I am a long term admirer of NASA and your excellence in space missions and engineering is extraordinary. I am well aware of how brilliant your scientists are in the topics they excel at. I'd never have guessed I'd need to write something like this to you.
However I need to talk here about what I see in your EIS and this particular mission and whether it is adequate to protect Earth. I'm doing this for the sake of all the inhabitants of Earth's biosphere, human, animals, plants, even insects. It is important to speak plainly about what I see. What I see in your plans for the Mars sample return mission, your EIS and your replies to our comments as published in this final PEIS, is that it doesn't show even basic understanding of "planetary protection of the past" in your own words, see:
The major mistakes I describe here will be immediately clear to anyone familiar with the basic literature on planetary protection for a Mars sample return. This lack of anyone trained in the necessary disciplines has lead to a situation where your team, sadly, are no more competent to do a plan to protect Earth than they would be if someone called in NASA to substitute for the WHO to contain an Ebola outbreak in Africa or substitute for the CDC to respond to an outbreak of avian flu in the States. It's for much the same reasons that you wouldn't expect the CDC or the WHO or the DoA to be competent to oversee a mission plan to send a spacecraft to Mars, on their own, with no help from NASA.
I am putting it like this in the hope that such direct, clear and straightforward speaking will lead to this matter getting the attention it needs. As John Rummel said in his brief email to me after saying that he is not in a position to talk to me himself about your plans:
I encourage you, however, to respond to NASA’s draft, highlighting the weaknesses that you have found. Somebody will listen – of that I am convinced – but I no longer work for NASA on this or any other project.
So far nobody has listened - your team replied to my comments but their replies showed they hadn't listened. But I am encouraged by John Rummel's comment and hope that at some point someone on your team will listen. Thanks!
I have a list of the main issues found at the end of this page with links to the relevant sections which may be useful:
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.
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
It’s important to recognize these mistakes 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.”
This shows in your replies to our public comments on your draft EIS and in the EIS itself. You simply don't have anyone with the necessary expertise left to respond.
Your current team didn't notice that your 2019 cite to the National Academy of Sciences directly rebuts the sentence it is attached to (for the Mars Meteorite argument)
What the EIS says:
“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], …”
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 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.”
It was also rebutted in the 2009 Mars sample return study from the Space Studies Board:
Thus, the potential hazards posed for Earth by viable organisms surviving in samples is [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.
In your replies to public comments on this argument you don't provide any evidence to explain why you say that Mars microbes would get here better protected and faster in Mars meteorites than in the sample tubes and don't give any page number cite to support it.
In context this is the full argument:
The natural delivery of Mars materials can
provide better protection and faster transit than the current MSR mission concept.
First,
potential Mars microbes 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], and, within the interior portions of the rocks, would be
protected from elevated radiation levels, and large temperature variations that meteorite
surfaces experience during the transit from Mars to Earth (Mileikowsky 2000).
Second,
a significant fraction of natural transits occurs on trajectories that require as little as
6 months where the material returned by the MSR mission concept would be in flight for over 18 months (Gladman 1997).
Thus, if potentially harmful microbes were abundant
on the Martian surface it is likely they already would have been transferred to Earth by
this natural process (Fajardo-Cavazos et al. 2005 [ABOUT B. SUBTILIS], Horneck et al. 2008 [ABOUT B. SUBTILIS AND CHROOCOCCIDIOPSIS], Howard et al.
2013 [ABOUT IMPACT GLASSES FORMED AT 1,700 C]).
Those cites are only about exceptionally hardy microbes, and the most recent cite seems to be a mistake as it is about trace biomarkers from trace organics in impact glasses that form at 1,700 C and not about the survival of any organisms.
None of them say that it is likely potentially harmful microbes would survive to Earth.
Fajardo-Cavazos et al. was about survival of b. subtilis on a sounding rocket. This is not controversial, b. subtilis is exceptionally hardy and there is growing evidence that if Mars ever had microbes as hardy as b. subtilis for impact ejection they would be able to survive to Earth on rare occasions.
Howard et al is about preservation of biosignatures in molten glass. This isn't relevant to the sentence it's cited to as they wouldn't contain viable life as they'd have been heated to temperatures of 1,700 C during formation:
Despite evidence that Darwin glass formed at temperatures
>1,700 ?C (ref. 7), we report the presence of biomarkers within
Darwin glass, which we suggest are remnants of the ancient target
ecosystem that were captured and preserved since the time of
impact.
Horneck et al is about lithopanspermia but it is only about b. subtilis and chroococcidiopsis. It confirms earlier results about b. subtilis testing it inside rocks and .
Because they are widely accepted as the
hardiest microbial representatives that can withstand extreme environmental stress conditions,
Bacillus spores are the most frequently used test
objects in experiments in space as well as in
ground-based simulations for studying the different steps of lithopanspermia
The vital launch window for the trans-
port of rock-colonizing microorganisms from a
Mars-like planet depends on the physiological
states of the microorganisms. It encompasses
shock pressures in the range of 5 to about 40 GPa
for bacterial endospores and lichens, and is limited to shock pressures from 5-10 GPa for the
cyanobacteria. This vital launch window is in accordance with the total launch window of martian meteorites, which is from 5-10 GPa to 50-55
GPa.
...
Considering the low frequency of
weakly shocked meteorites (about 5% with pressures of 10 GPa in the case for Mars), however,
this fact further reduces the chances for inter-
planetary transport of cyanobacteria-type organisms.
Our results
enlarge the number of potential organisms that
might be able to reseed a planetary surface after "early," very large impact events (Wells et al.,
2003) and suggest that such a re-seeding scenario
on a planetary surface is possible with diverse organisms.
There is NOTHING in any of the cites you use for this paragraph relevant to the thesis that any abundant species of potentially harmful life on Mars would get to Earth in meteorites. I am not aware of any peer reviewed paper that argues in this way and you don't cite one.
NOT COMPARING of transfer in meteorites with transfer in sample tubes.
NOT ABOUT potentially harmful microbes.
NOT ABOUT all species of microbes only exceptionally hardy microbes
If this conclusion was established it would be a very major new result in Planetary protection, but instead all the main peer reviewed cites rebut it.
Yet you haven't changed this sentence which remains central to your argument.
Robert Walker:
Draft PEIS says (MISTAKENLY) Mars life can get
to Earth faster and be better protected in
meteorites than sample tubes - their cites don't
support this - their main cite is about transfer
from Mars to its innermost moon Phobos instead
of Earth - and didn't look at sterilization during
ejection from Mars. This is a central point in their
argument (NASA, 2022eis: 3-3): "The natural
delivery of Mars materials can provide better
protection and faster transit than the current
MSR mission concept."
NASA:
The 2019 NASEM/ESF report contains a section titled "Ratio
of Natural to Spacecraft Flux of Martian Material to Earth" in
which the amount of material returned to Earth on relatively
rapid transits is estimated and compared to that planned for
return from the Martian moons by the JAXA MMX mission.
Regarding the shock pressures experienced by Mars ejecta
that reach Earth, the report noted that while the ejection
velocities are higher than for material reaching only the orbits
occupied by Phobos, "weakly shocked Mars rocks where
microbes would have survived are known, so this effect only
modestly reduces the flux to Earth relative to Phobos." Regarding the SterLim report referenced by the comment, the
estimate for Mars material flux to Earth provided in the 2019
NASEM/ESF report was derived from other sources and is
not cited in estimating the fraction of hypothetical Mars
microbes that would survive transfer
[This deflects away as it just tells me about the amount of material and is nothing to do with sterilization]
NASA fail to adequately consider the risks from life that can't get to Earth on meteorites - 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
There isn't anything here to support the thesis of
the draft EIS that it is easier for Martian microbes
to get to Earth on a meteorite than in a sample
tube. (NASA, 2022eis: 3-3): "The natural delivery
of Mars materials can provide better protection
and faster transit than the current MSR mission
concept."
NASA fail to adequately consider the risks from
life that can't get to Earth on meteorites - 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. Let's look at the first of these two statements
NASA use to support their conclusion that the
activity is very low risk, from the MSR safety fact
sheet from this page: "The evidence includes the
absence of any observed harm to Earth's
environment from Martian rocks that frequently
fall to Earth in the form of meteorites." Then in
the draft EIS: "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 natural
delivery of Mars materials can provide better
protection and faster transit than the current
MSR mission concept."
They cite the NRC report from 2009 but not on
this point. The National Research Council DID
look into this question in their "Assessment of
Planetary Protection Requirements for a Mars
Sample Return." However their conclusion was
the opposite of NASA's draft EIS summary. They
were unable to rule out the possibility that life
from Mars could have caused past mass
extinctions on Earth. The NRC found that most
of the meteorites that get to Mars are sterilized
during transit. But about 1% get here within
16,000 years and 0.01 percent within 100 years
(note none of the meteorites we have from Mars
left the planet less than hundreds of thousands
of years ago). This is from Earth (Board et al,
2009: 48): "Transit to Earth may present the
greatest hazard to the survival of any microbial
hitchhikers. Cosmic-ray-exposure ages of the
meteorites in current collections indicate transit
times of 350,000 to 16 million years. However
theoretical modeling suggests that about 1
percent of the materials ejected from Mars are
captured by Earth within 16,000 years and that
0.01 percent reach Earth within 100 years." NRC
continue that survival of organisms in meteorites
is plausible. If they can be shown to survive
ejection, entry and impact they can be expected
to transfer from Mars to Earth (Board et al, 2009:
48)
[they break off at that point, my attachment continues:]
"Thus, survival of organisms in meteorites, where they are largely protected from radiation, appears plausible. If microorganisms could be shown to survive conditions of ejection and subsequent entry and impact, there would be little reason to doubt that natural interplanetary transfer of organisms is possible and has, in all likelihood, already occurred."
However that is the big unknown. Can life from present day Mars get onto the meteorites, be ejected from Mars, and then survive the fireball of re-entry to Earth.
[By breaking off just before my real conclusion, they give a misleading impression. I seem to be contradicting myself with a conclusion that is the opposite of what I'm arguing because of the point where they clipped my comment]
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 meteorite
[NASA's reply just deflects away. I quoted from the 2009 cite where it says the Mars meteorite argument is invalid, they quote most of what I say except misleading clipping what I said to give the impression that I contradicted myself in my own conclusion and don't comment on it and don't change what the final PEIS says, and don't mention anywhere that the 2009 cite says the argument is invalid]
[Pages 3-3 to 3-4 doesn't mention any possibility of life that can't get to Earth on meteorites]
Thomas Dehel:
NASA incorrectly asserts that the safety case of Mars Sample Return is supported by the past arrival on Earth of meteorites from Mars.
Lithopanspermia has never been proven, and I am not aware that NASA subscribes to this as an established fact. If so, please provide that reference
NASA:
HS-012 The concept of interplanetary material transfer is of interest with respect to planetary protection, as noted by its inclusion in the rationale supporting an unrestricted return of material from the moons of Mars published by the National Academies of Science, Engineering and Math (PEIS, p. 3-3).
NASA The 2009 NRC report cited in the comment, in recommending an overall approach to backward planetary protection when returning samples from Mars, stated that "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."
This is in contrast to a contemporaneous literature review and synthesis on the specific topic of potential interplanetary organism transport that concluded some Earth organisms would likely survive certain interplanetary transits (Nicholson, 2009, https://doi.org/10.1016/j.tim.2009.03.004).
Overall, the introduction of Mars material to Earth's biosphere through natural processes remains consistent with a low risk of harm posed by Mars material. However low that risk may be and consistent with the 2009 NRC report and NASA guidance, 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."
[NASA deflects away just pointing to more material saying that it may be possible for life to transfer on rare occasions - but none of them prove that lithopanspermia has ever happened or that if there is life on Mars that it has to be able to get to Earth in meteorites]
This is an EXTREMELY SERIOUS citing error because the Mars meteorite argument is central for your planetary protection case in almost all of the planetary protection sections of the EIS and in your replies to public comments. Your previous planetary protection officers could NEVER have made this error.
It is also extremely serious because space colonization advocates have been using this argument for years to try to get NASA to drop all planetary protection. It is one of four arguments presented by Robert Zubrin, president of the Mars society (Zubrin, 2000, Contamination From Mars: No Threat) with the response from planetary protection experts (Rummel et al., 2000, Opinion: No Threat? No Way : 4 - 7). You likely don't realize you are doing this. But this EIS is effectively endorsing Robert Zubrin's invalid arguments, and supporting him in opposition to your 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, Robert Zubrin only has that non peer reviewed op. ed. Your EIS endorses ALL FOUR of Robert Zubrin's plausible but invalid arguments against the peer reviewed literature of experts on planetary protection with arguments that fall apart as soon as one examines them closely with some basic familiarity with the literature. The links here are to the open letter though later in this page I'll look at your response to comments alerting you to some of these issues too.
