Telerobotics Could Help Humanity Explore Space)

Tele-operated Centaur as an insert from: Carter Emmart / NASA Ames research center , Almost Being There: Why the Future of Space Exploration Is Not What You Think,

This is far better for humans in space too. The alternative some astrobiologists suggest is to remove the sterilization requirement altogether. This would rapidly introduce the anthropocene on Mars anywhere where there are habitats - which will make it far harder, not easier, to spot any threats to Earth's biosphere that might be there such as mirror life, say. which might be present in small numbers and our tools would spot terrestrial contamination much more easily than exotic biology - and it introduces the anthropocene to Mars not just for us but for all future generations for millions of years. We need to consider carefully whether we do this based on knowing what is there.

Once we get humans to Mars orbit - maybe not until late 2030s or 2040s we have the spectacular HERRO orbit for them to use. The ISS orbiting Earth is very inspiring, this would be too. It comes in close by both poles twice a day and it gets closest to Mars over the equatorial regions, the sunny side of Mars on opposite sides twice a day.

Video: One Orbit Flyby, Time 100x: Mars Molniya Orbit Telerobotic Exploration in HERRO Mission

Early astronaut explorers would likely use two spacecraft joined via tethers for artificial gravity to stay healthy, simulating mars gravity perhaps, and then operate surface marscopters, rovers and other surface assets, similarly to avatars in a computer game.

This is what it might look like from inside the spacecraft

Text on graphic: Mirror life here (one scenario)

Can never land (at least never return) - but can explore via immersive VR experienced more clearly than if they are on the surface

Would stimulate high levels of interest in the public

In the 1960s the public quickly got bored of the Apollo missions after the flag and footsteps succeeded.

Composite of photo from the Cupola of the ISS (Russian cosmonaut Dmitri Kondratyev (left), Expedition 27 commander; and Italian Space Agency/European Space Agency astronaut Paolo Nespoli in the Cupola, use still cameras to photograph the topography of points on Earth. Picture taken by 3rd crew member, Cady Coleman) and Hubble photo of Mars (, Photograph of Mars taken by the Hubble Space Telescope during opposition in 2003. 3)  

If we can go to Mars it's not much of a step to go to Jupiter or even Titan. Far more of a step up to go to the Mars from the Moon because we need ultra-reliable life support and ability to sustain it for years on end. Here is a reminder of this graphic:

This compares evacuation times:

ISS emergency evacuation a few hours, resupply every few months < day to arrive

Moon emergency evacuation 2 days, resupply takes 2 days to reach the Moon

Mars emergency evacuation minimum 6 months, emergency resupply minimum 6 months to arrive

(added text to this infographic from the Canadian space agency: Distances between Earth and the International Space Station, the Moon and Mars - infographic)

This is what we can do in Callisto based on studies of space settlement there.

Elon Musk’s artist’s impression of his spacecraft for a crew of 100, the Interplanetary Transport System. He said his spacecraft would use Europa as a refueling stop in the outer solar system. Callisto is a far better refueling stop because of the lethal ionizing radiation around Europa which is within Jupiter’s radiation belts. The artist’s impression actually more closely resembles Callisto as the surface of Europa is probably broken up and rough on the meter scale, at least with current understanding (Interplanetary Transport System, Official ).

Inset shows artist’s impression of an exploration base on Callisto (, The Vision for Space Exploration : 22)

.

Then there’s Titan

Text on graphic: Later humans may colonize Titan - the only other location in our solar system with an atmosphere

  • in the Saturn system
  • thicker atmosphere than Earth (mainly nitrogen)

Titan's atmosphere is so thick:

  • humans don't need spacesuits - just very thick diving suits and bottled oxygen
  • habitats are as easy to construct a s a terrestrial polytunnel
  • cold is far easier to protect against than vacuum
  • sources of energy from winds a few hundred meters up
  • gravity so low humans can fly by flapping wings!
  • sources for making plastics
  • ice for water, and for fuel
  • so very cold backward contamination is unlikely and forward contamination impossible unless it has liquid water in cryovolcanoes

(needs confirmation that there are no planetary protection issues)

(SpaceX Interplanetary Transport System at Saturn)

(Titan, Earth & Moon size comparison)
 

So this is a very positive future for humans in space.

I'm keen on humans in space myself. Ever since a child, long before Apollo, watched amazed when the first astronauts landed on the Moon. I'm sure that there we'll have an amazing future in space but we need to do it properly and what we do now matters for the future.

We can even shape that future, for instance if there is some wonderful exotic but vulnerable life on Mars or fascinating prebiotic chemistry maybe flipping chirality in multiple networks in different locations on Mars, our choices right now lead to two different diverging futures, for millions of years into the future depending on what we do.

Our descendants a thousand or a million years from now either get to study a planet with this exotic early life or prebiotic chemistry in our solar system or they have to travel out for light years into the galaxy to try to find something like the pre-anthropocene Mars.

Similarly if there is something on Mars that would have significant impacts on our biosphere, our decisions right now have the possibility of shaping Earth's biosphere for millions of years into the future. Many astrobiologists think that evolution of life is likely rare. The nearest planet with independently evolved life might be thousands of light years away. But it might be just a few hundred million kilometers away, on Mars. We don't know. If we are lucky enough to have something like that on Mars it would be of huge benefit to us, a great treasure, a great inspiration for space exploration in our solar system. But we'd be extremely foolish to return a novel biology to Earth and let it spread here, without first making very sure we understand its interactions with our biosphere and what it would do. And if it is similar to terrestrial life in its biology, it might well find Earth more habitable than Mars.

So, let's do this properly, find out what's there, and make our decisions based on knowledge rather than based on an absence of knowledge. Well that's how I see things and I hope you agree or at least it's given readers pause for thought.

But right now I hope you'll agree we need to make sure this EIS satisfies basic scientific credibility and is legal under NEPA.

.

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 endorsement | DRAFT: Call to NASA to defer or withdraw PEIS | Letters | BOOK: Preprint to submit to academic publishers

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