(PLAUSIBLE BUT INVALID) existing credible evidence says Mars has been uninhabitable for millions of years [iMOST think there is enough of a chance of finding life to try to get something to grow from the samples (iMOST: 94) and contradicted by NASA's own cite: "The exploration of … Mars … will help establish whether localised habitable regions currently existwithin these seemingly uninhabitable worlds”. (Origins, Worlds, and Life:393). ]
You noticed my comment on your draft EIS saying that the public deserves for the EIS to be peer reviewed:
The public deserves it to be peer reviewed first
by independent reviewers not connected with the
project
Your replied correctly NEPA doesn't require a peer review. It is up to the agency preparing the EIS how they make sure the report is accurate.
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)
However, NEPA DOES require scientific integrity
Agencies shall ensure the professional integrity, including scientific integrity, of the discussions and analyses in environmental impact statements § 1502.23 [Links directly to the legal text]
Amongst the measures needed to ensure this, it require agencies to make sure they include experts of the appropriate disciplines for the EIS.
Agencies shall prepare environmental impact statements using an interdisciplinary approach that will ensure the integrated use of the natural and social sciences and the environmental design arts (section 102(2)(A) of NEPA). The disciplines of the preparers shall be appropriate to the scope and issues identified in the scoping process (§ 1501.9 of this chapter).
That's the issue here. The disciplines of the preparers are not appropriate to the issues. Your treatment of the Mars meteorite argument makes that immediately clear.
I will give some other examples based on your responses to our comments. Your replies are as expected from scientifically literate experts who are not familiar with basic concepts in planetary protection.
Nobody would go to NASA for advice on how to contain an Ebola outbreak.
So why would NASA know how to contain samples from Mars that could potentially have new organisms never encountered by terrestrial biology before and potentially independently evolved life such as mirror life? Especially how can it know how to do that without liaising with appropriate experts for the task it faces?
You can't be expected to have the necessary expertise internally.
The Space Studies Board has said this many times, most recently in 2018 saying a formally constituted independent advisory process and body is needed, to provider peer review (amongst other reasons):
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.
We see the need for this body all through this report.
NASA shouldn't be in the situation where the most important sentence in the EIS for planetary protection has a cite that rebuts the sentence you attached it to - and nobody on your team noticed. This would never have happened if you'd followed the advice of the Space Studies Board.
Then NEPA requires you to present all major points of view on the environmental impacts.
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.
I will focus on the Mars meteorite here as top priority, because you focus on it so much in the EIS. So it's highly significant that the EIS never recognizes the consensus opinion in ALL the peer reviewed literature that the Mars meteorite argument is false.
Even when public comments pointed out this error to you, your team was not able to identify the refutations of the Mars meteorite argument in your own cites. Instead, the final PEIS continues to present the Mars Meteorite argument as a consensus. This is what the final PEIS still reads:
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) .
Now, one could split hairs and say that at the start of that paragraph you are just talking about transfer of martian material on meteorites - and of course the 2009 study and all studies for decades have agreed that Martian meteorites get to Earth.
However, this transfer of materials from Mars to Earth wouldn't by itself be a reason for saying that the risk of pathogenic effects is low. It wasn't until 2000 that we had a reasonable evidence that b. subtilis, a very hardy microbe, might on very rare occasions be able to get from Mars to Earth if such a hardy microbe ever evolved on Mars and could get into a meteorite. The paper that established this result also made it clear that the "harsh space environment sets a definite barrier for most microorganisms known"
Whereas this harsh environment sets a definite barrier for most microorganisms known, some have developed survival strategies, by transforming into a dry state, the so-called anhydrobiosis ..., or by producing spores, the dormant state of certain bacteria.
Concomitantly with their resistance to the adverse effects of drying, microorganisms in anhydrobiosis or spore stage are resistant to the effects of freezing to very low temperatures, elevated temperatures for brief periods, and the effects of ionizing. These characteristics make spores and anhydrobiotic bacteria especially prepared for coping with the extreme conditions of space
Add to that, it's any organisms on Mars that can't get here that are the potentially invasive ones. As I said in the open letter, Barn swallows aren't invasive in the States because they fly across the Atlantic naturally while Starlings, which can't cross it, cause over $1 billion in agricultural damage every year. I cover this in the open letter under:
The most one can say from the b. subtilis result is that it is possible that if Mars has very hardy microbes like b. subtilis that it might get into meteorites on rare occasions, maybe even every few hundred million years, maybe only in the early solar system when it had seas like Earth. They didn't establish anything about the frequency and they didn't establish anything about how hardy or otherwise native Martian life might be.
Then, the paragraph ends by adding the same 2019 National Academy of Sciences cite to support the Mars meteorite argument.
“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), …”
The first use of your cite is about Martian material (which of course is uncontroversial) and the second use is about potential Mars microbes but the overall impression is that it is all about Mars microbes and that it is a consensus in the literature that the 2019 report affirms.
As a result, the paragraph as a whole presents a clear and mistaken message to the uninformed reader that there is a consensus in the entire science community including the National Academy of sciences that the Mars meteorite argument is valid and not only that, that the National Academy of sciences also presents it as a consensus.
You also do not give any cites to suggest anyone disagrees with this supposed consensus in the peer reviewed literature even though your own cite disagrees with it.
As we saw the consensus is that the Mars meteorite argument is the other way around, that it is INVALID. You haven't provided any example of a peer reviewed cite that agrees with your conclusion, and I can't find one. The only paper I know of that supports it is the non peer reviewed op ed by the president of the Mars Society Robert Zubrin which I cover above in:
So - the view that the Mars meteorite argument is invalid is not only a major view on the Mars meteorite argument but it seems to be a 100% consensus in the literature. Yet it isn't mentioned in the EIS because you represent the consensus to the reader as the opposite of what it really is.
Again this is not the fault of anyone in your current team. It seems many people including brilliant scientists and engineers find this argument plausible and believe it to be already established.
Rather, it is a direct result of previous decisions to close down the planetary protection office, which removed from your team anyone familiar with the basic concepts and arguments in the cites you use to support this paragraph.
You also don't mention the views expressed by the ESF in 2012, and your former planetary protection officer Cassie Conley that the samples have to be contained as if they were the most hazardous Earth organisms known, risk group 4 organisms.
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.
Risk Group 4 (high individual and community risk): A pathogen that usually causes serious human or animal disease and that can be readily transmitted from one individual to another, directly or indirectly. Effective treatment and preventive measures are not usually available.
Cassie Conley, former NASA planetary protection officer from 2006 - 2018 summarized their policy at the time like this in an official NASA video which they have not taken down:
“that means we are going to contain the samples as if they were the most hazardous Earth organisms that we know about, Ebola virus.”
Your Planetary Protection engineer says this "isn't the planetary protection of the past".
This isn’t the Planetary Protection of the past — we are doing things differently. We have a different approach and philosophy.
There’s still a lot of work to go as we start to pave the way to humans on Mars — we’ve never done that, it’s a new precedent, so we’ll need that continued support to help with managing those knowledge gaps, including management support, engineering support and of course funding support.
The rubber is hitting the road; it’s time to get it done and we need that collective agency support to do that.
Indeed it isn't the planetary protection of the past. But why does their approach lead to repeated failings of basic scientific integrity in this draft EIS?
whether NASA and other institutions can be trusted to do the mission
worst case scenarios
whether the methods of handing the sample, quarantine and containment of any Martian life are adequate
It’s understandable that engineers whose minds are focused on solving numerous complex technical difficulties with the mission might not understand the need for all this.Why involve experts in public health, Earth's environment, or social or legal issues? This wouldn’t help solve their engineering problems and might well make them harder to solve with extra complexity.
You did have some experts in relevant disciplines. By its charter your (Planetary Protection Advisory Committee Charter) had at least four members knowledgeable in one or more of the fields of bioethics, law, public attitudes and the communication of science, the Earth’s environment, or related fields. But you dismissed them. Along with the interagency panel with its scientists from:
Department of Agriculture
Department of Energy
Department of Health and Human Services
National Institutes of Health
Centers for Disease Control and Prevention
Department of Interior
Department of Transportation
Environmental Protection Agency
National Science Foundation
Executive Office of the President
It is totally understandable you would find this expertise of no relevance to the science and engineering to achieve your mission priorities. However, for the general public, such expertise is absolutely essential for the issues that matter most to them.
NASA's team quoted this passage from my "many serious mistakes" draft paper on the EIS:
The draft EIS shows clearly the results of not setting up any advanced planning and oversight agency with experts in legal, ethical and social issues tasked with interfacing NASA decisions and the general public’s questions as the top priority – as recommended in numerous papers on Mars sample return missions. Rummel et al recommend a planning agency set up in advance with experts in legal, ethical and social issues - Uhran et al recommend an advanced planning and oversight agency set up two years before the start of the legal process – and the ESF recommends an international framework should be set up, open to representatives from all countries - NASA don’t seem to have done any of this yet. (NASA, 2023, MSR FINAL PEIS B-67),
NASA replied
The Committee on Planetary Protection, International Council for Science, Committee on Contamination by Extraterrestrial Exploration (CETEX), and Committee on Space Research (COSPAR) all serve this purpose. It is not within the scope of the NEPA document to mandate implementation of planning and oversight agencies, only to analyze the potential environmental impacts associated with a proposed action (NASA, 2023, MSR FINAL PEIS B-67),
As you'll see, the context is that I was talking about how NASA responded to this question from the public asking that given that the possible consequences of failure are so great, what is their target probability for an acceptable level of risk with
When the consequences of a failure are so great, a 100% guarantee should be required. ,,,
Just how low is “low likelihood”? Is NASA’s goal specification to prevent accidental release of the Mars samples 1 in a thousand? 1 in a million? 1 in a billion?
NASA replied in this way, which hasn't been changed in the final PEIS:
No outcome in science and engineering processes can be predicted with 100% certainty. The safety case for MSR safety is based on redundant containment supported by rigorous testing and analysis, the extensive experience of NASA and ESA with very similar activities over the past three decades, as well as independent reviews of program plans by external experts
I alerted NASA that members of the public who are concerned that NASA may not be taking sufficient precautions need something better than "No outcome in science and engineering processes can be predicted with 100% certainty"
Apart from anything about the actual risk assurance details here which we'll see are also inadequate, we have a major communication issue here. NASA's reply is not going to be reassuring or helpful to anyone asking that question. They asked the question because they are concerned that NASA isn't taking adequate precautions and NASA reply saying that
No outcome is 100% certain
this is false, e.g. the "no action" alternative can be predicted with 100% certainty to have no impact on Earth's biosphere
this is not reassuring to someone concerned that NASA is not taking its responsibilities seriously enough
and the question is a valid one in risk assurance, even your expert on risk assurance Chester Everline asks the same question so it deserves an answer
That they have lots of experience of very similar activities in the last three decades
this is false, you have no experience of similar activities in the last three decades, the only relevant previous experience is for Apollo
Perhaps an analogy will help to explain why it is not reassuring to answer in this way. Suppose the member of the public is a nervous flyer and asks the pilot
"what is the chance that this plane will crash? Iis it 1 in a thousand? 1 in a million? 1 in a billion?"
The pilot answers:
"No outcome in science and engineering processes can be predicted with 100% certainty. But the safety case for this plane has been established by rigorous testing and analysis and we have been flying planes like this for three decades."
It would be a correct answer in that case but not a skillful answer as the pilot hasn't answered the most important concern, hasn't reassured the questioner that the risk is low.
At least you could have respond to the questioner saying the risk is likely very low. But no. You are not able to say even that the risk is unlikely. It is what you don't say here that is the issue.
All the experts seem agreed that the risk is likely low and you could have said this without any controversy but due to lack of any expertise in communication with the public you didn't see the need to say it.
In the section of my attachment that you are responding to with this reply, I suggested you use the example of a smoke detector as a way to communicate to the public that we are talking about low risk here, low risk but of large scale harm.
A good analogy, it's more of the order of building a house without a smoke detector - but a house you share with nearly 8 billion people - than setting off outdoor fireworks in the kitchen. This smoke detector analogy is from Margaret Race from her contribution "No Threat? No Way" in the Planetary Report "(Rummel et al., 2000, Opinion: No Threat? No Way : 5). In this cite, she is responding to Robert Zubrin, president of the Mars society who thinks we don’t need to protect Earth from a Mars sample return. She wrote in 2000:
"He's confident in our impressive technological prowess; he's raring to go and doesn't want anything to slow down or stop our exploration of Mars - especially not burdensome regulations based on very small risks and scientific uncertainty. Yet when he suggests that there's no need for back contamination controls on Mars sample return missions, he's advocating an irresponsible way to cut corners. If he were an architect, would he suggest designing buildings without smoke detectors or fire extinguishers?
This one way to do it, my page to explain what the issues are about for people who get easily scared (and there are many such, autistic, bipolar, people who are very empathic or imaginative and so on):
But you don't mention the rest of that section. It must be one of the many sections you dismissed as "nonsubstantive". It isn't anything to do with engineering but it is of central importance to success of this mission to have expertise in communication with the public.
I hope what I say is clearer now. Using an analogy of a smoke detector will help to keep things clear. While at the same time acknowledging that there is potential for large-scale harm.
If NASA continues to not directly acknowledge the potential for large-scale harm and continues to respond to the public without any experience or expertise in risk communication, this is likely to lead to serious communication issues and in our modern connected world with social media, it is pretty certain to lead to an infodemic and conspiracy theories.
This was my comment that you reply to where I draw your attention to your mistaken statement that all your reasoning in the EIS supports the judgement that potential environmental effects would not be significant - which is not found in any of the major peer reviewed studies on a Mars sample return which instead paint a clear picture of a likely low risk of highly significant large-scale harm to the environment or to human health:
Draft PEIS says (MISTAKENLY) potential
environmental impacts would not be significant -
2009 NRC study says risk of large scale effects
appears to be low but not demonstrably zero,
and they can't rule out the possibility of large
scale effects on the Earth's biosphere from
martian life in the distant past. Then in the draft
EIS they say that the potential environmental
impacts from a sample release would not be
significant (NASA, 2022eis: 3-16): "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." This sentence is not cited. However in the
discussion of large scale effects, the 2009
National Research Foundation study they use as
a source elsewhere says that it is simply not
possible to discount such effects in the distant
past from Martian life transferred to Earth.
(Board et al, 2009:48):
Your reply is to first refer me to NEPA section § 1502.21 (c) and (d) and particularly to the last paragraph so let's just quote what it says verbatim:
(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.
You tell me that
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)
Of course "unlikely to pose a risk of significant ecological impact" does NOT mean that there would be no significant impacts. That's like saying a house fire is unlikely and therefore something as significant as a house fire can't happen.
But I think we are talking here to people who just aren't used to reasoning about such concepts.
The first part of that sentence is okay except it should read significant LARGE-SCALE ecological impacts, this is an important point that needs to be stressed as some ecological impacts are minor and short term such as a chemical release into a river of a small amount of toxic chemicals.
We are talking here about potential large-scale changes of Earth's biosphere that can't be reversed and are a change for all future generations in the worst case, such as return of mirror life. Indeed it would be more accurate to call the worst case scenarios here not only large-scale but unprecedented scale. A more accurate summary would add the words LARGE-SCALE and would also explicitly mention harm to human health. These changes would bring that first sentence into accord with the published peer reviewed studies on a Mars sample return.
that samples are unlikely to pose a risk of significant [LARGE-SCALE] ecological impact or other significant harmful effects [INCLUDING LARGE-SCALE HARM TO HUMAN HEALTH]
[Missing word LARGE-SCALE from the first half of the sentence and missing mention of human health which is covered explicitly in all the major Mars sample return studies]
I think personally it brings more clarity to the debate to also add POTENTIALLY UNPRECEDENTED here. The large studies don't explicitly say "unprecedented" for the large scale effects but it is clear from the discussions that this is the worst case and this is the concern of the general public too and Carl Sagan's statement
“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.”
With a clearer statement of the unlikely case, the first part of your sentence is okay.
The second part of this sentence is NOT okay
support the judgement that the potential environmental impacts would not be significant
It is not valid to reason from a low risk of significant large-scale effects to a judgement that the effects are not significant. The analogy of a house fire should help here as the risk of a house fire is very low but highly significant. You can only deduce a LOW LIKELIHOOD of potential LARGE-SCALE EFFECTS.
This is what the first half of the sentence supports, if stated more accurately
support the judgement that the potential environmental impacts would be low risk but highly significant large scale impacts on human health or the environment
This is the conclusion of all previous studies and the main difference in this EIS is the replacement of a low likelihood of large-scale effects with an assessment that the environmental effects would not be significant. But as you say in your comment reply to me, you don't have proof that the low risk effects would not be significant just that they would be low likelihood. Low likelihood doesn't prove no significance.
Your actual reasoning to the low-likelihood of environmental effects is also invalid and not based on the reasoning used in previous sample return discussions leading you to an impression of far lower likelihood than is presented in the peer reviewed studies you used.
Also, you do need to start talking clearly about large-scale harm and what you are doing to prevent it, or what you say is just not going to be credible to the general public. The meteorite argument and the argument that Mars is uninhabitable and that nothing there can live here and that anything from Mars that can live here won't harm us - those are very persuasive arguments for people who are enthusiastic to send humans to Mars quickly and who are ready to be persuaded.
However those assurances of zero risk based on inadequate reasoning won't work with fishermen worried about what happens if alien life destroys or replaces the marine microalgae, which are the basis of the marine food web, or farmers worried about the risk of a novel fungus that will kill a turkey flock, or doctors or nurses worried about a risk of going through what we went through with COVID but with a novel pathogen that may not even be based on terrestrial biology.
Meanwhile if asked, many may not even know if humans have been to Mars or not. It's not high in their priorities and it isn't a factor that will encourage them to pay less attention to risk. They have a very different perspective from enthusiasts for humans to Mars and you can't expect them to prioritize humans to Mars a few years sooner over even a very small house fire level of risk of serious harm to human health or the Earth's biosphere or their livelihoods.
I am saying this as someone who is enthusiastic for human exploration and settlement in the solar system myself. But who also values human life and Earth's biosphere beyond measure.
So this risk must be acknowledged and managed.
But it needs to be kept in perspective and not made to seem likely.
"Not 100%" is very different in the mind of the public from "Likely very low" and even that is far different from "Likely very low risk like a house fire" which I find is a wonderful analogy for communicating with the few of the public who have asked me about this already.
Once (hopefully) you have experts on your team in risk communication they may well come up with many tools for risk communication with the general public. Achieving methods for good communication will be high priority for them and will likely involve lots of work, focus groups and so on.
Mars Sample Return Studies have 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. They also talk about the need to develop tools to effectively interact with individual groups.
This is from the most recent ESF study in 2012:
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
There will be intense public scrutiny of NASA’s plans as it gets nearer to the date the samples return to Earth. If you still don’t have a functioning smoke detector in this analogy you will have to fix this.
So now look at your comment reply again, can you see that it doesn't actually answer my question?
The Committee on Planetary Protection, International Council for Science, Committee on Contamination by Extraterrestrial Exploration (CETEX), and Committee on Space Research (COSPAR) all serve this purpose. It is not within the scope of the NEPA document to mandate implementation of planning and oversight agencies, only to analyze the potential environmental impacts associated with a proposed action (NASA, 2023, MSR FINAL PEIS B-67),
We are talking here about an issue with your own replies to comments, with risk assurance and risk communication and general communication with the public in the EIS. It is about the composition of your team itself, about the disciplines of those involved in preparing the documents and plans.
You are right that it is not within the scope of the NEPA document to mandate these things. It can't, it's too late at that point. Rather, NEPA requires this expertise to be in place already, before the EIS process starts. This is one of many reasons why this EIS needs a clean restart. I mentioned that passage already:
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). The disciplines of the preparers shall be appropriate to the scope and issues identified in the scoping process (§ 1501.9 of this chapter).
The many mechanisms to communicate effectively with the public and listen to public concerns that previous sample return studies mandated would be included in that phrase: integrated use of the natural and social sciences and the environmental design arts
The basic engineering details for your mission plan are worked out. But you haven't made a start on most matters of most concern to the public. For this particular mission those issues require as much attention as engineering for success. Without sorting out those issues you can't expect to be able to do a valid EIS.
So let's go back now and look at more of these planetary protection issues.
Let's look at some more examples of planetary protection issues
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)
Your very cite for this "existing credible evidence" talks about exploration to help establish if there are localized habitable regions on Mars!
“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]).
My comment
Draft PEIS says (MISTAKENLY) existing credible
evidence suggests Mars hasn't been habitable
for life as we know it for millions of years - their
cite says that we need to search for current
habitats in a seemingly uninhabitable
Mars.
Your public reply to my comment says
This comment confuses two concepts: “life as we know it,” and potentially extant life on Mars that is different than life as we know it.
This response again shows a lack of familiarity in basic concepts. The searches described in that book are for habitats for life as we know it because we simply don't know enough to search for habitats for life as we don't know it.
You can also check the iMost team that recommends your science experiments. It says that if it finds living organisms in the samples it should have diverged from the tree of life of terrestrial organisms
Unless Mars was recently seeded with Earth life, it should be phylogenetically different from modern life, either having diverged from the tree of life prior to the most recent common ancestor to life on Earth or showing a deep-branching evolutionary relationship
Your iMOST team does discuss the possibility that there could be independently evolved life in the samples
“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.”
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).
All this is based on "life as we know it".
At the same time they design our instruments so they can also spot life as we don't know it as best we can.
When we search for habitats for life as we know it, we are also searching for habitats for any life as we don't know it with similar requirements such as mirror life, life with a different vocabulary of amino acids, or some minor variant on DNA etc.
First we search for liquid water with enough water activity for life. We have already found that. All five of the discoveries of near surface brines on Mars were surprises.
SR-SAG2 found seven types of microhabitat that could be present on the surface of Mars
Ice-related Liquid or vapor-phase water coming off frost, solid ice, regolith or subsurface ice crystals, glaciers
Brine-related Liquid water in deliquescing salts, in channels within ice, on the surface of ice, within salt crystals within halite or other types of ‘‘rock salt’’
Aqueous films on rock or soil grains Liquid water on regolith particles of their components such as clay minerals, on surface of ice, on and within rocks, on surfaces of spacecraft
Groundwater and thermal springs (macroenvironments) Liquid water
Places receiving periodic condensation or dew Liquid water on regolith particles of their components such as clay minerals, on surface of ice, on and within rocks, on surfaces of spacecraft
The 2015 Space Studies Board review says that though SR-SAG2 considered these microenvironments it only briefly considered the implications of our lack of knowledge of them
Physical and chemical conditions in microenvironments can be substantially different from those of larger scales. Although the SR-SAG2 report considered the microenvironment (Finding 3-10), the implications of the lack of knowledge about microscale conditions was only briefly considered.
…
Craters, and even microenvironments underneath and on the underside of rocks, could potentially provide favorable conditions for the establishment of life on Mars, potentially leading to the recognition of Special Regions where landscape-scale temperature and humidity conditions would not enable it.
This is the relevant passage in the EIS. NASA affirm a consensus that the Martian surface is too inhospitable for life to survive there today, particularly in the shallow subsurface in Jezero crater. What is controversial here is the source, and calling that source a consensus when in reality it is highly controversial even though it is a major study by the Space Studies Board.
Consensus opinion within the astrobiology scientific community supports a conclusion that the Martian surface is too inhospitable for life to survive there today, particularly at the location and shallow depth (6.4 centimeters [2.5 inches]) being sampled by the Perseverance rover in Jezero Crater, which was chosen as the sampling area because it could have had the right conditions to support life in the ancient past, billions of years ago (Rummel et al. 2014, Grant et al. 2018).
[Rummel et al., 2014 is often referred to as SR-SAG2]
SR-SAG2 seems to be far better known than the Space Studies Board review of it. SR-SAG2 has 308 cites in Google Scholar. The Space Studies Board review of it has only 16 cites in Google scholar. SR-SAG2 paints a picture of a much less habitable Mars than the 2015 review of it, and especially in places like Jezero crater. SR-SAG2 rules out any habitability in places like Jezero crater while the review finds significant knowledge gaps and say that it's not possible to make such a decision from maps made from orbit.
The background here is that NASA and ESA took the unusual step of commissioning a review of the SR-SAG2 study partly in response to concerns its authors were too closely aligned with the Mars Program office. A major study is pretty much by definition controversial for NASA and ESA to commission a review of it immediately after its publication in peer reviewed journals.
NASA and ESA commissioned this review of SR-SAG2 partly out of concerns that MEPAG is not independent from NASA. When they found out that they had similar concerns they commissioned a combined review.
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. ...
I commented on NASA's draft EIS saying it was a serious omission to cite SR-SAG2 and leave out its 2015 review.
It is a serious omission to cite Rummel et al 2014 and not cite the 2015 study commissioned by ESA and NASA that overturned or modified many of its findings.
NASA replied to my comment that the review modified only 13 findings and removed only 1 finding:
The changes proposed to the 2014 paper by Rummel et al. (no change to 29 findings, modification of 13, combination of 2 findings, removal of 1 finding and introduction of a new finding regarding Humans to Mars missions) as a result of a joint review by the National Academies of Science, Engineering, and Medicine and the European Science Foundation are relevant for fine differentiation of special regions from other areas on Mars for forward planetary protection.
Even to the extent that habitability and special regions are considered together, Jezero Crater’s shallow subsurface has parameters for neither.
However, What matters isn't the total number of findings modified but what the modifications were and if they were relevant to Jezero crater. First the SSB review criticized SR-SAG2 for its use of maps.
This is directly relevant to Jezero crater as the SSB review says any maps from orbit can only represent incomplete knowledge that will certainly be changed.
Maps that illustrate the distribution of specific relevant landforms or other surface features can only represent the current (and incomplete) state of knowledge for a specific time—knowledge that will certainly be subject to change or be updated as new information is obtained
The Space Studies Board Review of MEPAG also says SR-SAG2 didn’t adequately discuss the potential for life to be transported in the dust in the atmosphere (e.g. dust storms)
"The SR-SAG2 report does not adequately discuss the transport of material in the martian atmosphere. The issue is especially worthy of consideration because if survival is possible during atmospheric transport, the designation of Special Regions becomes more difficult, or even irrelevant."
Here, “special regions” are regions where terrestrial organisms are likely to propagate. The second half of the definition isn’t used much given that we don’t yet know capabilities of any putative Martian life:
“within which terrestrial organisms are likely to propagate, or a region which is interpreted to have a high potential for the existence of extant martian life forms.”
If terrestrial life can be spread from anywhere to anywhere on Mars it becomes much harder or impossible to map out safe regions for forward contamination, depending how easily it can spread
The Space Studies Board review of MEPAG says SR-SAG2 only briefly considered the implications of our lack of knowledge of microenvironments on Mars
Physical and chemical conditions in microenvironments can be substantially different from those of larger scales. Although the SR-SAG2 report considered the microenvironment (Finding 3-10), the implications of the lack of knowledge about microscale conditions was only briefly considered.
Finding 3-10: Determining the continuity/heterogeneity of microscale conditions over time and space is a major challenge to interpreting when and where Special Regions occur on Mars.
It then gives a list of seven naturally occurring microenvironments on Mars: Vapor-phase water available Vapor or aerosols in planet’s atmosphere; within soil cavities, porous rocks, etc.; within or beneath spacecraft or spacecraft debris
Ice-related Liquid or vapor-phase water coming off frost, solid ice, regolith or subsurface ice crystals, glaciers
Brine-related Liquid water in deliquescing salts, in channels within ice, on the surface of ice, within salt crystals within halite or other types of ‘‘rock salt’’
Aqueous films on rock or soil grains Liquid water on regolith particles of their components such as clay minerals, on surface of ice, on and within rocks, on surfaces of spacecraft
Groundwater and thermal springs (macroenvironments) Liquid water
Places receiving periodic condensation or dew Liquid water on regolith particles of their components such as clay minerals, on surface of ice, on and within rocks, on surfaces of spacecraft
The 2015 Space Studies Board review says that though SR-SAG2 considered these microenvironments it only briefly considered the implications of our lack of knowledge of them
Physical and chemical conditions in microenvironments can be substantially different from those of larger scales. Although the SR-SAG2 report considered the microenvironment (Finding 3-10), the implications of the lack of knowledge about microscale conditions was only briefly considered.
…
Craters, and even microenvironments underneath and on the underside of rocks, could potentially provide favorable conditions for the establishment of life on Mars, potentially leading to the recognition of Special Regions where landscape-scale temperature and humidity conditions would not enable it.
…
The review committee agrees with Finding 3-10 of the SR-SAG2 report but stresses the significance of the microenvironment and the role it might play on the definition of a Special Region in areas that (macroscopically speaking) would not be considered as such.
The Space Studies Board review draws special attention to biofilms. These aren’t discussed in SR-SAG2 (it has only one mention of the word).
Given the wide distribution and advantages that communities of organisms have when they live as biofilms enmeshed in copious amounts of EPS [substances that microbes can produce around them to help make a “home” in a hostile environment], it is likely that any microbial stowaways that could survive the trip to Mars would need to develop biofilms to be able to establish themselves in clement microenvironments in Special Regions so that they could grow and replicate.
The majority of known microbial communities on Earth are able to produce EPS, and the protection provided by this matrix enlarges their physical and chemical limits for metabolic processes and replication. EPS also enhances their tolerance to simultaneously occurring multiple stressors and enables the occupation of otherwise uninhabitable ecological niches in the microscale and macroscale.
These findings can't be dismissed as irrelevant to Jezero crater. NASA conclude their reply to me:
Even to the extent that habitability and special regions are considered together, Jezero Crater’s shallow subsurface has parameters for neither.
But that is the very point that is at question here. Jezero crater is not currently regarded as a special region. But there is potential for localized microhabitats that haven't been detected by Perseverance including microhabitats made more habitable using biofilms that have evolved to grow in Jezero crater over billions of years. There is also potential for transport of viable spores or biofilms in the atmosphere and dust storms from distant parts of Mars or nearby microhabitats not yet identified either from orbit or by Perseverance including caves, micropores in salt, perhaps melting frosts in some circumstances and so on.
Any life on Mars has had billions of years to evolve to those conditions and millions of years to slowly establish itself, perhaps as a biofilm in some niche microhabitat in Jezero crater and if it is possible to spread in dust storms there may be microbes with adaptations they evolved over billions of years to do so.
Combining these ideas we get an especially interesting scenario for Jezero crater which combines together three of those knowledge gaps, transport in the atmosphere, biofilms and microhabitats. Amongst several relevant discoveries, later research found small fragments of biofilm, thin layers of a microbial colony three hundredths of a millimeter thick, can travel 100 kilometers in daylight in the light Martian winds before it is sterilized (Billi et al.., 2019, A desert cyanobacterium under simulated Mars-like conditions in low Earth orbit: implications for the habitability of Mars)
These authors don't look at transport at night (the winds are as strong at night as in daytime during Martian dust storms) or in the dust storms which blocked out 97% of the UV for three weeks in the great dust storm of 2018. These could turn the survivable distance from 100 km to 1000s of kilometers.
I cover this in my open letter - this is just an illustrative scenario of several that one could devise to show that there may be potential for astrobiological surprises in Jezero crater. Those surprises would be impossible if one goes by SR-SAG2 but become possibilities with the knowledge gaps identified in the 2015 review (SSB, 2015, Review of the MEPAG report on Mars special region)
NASA's purpose and need is too narrowly
defined - it requires the samples to be returned
to Earth for safety analysis - which prevents
them considering a sterilized sample return even
though a sterilized sample return wouldn't need
a safety analysis.
...
So they
use the narrow scope of the needs and purpose
to exclude any alternative that doesn't permit a
safety assessment of the sample to detect if
there is life in it or not before it is returned.
This is your reply:
NASA's purpose and need for the Mars Sample Return
Mission is derived from 1) the overall goals, as directed by the
Executive Branch and Congress, to explore space peacefully
for the benefit of all humankind and 2) NASA's and the
scientific community's specific priorities. The scientific
community has told NASA repeatedly that returning a set of
well-selected samples of Mars to Earth should be one of the
agency's highest priorities. These samples would be a
treasure trove of information, potentially about life on Mars,
but also about the climate history and geologic evolution of
the Red Planet. Additionally, these samples could help us
prepare for sending humans to Mars. Seeking to return such
samples from Mars represents the culmination of a dozen
carefully planned previous missions to the Red Planet across
several decades, which have prepared NASA and its partners
to accomplish MSR safely and successfully
(NASA, 2023, Mars Sample Return FINAL PEIS : B-72)
So you agree your purpose and needs section does exclude a sterilized sample return, but say returning unsterilized samples is a scientific requirement of your mission to return unsterilized samples to Earth. You also say this explicitly here in another comment reply making it clear you are using your purpose and need section to exclude the reasonable alternative of a sterilized sample return.
Sterilization of the samples prior to opening the containment
vessels inside the containment facility is not consistent with
the purpose and need (Chapter 1)
The only reason given for returning unsterilized samples is to establish that it is safe to release them unsterilized to for study outside containment. This is not logical for a pre-sterilized sample return. So there has to be some other reason for requiring it.
In the comment reply the only clue for what this other reason might be is:
Additionally, these samples could help us prepare for sending humans to Mars.
I suggest this because of what I know of the history of this mission. It was motivated by a National Research Council study published in 2002 called "Safe on Mars" as the only paper on astrobiology cited by the decadal review. So it is reasonable to suppose that the motivation is to do with the aim to find a way to send astronauts safely to Mars.
Could it be that the reason here is you think unsterilized samples can be used to prove that it is safe to send humans to Jezero crater in a follow up mission?
If so it should be stated explicitly in the Purpose and Need section. It is the only thing I can think of that makes logical sense of your responses and perhaps you haven't realized it needs to be explained and looked at.
The history of this Mars mission proposal does suggest that as a possible motive. It goes back to "Safe on Mars". This study by the National Research Council in 2002 proposed that NASA establishes zones of minimal biological risk on Mars.
The suggestion was to send a precursor mission to determine if organic carbon is present. If organics were found, at or above the life-detection threshold, the suggestion was to use a sample return to find out if there is life present ( Space Studies Board, 2002. Safe on Mars: Precursor measurements necessary to support human operations on the Martian surface : chapter 5 : 38 ). If no life was found in the sample returned from a region, it would be declared a safe place for humans to land.
However, though Curiosity found organics in 2014 (JPL, 2014, How NASA Curiosity Instrument Made First Detection of Organic Matter on Mars), the organics discovered so far are believed to come from infall from space, and the search for life is far more complex than just investigating the first organics found on Mars.
With our modern understanding of Mars, most organics will NOT be associated with life and never has been alive. Amongst all the organics from space, there may be microenvironments in some places on Mars where life can flourish.
“Safe on Mars'' was also written at a time when the possibility of present day life on the Mars surface was considered to be remote. At the time the surface was thought to have no possibilities for liquid water. This was before
the unexpected discovery in 2008 of perchlorates on Mars (Hand, E., 2008, Perchlorate found on Mars), which made brines possible at lower temperatures,
and many new suggestions for surface potential microhabitats,
These discoveries showed how very localized microenvironments might be on Mars, raising the possibility there could be small microenvironments not yet detected even in places like Jezero crater.
Safe on Mars also doesn't take account of knowledge gaps about transport of life in the atmosphere, especially in the duststorms. This is a matter of very active research at present, as covered in the main open letter under:
So we can no longer think realistically about the simple approach of returning one sample collection to Earth, analysing organics found, and if no native life is present to certify that area of Mars as safe for humans.
It will take a lot of thorough investigation which we can't do with sample returns, to establish whether or not it is safe for the explorers or for Earth to send humans to Jezero crater.
NASA needs to rely on research newer than from 2002 to establish this.
I know that Safe on Mars is not cited in the current paper. But the reason given in the Purpose and Need section for making it a top priority to return unsterilized samples is not logical if the aim is to protect Earth from anything in the samples as it is safer for Earth to return sterilized samples than to return unsterilized samples for safety testing. Given the history of this mission what I described here may be the original motivation for this requirement.
You need to look at the motivation for this requirement in the Purpose and Need section and expand on it and see if it still applies. If it does indeed trace back to the 2002 Safe on Mars paper then the reasoning is no longer valid and the requirement needs to be dropped and replaced by a requirement to do far more in situ exploration on Mars.
Based on what was known at the time, the authors of “Safe on Mars” were so certain that nothing of significance would be found, as the most likely outcome, that they suggested planning for a manned mission should go ahead, even before a sample can be returned. They expected the result of the first sample return to be favorable for a manned mission immediately after it ( Space Studies Board, 2002a, chapter 5: 41).
There has been some concern that if a sample return is required, the planning for the first human mission to Mars may be delayed until a sample can be obtained. The committee believes that, even should a sample be required because organic carbon has been found, a baseline plan for a mission to Mars and even hardware development may still proceed under the assumption that a sample return will not find anything significant enough with regard to Martian biology to invalidate the baseline mission plan.
We can no longer make that assumption today. “Safe on Mars” is one of the main Mars related cites in the Decadal survey which in turn was the original motivation for the Mars sample return mission (Space Studies Board, 2012:157).
It is the only cite in the Decadal survey summary for the sentence:
The elements of the Mars Sample Return campaign, beginning with the Mars Science Laboratory, will provide crucial data for landing significant mass, executing surface ascent and return to Earth, and identifying potential hazards and resources."
Returned samples are also critical for developing appropriate planetary protection protocols for both Mars and Earth.
“Breaking the chain of contact” when leaving Mars is technically achievable for robotic missions, but it is not possible for a crewed mission and potential biological hazards must be determined before humans go to Mars.
However, Perseverance mission is not going to settle questions about the safety for Earth’s biosphere or astronauts of any present day life on Mars, even in Jezero crater.
Perseverance is:
targeting a region of interest for past life rather than present day life – it won’t be able to decide if there are other regions nearby such as RSLs that could produce spores in the dust or caves, or micropores in salt deposits etc or other regions of Mars that have present day life.
is not equipped to search for biosignatures in situ, past or present
is not searching in the right places to look for extant life even in Jezero crater, for instance it is a near certainty that Jezero has the same brine layers that Curiosity found in Gale crater but Perseverance won't be trying to sample these brine layers in the sand dunes (which could be habitats for more capable Martian life)
will return very little by way of dust, no dedicated dust collection - which might potentially carry viable dust from distant parts of Mars – it will have two samples of regolith, that likely contains some dust and whatever dust adheres to the outside of the sample tube walls
won't return much by way of salts, just whatever might happen to be in the two regolith samples, if any - astrobiologists say this is a top priority for searching for extant life on Mars, indeed the only sample return specifically mentioned by Carrier et al.
will have so much biological contamination that extant life is likely to be undetectable anyway at the very low levels expected in a location like Jezero crater
In short, the current sample return strategy doesn’t have a strong focus on extant life, and is not going to return samples from the most likely places to search for present day life even in Jezero crater such as the dirt, salty brine microhabitats or the Martian dust.
Perseverance is also not sufficiently sterilized to approach any region with potential microhabitats for terrestrial life, such as one of the Recurring Slope Lineae, if it finds one in Jezero crater.
In short, the selection of samples returned by Perseverance is not designed to give even a first idea of whether there might be extant life in Jezero crater.
It is far too early for returned samples to tell us anything about potential biological hazards. If we wanted to do that we need to search on Mars for extant life not search for past life and hope that if there is present day life on Mars that just by chance some of it might get into samples selected for the purposes of trying to find out about the past of Jezero crater.
So there is no way we will have advanced significantly in our knowledge of whether there are any biological hazards for human explorers in Jezero crater.
If that our objective is to look for biohazards for human explorers, we should make it an explicit objective, tell astrobiologists that it is the priority and work together to find out what we need to do to resolve the issue. That hasn't been done. There is no mention of this in the Needs and purpose for the mission.
An EIS needs to consider the environmental impacts, and not just the objectives of the agency.
Bear in mind you are legally required to include a "no action" alternative, So you are required to consider an alternative that would mean that none of your science goals are met which is a reasonable alternative.
Similarly you are required to consider alternatives that have potential impact on your science goals. Any rigorous analysis would also have to outline which goals you think it compromises, evaluate the impact on those goals, and then weigh that against the extra protection to Earth of keeping it 100% safe (in this case of a sterilized sample return).
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
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.'
In that passage, the CEQ reasserts that it is not enough to mention reasonable alternatives, they also need adequate consideration.
Looking at the details of National Parks v. Bureau of Land Mgmt,, the relevant EIS did mention many reasonable alternatives but dismissed them because of narrowly drawn up project objectives. The justices ruled:
Agencies enjoy "considerable discretion" to define the purpose and need of a project. Friends of Southeast's Future v. Morrison, 153 F.3d 1059, 1066 (9th Cir. 1998).
However, "an agency cannot define its objectives in unreasonably narrow terms."City of Carmel-By-The-Sea v. United States Dep't. of Transp., 123 F.3d 1142, 1155 (9th Cir. 1997).
In that case the purpose and needs were "(1) to meet long-term landfill demand; (2) to provide a long-term income source from a landfill; (3) to find a viable use for mine byproducts; and (4) to develop long-term development plans for the Townsite." and alternatives were rejected that didn't fulfill all those objectives. The justices regarded those as unreasonably narrow terms.
You use a similar approach of a narrowly drawn up needs section.
These same principles regarding the importance of using terrestrial laboratories to enable the best scientific return also apply to the care and attention to detail that would be required to conduct a proper and comprehensive sample safety assessment in the proposed SRF [Sample Receiving Facility].
You are using the need for a safety assessment for unsterilized samples to reject a sterilized sample return. Your own plans treat sterilized samples as safe for release right away.
You could fix this by re-writing the purpose and needs section to say that you need a proper and comprehensive safety assessment ONLY if the samples are returned unsterilized.
If we prove there is no life in this sample from Jezero crater it does NOT prove that Jezero crater is safe for humans
I don't know if this is a motivation. It is not mentioned anywhere in the EIS that I noticed. But your requirement to return unsterilized samples to Earth in the purpose and needs section might make more sense if it was intended not for these samples but to try to prove that Jezero crater is safe for humans.
If so - no this wouldn't prove anything about safety for humans even in Jezero crater. There could be a small patch of life just one centimeter away from the spot sampled and you wouldn't return it.
There is no substitute for a comprehensive in situ search on Mars.
There's another issue here too, that your safety assessment can't work due to the high level of terrestrial contamination of the samples and because it is impossible to keep out very low levels of life if there are only a few viable microbes That's covered in the open letter here:
There is no need for an MSR Sample Safety Assessment Protocol if all sample are sterilized before they reach Earth
- samples have so much terrestrial contamination at 8.1 ppb there would be virtually no astrobiological interest anyway
- and the
A sterilized sample return will achieve many of your mission objectives. Indeed it is possible that it has no impact on the life detection because the permitted levels of contamination at 8.1 ppb of terrestrial organics in the samples are so high as to make the detection of past or present day life on Mars virtually impossible
Note, NASA is talking about thoroughly mixed contamination here. 8.1 ppb / 0.7 ppb throughout the samples, not just some contamination on the walls of the sample tubes.
Then for geology - the rocks you return are unlikely to have a surface exposure age less than 80 million years, the youngest exposure age found by Curiosity. Perseverance is not able to detect exposure ages as it lacks the necessary instrument.
So in principle very young fresh geological samples could be altered by a sterilization level dose of ionizing radiation. But depending on what level of sterilization is selected (which would need a multi-disciplinary expert panel to assess), it may well be equivalent to less than 80 million years of ionizing radiation. Even if it is more than that, most of the changes such as colour changes of halite and some other crystals will have happened already. There is no change in the isotope ratio.
As I explain in the open letter, Ionizing radiation has little effect on geology - salt crystals change colour but at doses far less than expected for even recently exposed materials on Mars, no changes in crystal spacing and no changes in the ratios of isotopes for radiometric dating after 3 million years equivalent of ionizing radiation (Allen
et al, 1999, Biological sterilization of returned Mars samples). We likely need much more than 3 million years, but no reason to expect any change in isotope ratios and most or all of the specimens except the surface soil / dust / salts would likely have had far more ionizing radiation dose already.
So sterilization does need a rigorous analysis. Based on a preliminary outline it seems that there may be no effect on the science return due to
the high level of forwards contamination
that the samples have likely had sterilization doses of ionizing radiation already (the extra sterilization would be to make sure no present day life survives).
That is why you analyse reasonable alternatives and I hope I've demonstrated that sterilizing all the samples is a reasonable alternative which has potential for
virtually no impact on science return
great simplification in terrestrial handling procedures
no appreciable risk of harm to Earth's inhabitants or the biosphere from the returned samples.
If the public are not satisfied with your plans to protect Earth in 2033, you may well be required to sterilize all samples returned to Earth anyway
If this preliminary analysis is right, sterilization would have virtually no impact on the science return either
NASA's response to my suggestion to greatly enhance the value of a 100% sterile sample return with bonus samples collected in CLEAN containers
We can even greatly enhance the return value with a sterilized sample return with my suggestion of bonus samples collected in CLEAN containers
Second 100% safe alternative, NASA’s proposal can be greatly enhanced in astrobiological value by adding simple capabilities with 100% sterile containers to return a sample of dirt, a highly
compressed sample of gas from the atmosphere to detect minute traces of biologically relevant gases and a sample of dust from dust storms trapped in the filters for the air compressor – these can also be returned sterilized
[quoting from my (Walker, 2022, So many serious mistakes in NASA's Mars Samples Environmental Impact Statement it needs a clean restart : 68)]
Yes outcomes in science and engineering CAN be 100% safe, for instance "no action" is 100% safe for Earth's biosphere
- your reply here again shows a lack of understanding of the basic context and the motivation for these suggestions
No outcome in science and engineering processes can be
predicted with 100% certainty.
(NASA, 2023, Mars Sample Return FINAL PEIS : B-55)
However there ARE 100% safe alternatives such as the "no action" alternative. So this needs closer examination than just to say it's impossible to achieve 100% safety.
For sterilized samples experts are confident we can find a level of sterilization to make them safe. We should be able to sterilize biological entities even if not based on terrestrial biology
It is believed that if such a biological entity exists, humans would be able to kill it (by the sundering of covalent bonds in a rigorous sterilisation process).
Irrespective of the chemical basis of any life-form, a confidence level of sterilization can be provided with only two assumptions: 1) any reproducing life-form must be based on macromolecules (i.e., polymers) with interatomic covalent bonds (not crystal lattices), and 2) since all such bonds have similar strength, destroying these bonds destroys the life-form.
This does need more attention. When it comes to sterilizing potentially alien biology it is something that involves experts in origins of life, synthetic biology and so on. But it does seem feasible to set a level of sterilization using ionizing radiation that we are confident will protect Earth 100%.
Some things are technically possible, e.g. that all the water molecules in my toes happen to all jiggle in the same direction at once and as a result my toes shoot off at supersonic speed. That is a number one could calculate or at least estimate, the "chance" that I lose my toes in this unusual way.
In the same way in principle a radioactive cobalt source might by chance not emit any gamma rays for the duration of the irradiation process. However, that is not a credible scenario. So we need to analyse, what are the possible ways that sterilization could fail? Are any of them credible, and do any of them introduce appreciable risk?
If there is no appreciable risk of failure, it is reasonable to call it informally 100% safe.
With sterilization then it's normally done by estimating the dose needed for a 10-fold reduction in viability. However there comes a point where no organism could survive.
I do voluntary work helping scared people over the internet and it is important to me that we communicate low levels of risk and zero risk in a way that is understood clearly by everyone.
It is also reasonable to look at an alternative that greatly lowers an already small risk. But I think it is reasonable to refer to a presterilized sample return as a way to keep Earth 100% safe.
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 is from the most recent ESF study in 2012:
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
There will be intense public scrutiny of NASA’s plans as it gets nearer to the date the samples return to Earth. If you still don’t have a functioning smoke detector in this analogy you will have to fix this.
This is not like the Apollo era. Back at the time of the Apollo landings there was no understanding of these issues in the general public. Only a few experts like Carl Sagan noticed that the astronauts opened the capsule door in the open sea letting the dust from the Moon fall into the sea the very worst place to contaminate with extraterrestrial life. 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.
Given that sample
return missions of the type proposed for MSR
have never been attempted before, is it even
feasible to do enough testing to assure that a
99.9999% target can be achieved
You reply to that
With regards to the assurance case (HS-
017), no outcome in science and engineering processes can
be predicted with 100% certainty.
This again shows a basic lack of understanding of risk assurance. Some outcomes CAN be predicted with 100% certainty. If the samples aren't returned at all, we can predict with 100% certainty that there will be no harm to Earth's biosphere.
Similarly if you sterilize all the samples returned to Earth, then with an appropriate level of sterilization we can achieve 100% certainty - or at least "no appreciable risk".
Chester Everline then raised an issue with your probability target for containment. This is only for the capsule landing in the Utah sands, not for lab leaks in the Sample Receiving Facility.
NASA applies a 1 in a million chance of containment to three different pathways by which material could escape from Mars and reach Earth.
If those pathways are independent then the overall probability is (1-1/million)^3 or 0.999997. That's 99.9997% containment or about one chance in 333,000 of release.
So which is it? 1 in a million or 1 in 300,000 (approx)? And what is their overall stringent probability target for the entire mission? Is this it or is it something else?
He also says that the passage is confusingly written.
Chester Everline
It is unclear, from a risk
management/environmental impact perspective,
what a stringent probability target is. It is
explicitly stated (in the last paragraph on page S-
11 and its continuation at the top pf page S-12,),
that the MSR Campaign:
. has established stringent probability targets to
drive robust containment engineering;
. selected a target value equivalent to a 99.9999
percent probability of successful
containment;
. applies these targets to each of three material
vectors or pathways along which Mars material
may reach Earth.
With respect to the three material vectors or
pathways, if each pathway has a 99.9999
percent probability of successful containment,
then the probability the MSR Campaign achieves
successful containment is 0.999999 cubed or
99.9997% if the probabilities for each pathway
are independent. If this is the intent it should be
explicitly stated and if the intent is that the entire campaign must have at least a 99.9999 percent
containment probability that should be explicitly
stated.
The comment correctly identifies that the target value is
applied, as stated in the PEIS, "to each of three material
vectors" (pp. S-11 and 3-16) and identifies how an overall
likelihood might be calculated.
The use of high probability
targets for containment assurance is stringent in the sense
that each serves to limit the likelihood of releasing unsterilized
material, consistent with NASA's required approach, where
"preventing harmful biological contamination of Earth's
biosphere is the highest priority" (NPR 8715.24).
NASA allows
but does not require restricted sample return missions to
achieve compliance through demonstration of a specific
likelihood threshold (Section 5.4.2, NASA-STD-8719.27).
To
demonstrate compliance with NASA planetary protection
standards the MSR Program has developed and continues to
refine an Assurance Case, which provides quantitative data
on the performance of the as-flown systems in terms of
containment likelihood as described in the PEIS (pp. 3-16 and
3-17).
It doesn't make a lot of sense They say that by stringent containment they mean they applied stringent containment to each of the three pathways - but that they don't have an overall containment target. They say that NSAA doesn't require missions to have a specific likelihood threshold.
From this it's clear that NASA is attempting to do risk assurance here without setting a specific likelihood threshold for containment for the overall mission.
The passage Chester Everline commented on is still confusing and doesn't make it clear, the first sentence is most naturally understood as a 1 in a million chance of successful containment
The MSR Campaign selected a target value equivalent to a 99.9999 percent probability
of successful containment. These targets are applied to each of three material vectors
Mars Sample Return Campaign Programmatic EIS
S-12
or pathways along which Mars material may reach Earth: 1) free particle transport; 2)
approach, entry, and descent; and 3) landing.
(NASA, 2023, Mars Sample Return FINAL PEIS : S-11 - S-12)
[It is not clear to the reader that this is just a probability target that they use for some basic events such as these three pathways without any overall campaign wide mission target]
NASA clarifies in their replies to Chester Everline that there is no overall mission likelihood target but haven't edited this passage to make it clear that they aren't using an overall mission likelihood target.
Chester Everline mentions the idea of doing in situ studies first on Mars. This is another way to archive 100% certainty that there will be no harm to Earth's biosphere:
Thus there is a trade here, involving sending
scientific instruments with limited capability to
Mars - which has essentially unlimited material to
sample and analyze, or returning about a half
kilogram of Mars material to Earth (where there
is an abundance of analytical science
instruments and skilled scientists to operate
them) with the understanding that ultimately
more samples will likely be needed.
Even if such
possibilities have already been considered and
discarded as infeasible, adding a paragraph to
the MSR PEIS summarizing this and citing the
appropriate references would assuage concerns
that the MSR PEIS has too narrow a focus.
But that is a mistaken reply. The "no action" alternative doesn't mention deferring the mission.
Under the No Action Alternative, the MSR Campaign as described in this PEIS would
not be undertaken. As a result, investigation of Mars as a planetary system would be
limited due to the cost and complexity of sending instruments into space or to Mars for
in situ analyses. By not undertaking the MSR Campaign, scientists would not have
access to the full breadth and depth of analytical science instruments available in Earth
laboratories.
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
Chester Everline said that they should rest their case on the Mars meteorite argument - which we know is false.
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 demonstratedthe 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
...
If the MSR Campaign is
unable to convincingly demonstrate that the risk it poses to Earth is not less than an analog
natural hazard the risk from MSR should be considered unacceptable. If the MSR Campaign can
convincingly demonstrate the risk it poses to Earth is less than an analog natural hazard, then
returning samples using MSR is analogous to having another Mars meteorite impact earth. The
MSR assurance case should focus on this.
Indeed in my literature search the most recent study I found suggesting returning samples from Mars in favour of in situ study was from 2002. I can't find any papers or published interviews since then that recommended a sample return as a priority either for present day life or past life. What changed since 2002 is
Tremendous miniaturization of life detection such that we can send instruments for in situ life detection to Mars that used to be far to heavy to be practical
Huge increase in complexity of our understanding of Mars
Recognition that present day Mars has numerous potential microhabitats and that if life is present there it may be very localized and past life also may be very hard to detect.
As a result we do not know enough to intelligently select samples to return for either past or present day life until we can detect it in situ.
In situ exploration is such a clear winner here for the search for life for the very reason Chester gave. We do have the capability to detect life in situ on Mars at least if it resembles terrestrial life, including the ability to detect organics with exquisite sensitivity, one amino acid per gram for astrobionibbler, and test for microbial respiration and metabolism remotely on Mars (which doesn't require us to be able to cultivate it). So we CAN send instruments to Mars that are able to do preliminary searches and we don't need to return every gram of material back to Earth to search for it here first.
If we look for life in situ on Mars, our mission has essentially unlimited material to analyse. The issue with returning a small sample without in situ life detection is we don't have a way yet to intelligently select the samples that may have past or present day life in them since unlike the situation on Earth, even microbial life on Mars past and present is likely to be rare and hard to detect.
While organics from infall from space are expected to be abundant and present almost everywhere on Mars, indeed the main thing to explain is why we don't see more of it.
Let's take an artificial scenario to show the idea. Suppose there are small patches of life on average every 10 meters throughout the surface of Jezero crater.This is right up at the high end of habitability for the crater. Suppose each patch is 10 centimeters in diameter. Suppose them distributed in a square grid pattern for simplicity. Then the chance that one at least of Perseverance's two samples of regolith samples a patch of life is about 2% or 1 in 50.
It's a similar picture for life in the dust. In reality the chance of returning viable life in the samples may be well below that illustrative 2% figure. It is possible that it's higher than that, if you take a very optimistic view and believe that Viking discovered viable life already in the 1970s, or that there is viable life, in the regolith almost everywhere - perhaps blown there in the wind and protected from UV in propagules that are adapted to Mars conditions. But the majority view here is that if there is viable life on the surface of Mars we likely have to search some time to find it.
For past life. the biosignatures have likely been degraded, by corrosive chemicals, been leached out, it takes special conditions to deposit it, it will be mixed with organics from infall from space. It might not have been abundant originally, and there's the ionizing radiation.
So for past life we need to be able to dig or at least to visit recently excavated craters and may have to search several such craters or outcrops and in many places until we find a patch of past organics that survived unaltered for 3 billion years, originally had life in it, and still has organics from past life.
So yes, such ideas have been considered before. Not only that. A white paper submitted to the decadal review by astrobiologists emphasized the need to be able to detect life in situ before we can intelligently decide which samples to return
We feel that organic detection efforts over the next two decades via investment into advanced in situ robotic instrumentation are fundamental in support of a future intelligent MSR mission.
Currently, MSR is regarded by much of the scientific community as largely weighted towards a technology demonstration as the rationale for good astrobiology will not be apparent until we discover more about our neighboring planet.
1. MARS SAMPLE RETURN (MSR) SHOULD ONLY BE SUPPORTED AFTER THE PRESENCE OF BIOMARKERS HAS BEEN CONFIRMED .
Mars sample return missions would eventually allow for high precision measurements to be conducted with higher sensitivity, accuracy, and greater scope than is possible with in situ instrumentation. The major scientific drawbacks of such mission architectures would be the low achievable sample return masses (~350 grams), the fact that any returned sample(s) would only probe a minute geographical area on Mars, and the fact that no unequivocal evidence of biosignatures has yet been obtained to ensure that the returned sample would address the potential detection of extraterrestrial life.
There are serious community reservations about a rush to commit valuable scientific resources and funding to MSR until a valid scientific discovery has been made to justify investment – the in situ detection of localized biosignatures and an attempt at characterization of spatial variability as a function of depth or mineralogy would make a strong case as a valid scientific rationale on which to pursue expensive sample return ambitions. We feel that organic detection efforts over the next two decades via investment into advanced in situ robotic instrumentation are fundamental in support of a future intelligent MSR mission. Currently, MSR is regarded by much of the scientific community as largely weighted towards a technology demonstration as the rationale for good astrobiology will not be apparent until we discover more about our neighboring planet.
Bada et al. specifically recommend "follow the nitrogen". This is an essential atom for terrestrial life as it permits bonds that can be broken easily for life processes. But Mars doesn't have widespread inorganic nitrate deposits.
So - they suggest looking for organics associated with nitrogen.
It has been argued that while there are numerous abiotic pathways to carbon chemistry,
the presence of nitrogenous compounds is specifically diagnostic for biogenicity on Mars, a planet that
lacks widespread inorganic nitrate deposits [Capone 2006]. We endorse here a variation of the Follow the
Nitrogen approach in which chemical characterization of highly specific nitrogenous compound classes
would provide a method for unequivocal biosignature detection.
That by itself wouldn't be enough to detect samples suitable to return to Earth. They go on to suggest we look specifically 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 - either all the same as the terrestrial amino acid or all its mirror image. Amino acids on the surface or near the surface would soon be degraded by cosmic radiation but if buried sufficiently deep enough may remain to be diagnostic of likely life.
They say that we need to be able to detect low parts per billion or parts per trillion of amino acids.
Diagenetic pathways may have acted to degrade organic compounds over time due to the oxidizing
surface conditions on Mars [Benner 2000]. For this reason, it is paramount that technologies exist for
highly specific quantification of the target biomolecular compounds at trace levels, equivalent to low
parts-per-billion (ppb) or parts-per-trillion (pptr) sensitivity.
Bada et al were involved in developing the Urey in situ life detector instrument package for ExoMars which sadly was descoped. So this next paragraph is based on their experience with field trials of Urey. They find that there are incredibly pronounced variations in biodensity at both the macroscale and the microscale.
Field studies carried out in 2005 as part of
Urey instrument development efforts have shown that in extremely arid locations like the Atacama
Desert, variations in biodensity are incredibly pronounced on both the macroscale and microscale [Skelley 2007]. If similar levels of biological heterogeneity were expected at one time on Mars, then it is
probable that biosignatures could remain elusive during in situ investigation if instruments with
inadequate sensitivity were utilized. Similarly, selection of a limited sample size could result in a null
result for life detection during MSR missions and poses a high risk of ultimate failure
So even if there was life there in the past with similar abundance to the Atacama desert we would likely not find it unless the in situ instruments are sufficiently sensitive.
As for returning life, if we return only a few samples we likely miss it.
Then they stress the importance of the ability to drill for past life to find samples that still have recognizable biosignatures without too much surface ionizing radiation.
Drilling to the greatest depth possible will
allow for the greatest chance of success of detecting organics and potential biosignatures on Mars[Kminek & Bada 2006]. The 2011 MSL includes capabilities to drill centimeters deep within surface
rocks while ExoMars, set to launch in 2018, includes a sample drill that will provide capability to probe
up to ~2 meters depth within the regolith.
Returning samples before then is a gamble which in the worst case is going to return ambiguous samples that don't resolve any of the main questions in astrobiology. Bada et al were unambiguous in their recommendation to the Decadal survey "it is not yet time to start down the MSR [Mars Sample Return] path". They said we do not yet know enough to intelligently select samples to return.
In this White Paper we argue that it is not yet time to start down the MSR [Mars Sample Return] path. We have by no means
exhausted our quiver of tools, and we do not yet know enough to intelligently select samples for possible
return. In the best possible scenario, advanced instrumentation would identify biomarkers and define for
us the nature of potential sample to be returned.
In the worst scenario, we would mortgage the exploration program to return an arbitrary sample that proves to be as ambiguous with respect to the search for life as ALH84001.
That was the most current astrobiological advice you had available to you when you selected the Mars Sample Return mission as your top priority for the next two decades (as you acknowledged it couldn't be completed in one decade).
Future missions would therefore benefit from the development of instruments capable of direct and unambiguous detection of extant life in situ, and improvements are needed in capabilities for sample preparation to optimize biosignature detection. Spacecraft resources should support a sufficient number of sample analyses to support replicate analyses, positive and negative controls.
Contamination control should be coupled with contamination knowledge so that Earth-sourced material can be eliminated as a possible source of any biological material discovered in Martian samples.
The Mars community, in their inputs to the decadal survey, was emphatic in their view that a sample return
mission is the logical next step in Mars exploration.
Mars science has reached a level of sophistication such that fundamental advances in addressing the important questions above will come only from analysis of returned samples.
As we saw, Bada et al, in the only white paper on the topic submitted to the decadal review, said the opposite of this.
In this White Paper we argue that it is NOT YET TIME to start down the MSR [Mars Sample Return] path.
But this point of view is not mentioned. The mission is intended as an astrobiological mission but right from the outset your team didn't listen to what the astrobiologists said and didn't report what they said to the public.
In short Bada et al said fundamental advances in astrobiology are highly unlikely to come from analysis of returned samples. They said it is essentially a gamble to return samples that were not selected for life in situ first and that the most reliable way to find life on Mars is to search for it in situ.
However the team who processed these papers never noticed or at least never mentioned these points. Instead, they relied on research already a decade old at that time, Safe on Mars from a time with a much simpler understanding of Mars and less capable instruments for in situ studies (Space Studies Board, 2002,
. Safe on Mars: Precursor measurements necessary to support human operations on the Martian surface. , chapter 5: 38) and even then it said that:
"If such capabilities were to become available, one advantage is that the experiment would not be limited by the small amount of material that a Mars sample return mission would provide. What is more, with the use of rovers, an in situ experiment could be conducted over a wide range of locations."
The instruments were already far smaller and more capable just 7 years later at the time of the paper by Bada et al. Since then astrobiological instruments continued to get smaller and more capable, while our understanding of past and present day habitability of Mars gets more complex. The now overwhelming case for in situ study for astrobiology continues to get stronger.
We now have instruments that can do almost all the in situ life detection on Mars. You even have a report on their capabilities for your proposal to send a miniature life detection lab to Jupiter's moon Europa which includes a long list of instruments able to do in situ life detection on Europa. The team concluded:
The Europa Lander mission concept is designed to achieve ground-breaking science. The SDT (Science Definition Team) is confident that a payload matching or exceeding the requirements described herein could potentially reveal signs of life on Europa (Hand et al., 2017, Report of the Europa Lander Science Definition Team : xi).
The Europa lander team also had a self-imposed restriction on the life detection instruments they permitted to be included as it set the requirement that they ALL must be dual purpose, able to provide valuable information about the chemistry or geology even if there is nothing found of biological interest.
"Life-detection experiments should provide valuable information regardless of the biology results"
This meant they couldn't include instruments that are only of interest for searching for life, such as tests for microbial respiration though they could include experiments that were dual purpose that could also be used for geological studies. A miniature lab above GEO wouldn't be restricted in this way, we can send instruments to the lab specifically designed to search for life which would tell us nothing of geological or chemical interest. It would also have the advantage that materials such as headspace gases can be returned to Earth sterilized for further analysis.
That's included in my attachment 8 for (Walker, 2022, Comment posted December 20th). However your 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.
So yes, based on what many astrobiologists have written, in situ is far better. I haven't actually found any papers by astrobiologists arguing that for their discipline a Mars sample return is better than an in situ search, at least since Safe on Mars, except as a technology demo for future missions we can do once we have a better understanding of what we need to return.
So it is most likely a technology demo for astrobiology than a mission likely to resolve central questions, about past or present day life. However we can make it the best technology demo we can and do our best to make it to optimize the chances of returning something of interest to help advance our understanding of present day life, or present day chemical conditions on Mars at the level of detail needed for astrobiology and past life, or chemical conditions in past sample on Mars at the level of interest for astrobiology. For past life samples we need ideally for the samples to be so clean we can detect parts per trillion of organics.
That's what my bonus sample suggestions are about.
Atmosphere compressed into a clean container - this will help detect trace gases that will be quite impossible to detect in the small amounts of atmosphere in your non sterilized sample tubes.
Dust - on Earth anyway, we detect life from as far away as the Gobi desert in Japan. If there is life on the surface of Mars even far away, then some viable or dead life may get into the dust at times and may be detected if we collect a reasonably large sample of dust, if only a few cells or propagules per gram or less. We get the dust almost for free with the atmosphere compressor, running it in a cycle to collect dust after the atmospheric sample is collected. It could also come from closer by, caves, microhabitats like the RSLs possibly novel undetected microhabitats, salts with micropores, biofilms exploiting the brines Curiosity found.
Salts - if it is possible to return salts. Astrobiologists say these are top priority for preserving present day life, also can help provide habitats for them.
Dirt - we still don't have a complete explanation of what Viking found. Neither the life nor the chemical explanations can explain everything. We need to understand this to make progress and know the next questions to ask. Then - there may well be interesting biochemistry in the dirt
A pebble from a recently excavated crater.
All the other samples except the salt and the pebble can be collected in situ around the lander. The pebble is a challenge - it could be collected nearby but bound to have a large exposure age. The salts - maybe some in the regolith but in small quantities - they are rarer in Jezero crater than Gale crater.
However, NASA plans to send two marscopters with the ESA lander as a backup.
The helicopters would be a backup option if something went wrong with Perseverance. The sample return lander would settle close to where Perseverance had dropped the rock samples on the ground, sealed within tubes about the size of cigars. The helicopters would then fly the samples back to the lander.
So it can certainly pick up an unsterilized pebble instead of a sample tube - perhaps at the end after it has already ferried over all the sample tubes. Perhaps it can be adapted to pick up a scoop of salt if there is any within a few hundred meters. It will have little wheels to travel short distances on the ground and a grapple. The 700 meters would give quite a large area it can explore to find interesting small rocks to return unsterilized to study above GEO.
It can in principle travel a long way. This would depend on how far it can communicate. It traveled over 700 meters on April 8, 2022 (NASA, 2022, Ingenuity Mars Helicopter's Record-Breaking Flight). At that rate it can travel 7 kilometers every ten days, as it's solar powered. Otherwise we are limited to whatever it can pick up within flying range of the lander. If it can communicate with the lander far as 7 kilometers, or perhaps to / from orbit (??) perhaps we could target the lander to land within flying range of a recently excavated crater in Jezero crater?
This is the passage you quoted from my attachment:
This paper recommends that the ESA fetch rover adds a dust sample, originally planned for Perseverance. This could be used to search for dust-storm resistant Martian propagules which could be transported in Martian dust storms. It can be combined with a large volume compressed atmosphere sample to greatly increase sensitivity for biosignatures in the atmosphere
A sample fetch rover is no longer part of the planned MSR Campaign architecture. The sampling hardware and procedures regarding sample collection and processing for
the MSR Campaign are already in place on Mars; the planned MSR Program would simply collect the existing sealed sample tubes and return them to Earth (see Section 2.1.2 for discussion of current architecture)
B-56-57)
Your response is to refer to a previous response AL-004
Modification to ESA fetch rover sample retrieval
arm to dig an extra sample of dirt as for the
Viking scoop and add it to a smaller 100% sterile
container within the Orbital Sample Container.
AL-004
Refer to the previous response for AL-004.
Walker 0254-A7
Proposal to use the Marscopters to search for
young undegraded craters that could have
exposed rocks from 2 meters or more below the
surface in the last few tens of thousands of years - this greatly increases the chance of a sample
of past life of enough interest to be of
astrobiological value
The proposal is NOTHING TO DO WITH HOW THE SAMPLE ARE SELECTED except for the proposal to search for a recently excavated crater for the sterilized pebble.
The issue is that NONE OF YOUR SAMPLES ARE CLEAN ENOUGH FOR ASTROBIOLOGY which is the reason for the reasonable alternative of adding bonus samples in clean containers.
This response shows no awareness or understanding of any astrobiological motivation for clean samples. Yet your iMOST team stresses the importance of reducing contamination.
My proposal is for an atmospheric compressor to compress a clean sample of atmosphere and a sample of dust. This is something we can add to a stationary lander.
This is intended as a reasonable alternative to consider. You are excluding a reasonable alternative improperly just by saying that it isn't in your current plans.
If this was an astrobiology mission then this proposal would be of high importance to consider.
This suggestion needs to be seen by experts with the ability to evaluate the science value of this proposal.
Your examples of previously approved BSL-4 labs do not have protocols designed to contain alien life of unknown biology
NASA’s draft EIS 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.
...
Indeed, the draft EIS 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.
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.
The key word here is "known infectious substances". Here we are talking about potentially unknown substances that could include mirror life, for instance or fungal pathogens. Many terrestrial diseases can't be contained by use of quarantine, but aren't infectious enough for that to matter or are already everywhere in the environment like tetanus or Aspergillus fumigatus.
We can't contain an unknown harmful organism which we don't even know is related to terrestrial life. Try designing a protocol to contain mirror life that is able to set up home in a human microbiome and hasn't yet been identified as such. Or try designing a protocol to keep out an alien fungus that is able to live in the human microbiome. It can't be done with current technology.
Then try to do it so that it also contains the very tiny ultramicrobacteria.
So there are challenges here that a normal biosafety lab doesn't encounter ever
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
That's included in my attachment 8 for (Walker, 2022, Comment posted December 20th). However your 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.
You do no independent study of the Sample Receiving Facility in this EIS leaving this as a detail to be worked out later.
Your reasoning relies on submitted final Environmental Impact Statements for other biosafety level 4 laboratories.
NASA's team concludes:
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 draft EIS]
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 . 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.
Cites:
NIH/DHHS. (2005). Final Environmental Impact Statement National Emerging Infectious Diseases Laboratories, Boston, Massachusetts. Bethesda, MD: National Institutes of Health, U.S. Department of Health and Human Services.
DHS. (2008). National Bio and Agro-Defense Facility Final Environmental Impact Statement. Washington D.C.: U.S. Department of Homeland Security
[My comments in red]
In this quote, I draw your attention to the sentence:
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 have shown that the risk to the public is negligible
This is not referring to any analysis that you have done. It just refers to analyses done in previous biosafety level environmental impact statements which were impact statements for the task of containing known types of human disease of a known form of biology, terrestrial biology and with known capabilities or expected capabilities.
Third 100% safe alternative to this mission:
return geological sample tubes sterilized to Earth - and return unsterilized astrobiological samples
to a high orbit to study remotely using miniature
life detection instruments like those designed by
astrobiologists to send to Mars - even a microbe
as risky to Earth's biosphere as mirror life can be
studied and cultivated safely in a suitable high
orbit.
Suggestion: the geological samples can be
sterilized and returned directly to Earth and the
suggested dust, atmosphere and dirt samples
collected in 100% sterile containers can be
returned to a satellite above GEO for the
astrobiological studies.
There is no need to do the MSR Sample Safety Assessment Protocol if all samples are examined unsterilized in orbit and are sterilized before they reach Earth. That’s because there wouldn’t be any need for a Sample Receiving Facility, except as a place to store sterilized samples.
B-54
NASA's response to this is
Refer to the previous responses for AL-001 and AL-002
AL-001 As discussed in Section 1.3 of the PEIS, the complexity and cost of sending advanced instruments to study Mars in place (in situ) would restrict the scope and detail of the science that could be done; many important classes of scientific instruments are not amenable to the miniaturization and ruggedization that would be necessary to operate from a spacecraft. An important aspect of this is that many critical measurements can only be done on samples that have been through intricate sample preparation processes, and most of those processes are not able to be automated. Additionally, Section 2.3.1 of the PEIS discusses the limitations associated with a remote or in-orbit sample safety assessment, which was an alternative considered but not carried forward.
(NASA, 2023, Mars Sample Return FINAL PEIS : B-30)
However I already address those points in my proposal which you haven't noticed
The sensitivity and accuracy of
Mars Sample Return Campaign Programmatic EIS
instruments operated in microgravity is much lower than similar instruments on
Earth
(NASA, 2023, Mars Sample Return FINAL PEIS : 2-25 to 2-26)
In my proposal the instruments are NOT operated in microgravity. They are operated in Mars gravity in a Mars simulation centrifuge similar to the centrifuge used in the ISS.
there is a significant chance of “false negatives” if
the SSAP is not done properly (i.e., declaring that the Mars samples are not
hazardous when they could be).
In my proposal all samples returned to Earth are sterilized. There is no risk of a false negative. The samples are treated as hazardous until we know more about Mars by in situ studies and later sample returns.
I also cover those issues with using your returned samples for safety assessment in my "So many serious mistakes" attachment under:
Problem of microbial dark matter - we don’t have a census even of all the RNA and DNA that we sent to Mars in the Perseverance sample tubes - which likely contain many genes from species we haven’t yet sequenced
(Walker, 2022, So many serious mistakes : 189)
Many entire phyla are only known through a small rRNA fragment of their protein factory - specifically the rRNA component of the 16s ribosome subunit
(Walker, 2022, So many serious mistakes : 190)
The Perseverance clean room had many uncultivable species, 36 out of the 41 species identified by their 16s ribosome subunits were found in only one location - and 4 had ribosomes that didn’t closely resemble any previously known ribosome
(Walker, 2022, So many serious mistakes : 193)
If this level of diversity can be generalized to the tubes, each sample tube could contain unique 16s subunits not found in any of the other sample tubes and out of 38 sample tubes three or four of them may contain subunits that don’t closely resemble any ribosomes so far known on earth, although originating from earth
(Walker, 2022, So many serious mistakes : 194)
Those sections are not discussed in the response to public comments, presumably dismissed as "nonsubstantive". But they are substantive and you will find you have no answers to them if you consider these points.,
Remote sample analysis would be exceedingly complex, especially if automated,
and would include the need for destructive reopening of multiple tubes, posing a
significant threat to major efforts made over more than a decade to maintain the
scientific integrity of each of the samples.
In my proposal Perseverance's sample tubes are sterilized without opening them. This sterilization would have no or virtually no impact on the science interest since they have already been subject to such high levels of ionizing radiation that any sensitive geological crystals have already been altered, and any recognizable past organics related to life or prebiotic processes are already reduced to less than 0.1 ppb and will be impossible to detect against the signal of the 8.1 ppb of terrestrial contamination. The chance of detecting present day life is virtually zero again because of the contamination.
If it was thought important to look at some of the samples unsterilized for some reason - perhaps because Perseverance returns a sample from a recently exposed crater - then we need to work on ways to open it above GEO and do all the analysis that's needed when they are opened above GEO. But in this proposal we already have a suite of sensitive life detection instruments present above GEO to examine them.
Otherwise, the orbital lab is used only for examining the bonus samples of dirt, salt, dust and atmosphere for astrobiologists.
Additionally, a positive result from the SSAP
represents a potential hazard to crew health within a small, enclosed system,
plus a contaminated facility that will eventually need to be returned to Earth (or
will fall to Earth if there is a system failure). Similarly, a failure of sample
containment at a lunar base could lead to onerous requirements for
decontamination protocols for future travel between the Earth-Moon system
(NASA, 2023, Mars Sample Return FINAL PEIS : : 2-26)
This is why in my proposal the samples are returned to a miniature life detection lab above GEO and humans never go near it.
Designing, flight-qualifying, and
launching appropriate instruments of analysis to be operated by non-expert crew
members would be a major challenge
(NASA, 2023, Mars Sample Return FINAL PEIS : : 2-26)
These are instruments operated remotely by expert scientists just as they would for a life detection mission on Europa but with much lower latency. Many of the instruments are already built / tested at various degrees of preparedness. They wouldn't be used for just this one mission. Instead this mission is an opportunity for universities to flight test their instruments which can be sent later further afield to Mars, Europa, Ceres, Enceladus or wherever we wish to send in situ life detection instruments.
Such other orbital or lunar structures that could
potentially be used instead of the ISS are not yet constructed and may be subject
to delays such that the MSR Campaign cannot reasonably plan to use them.
(NASA, 2023, Mars Sample Return FINAL PEIS : : 2-26)
This is based on an assumption that it is returned to an orbital structure with human technicians. We can send a new satellite to above GEO with no delays, we can easily have one ready to fly by 2033 if we start work on it this decade.
We have already miniaturized numerous instruments that can search for life in situ. Already in 2016 the scientists in the team concluded:
The Europa Lander mission concept is designed to achieve ground-breaking science. The SDT (Science Definition Team) is confident that a payload matching or exceeding the requirements described herein could potentially reveal signs of life on Europa (Hand et al., 2017, Report of the Europa Lander Science Definition Team : xi).
You exclude any alternative that doesn't return unsterilized samples in your Programmatic Alternative Screening Criteria.
The basic reason given is that they have to be capable of doing "safety assessment". But we saw in the previous section that all the samples will go to Hold and Critical review anyway. See above:
So that's an unachievable objective and you are using it to exclude reasonable alternatives that keep Earth 100% safe.
Also the details are not accurate. You require that ALL tests we could do on Earth can be done in any alternative. But a reasonable alternative isn't required to be able to achieve all the things in your mission plan. There may be a trade off between safety for Earth and the experiments you can do.
It is a reasonable alternative to consider if it has fewer experiments but with 100% safety for Earth (no appreciable risk).
However your evaluation is also based on a source that is out of date and was also incomplete. For some reason your iMost report pays little attention to the in situ instruments already designed such as LDChip and astrobionibbler, neither of those mentioned. The term "microfluidics" doesn't occur in the iMOST report which has been central to the miniaturizing of instruments. The term "antibody" also doesn't occur which is central to the functioning of LDChip because of the remarkable sensitivity of polyclonal antibodies which let them detect a previously undetected microhabitat in the hyper-arid core of the Atacama desert.
Your iMOST team's report was published before the Europa lander report.
You should consider the Hand et al., cite for many instruments not mentioned in Beaty et al.: Beaty et al. has no mention of
superresolution microcopy
Raman microscopy coordinated with optical microscopy
fluorescent dyes that
bond to specific macromolecules such as lipids, proteins and nucleic acid.
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.
"Life-detection experiments should provide valuable information regardless of the biology
results"
But we don't need to set such a requirement for the lab above GEO and we need to get away from this limitation to do a thorough in situ search on Mars.
As mentioned already, your 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.
By relying solely on a report from 2017 that didn't attempt a survey even of the instruments already suggested for in situ analysis on Mars, and published too late to take account of the extensive study of in situ instruments for Europa, your EIS doesn't have an adequate consideration of the possibilities for in situ analysis on Mars.
I provide these cites in my attachment 8, that I supplied to the final PEIS. But because you dismissed it as "nonsubstantive" you never got to see those cites.
This is the relevant section of the EIS:
Alternatives must be able to accommodate the equipment required to conduct the
proper analysis to meet MSR Campaign objectives (which include not only
science but also a properly rigorous assessment of the biological safety of the
samples). 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):
Complex sample preparation. Several of the high-priority investigations would
involve sample preparation procedures (e.g., creating very thin slices) that would
be too complicated for in situ missions. The procedures to do this in terrestrial
labs are well established, but the ability to conduct similar sample preparation
procedures on Mars does not currently exist nor is likely to exist in the future.
Instrumentation that would not be suitable for flight to Mars. Many types of
scientific instrumentation would not be compatible with mounting on a Mars
Lander because the equipment is too large, requires too much power, requires
too much maintenance, involves complex procedures, or a combination of these
factors.
Lack of instrument diversity. In situ missions to date have been limited to 5 to
10 scientific instruments. However, terrestrial labs could analyze returned
samples using at least 50 to 100 instruments, including future instruments that
have not yet been designed. This could significantly amplify the ability of
scientists to make initial discoveries and to respond to initial or unexpected
discoveries with follow-up tests that are not currently able to be envisioned. Such
complementary measurements would significantly increase the degree of
definitiveness to which a scientific question could be answered (which commonly
is dependent on whether a preliminary result could be confirmed by a different
kind of measurement).
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. 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.
Some are exquisitely sensitive able to detect a single amino acid in a gram of sample. One of the most challenging to miniaturize is the gene sequencer. But NASA are collaborating in development of the gene sequencer SETG that would work as far away as Jupiter's moon Europa (Carr et al., 2020, Nanopore sequencing at Mars, Europa, and microgravity conditions). 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)
If we look at the proposed list of life detection experiments given by iMOST we see that some can now be done with miniaturized instruments. We also see that some of the ones that couldn't be done as far away as Europa COULD be done with a small life detection lab above GEO because we can return sterilized materials from it to Earth for analysis.
For instance, it is correct that if we use labelled release as for the Viking experiments, we can only analyse radioactive headspace gases. We would want to use isotopes of nitrogen, sulfur etc that aren't radioactive to track where other elements go and these would need to be returned to Earth for analysis.
However, sterilizing the headspace gases wouldn't change the isotope ratios. So if we do respiration experiments and gather headspace gases, we can sterilize those gases and return them to Earth for analysis and still be able to find the isotope ratios in the headspace gases.
If we are able to grow life from the samples, we can then return those microbes sterilized for detailed study but just can't return them unsterilized which is as one would expect.
We can still do a huge amount of in situ life detection in the miniature lab above GEO if we are lucky enough to return detectable life with the first samples from Mars.
This is another clear example of a confusion that could never occur if we were talking to planetary protection experts as previously understood or if NASA's Mars Sample Return Team had anyone to answer our public comments with an understanding of the most basic concepts of containment for biosafety laboratories.
My comment
Draft 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”
The 2012 European Space Foundation study says its 0.05 micron size limit needs to be reviewed regularly – this alone is sufficient reason to halt this EIS process until the new size limits review is done.
(NASA, 2023, MSR FINAL PEIS : B-63)
[emphasis added in red, they may not have noticed the " larger than 0.05 μm" qualification or the requirement to review the size limit regularly]
NASA's team responded to this statement saying
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.”
They say here that they are of the opinion that because a HEPA filter can achieve better than 99.97% for smaller particles that their Environmental Impact Statement doesn't need to mention the recommendation in the ESF study that the facility shouldn't permit release of a single particle larger than 0.05 microns.
It is clear from this that
NASA are not challenging the European Space Foundation's recommendation. They accept it but it is their opinion that HEPA filters can already achieve this level of containment.
HEPA filters are certainly not CERTIFIED for 100% containment at any particle size so they plan to use them for a task they are not certified to work for and hope they would work.
Beyond that point it is a little hard to follow their logic. But they
may be of the view that the ESF requirement was to achieve 100% for isolated single particles at 0.05 microns only.
The NASA engineers
may have missed the "larger than 0.05 microns" qualification and been of the opinion that the authors of the ESF study were only concerned about 100% containment of ultramicrobacteria and not of 100% containment of larger particles.
This is only conjectural. But if that's the reason for the error, it's understandable for engineers looking just at figures and not considering the rationale behind figures.
It would however show no understanding of the rationale behind the figure, to contain ultramicrobacteria that can pass through 0.1 micron nanopores. Suppose theoretically you could achieve 100% containment at 0.05 microns but not at any larger size, what use would such a filter be to contain ultramicrobacteria??
Such a filter is not going to contain ultramicrobacteria that attach themselves to larger particles. That is indeed a situation one might expect for samples from Mars. If they did contain ultramicrobacteria, they would likely often be attached to larger dust grains or sand grains.
Whatever the reason for the mistake, it is a clear example of issues that can arise when engineers use figures from a paper without a basic background in the concepts described in those papers.
You go on to tell me that the details of how NASA will use HEPA filters to comply with the ESF requirement to contain 100% of particles at 0.05 microns will be resolved at Tier 2.
Requirements associated with the SRF [Sample Receiving Facility] (to include management of particle size under the conditions required for sample curation) would be addressed in the Tier II phase of the NEPA process.
As I understand it from the NEPA requirements this terminology means you see it as a detail that doesn't need to be looked at until you get to the detailed work on the Sample Receiving Facility.
Agencies should tier their environmental impact statements and environmental assessments when it would eliminate repetitive discussions of the same issues, focus on the actual issues ripe for decision, and exclude from consideration issues already decided or not yet ripe at each level of environmental review. Tiering may also be appropriate for different stages of actions.
In more detail
Section 1508.28 Tiering.
"Tiering" refers to the coverage of general matters in broader
environmental impact statements (such as national program or policy
statements) with subsequent narrower statements or environmental
analyses (such as regional or basinwide program statements or
ultimately site-specific statements) incorporating by reference the
general discussions and concentrating solely on the issues specific to
the statement subsequently prepared. Tiering is appropriate when the
sequence of statements or analyses is:
(a) From a program, plan, or policy environmental
impact statement to a program, plan, or policy
statement or analysis of lesser scope or to a site-specific
statement or analysis.
(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.
if the required technology doesn't yet exist to achieve the recommendation of the European Space Foundation
this is an issue of broad scope that needs to be looked at in the EIS itself
rather than an issue of lesser scope that only needs to be decided for site specific plans for the Sample Receiving Facility.
So, let's look more closely at this, what the ESF recommend, the rationale for their recommendation, and why a standard HEPA filter can't be expected to fulfill that requirement.
This is how the 2012 ESF report explained its decision at the time.
The value for the maximum particle size was derived from the NRC-SSB 1999 report ‘Size Limits of Very Small Microorganisms: Proceedings of a Workshop’, which declared that 0.25 ± 0.05 μm was the lower size limit for life as we know it (NRC, 1999). However, the past decade has shown enormous advances in microbiology, and microbes in the 0.10–0.15 μm range have been discovered in various environments. Therefore, the value for the maximum particle size that could be released into the Earth’s biosphere is revisited and re-evaluated in this report. Also, the current level of assurance of preventing the release of a Mars particle is reconsidered.
The European space foundation said we have to contain ultramicrobacteria and gene transfer agents - the ESF in 2012 updated this 1999 requirement of containment of 0.2 microns to a 1 in a million containment for a single particle of 0.01 microns or larger, and 100% containment for 0.05 microns or larger
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
violet bar for shortest wavelength of violet light (380 nm or 0.38 microns)
Both these figures are from the attachment NASA is replying to here. I have added extra text showing the wavelength of violet light to the figure in this response to help make it clear quite how tiny these particles are that need to be contained with the ESF recommendation.
To get a first idea of how challenging this requirement is, even the best optical microscopes can't see things so small (unless they are very bright). There's an irreducible fuzziness set by the limits of the wavelength of visible light itself. Blue light can give sharper images than red light but even the bluest light we can see can't resolve structures to details of much less than 0.2 microns (MicroscopyU, n.d., resolution) or half the wavelength of blue light.
The theoretical limit is achieved if the condenser which focuses light onto the specimen can shine light onto it nearly at 90 degrees to the line of sight and if the objective is able to collect light that shines through it at nearly 90 degrees to the line of sight - and if the specimen itself is enclosed in glass or oil. In such a situation the resolution can be slightly less than 0.2 microns (Zeiss, n.d., Numerical aperture and resolution)
So 0.05 microns is REALLY TINY. We can get below that using electron microscopes and various other techniques (superresolution imaging for instance) but it's not easy.
So - we have a requirement here to contain particles that are too small to see in a microscope unless they are illuminated and show up as very bright dots. Even then it is hard to illuminate them, because each particle is so much smaller than the wavelength of even violet light.
Here is figure 3 from your own cite to show the issue.
Text on image in dark blue (added by me). The best real world filter at 0.05% I found achieved 88% containment.
[Diffusion regime[ Particles much smaller than gaps between fibers. Many hit the fibers by random jostling but always a few get through.
It is hard to test containment for particles so small (well beyond optical resolution of microscopes)
In my literature search I haven't yet found any air filters designed with an objective of 100% containment at any size.
HEPA filters are required to trap 99.97% of particles of 0.3 microns in diameter and 99.99% of particles of greater or smaller size (WHO, 2003, Laboratory Biosafety Manual Second Edition (Revised)) . These standards don’t set any size limit for 100% containment.
100% containment for larger than 0.05 microns means 100% containment also at the most penetrating particle size, the size where most particles get through the filter by definition.
No HEPA filter achieves 100% containment.
From their figure 3, the smaller particles are trapped by diffusion, i.e. by brownian motion. They are far smaller than the gaps between the fibers and are small enough to be jostled around by air molecules. How many hit the fibers depends on the rate of air flow, particle size and fiber spacing. But this is a random process and can never achieve 100% containment.
Their own cite it doesn't say 100%. It says nearly 100%.
The key implication to emphasize is that HEPA filters are nearly 100% efficient at capturing the spectrum of particles down to the very smallest airborne particles.
The best way you can increase the efficiency of a HEPA filter is by reducing the air flow.
As a rule of thumb, reducing the velocity by half not only reduces the pressure drop by half but also decreases particle penetration through the filter media by nearly an order of magnitude. .
A HEPA filter can't achieve 100% containment at any size. NASA are correct when they say that smaller particles (at least up to a point) are contained more easily than the ones at the most penetrating size. But a 0.05 micron particle of course can get attached to a larger particle! Indeed it's a likely scenario in a sample of Mars, that ultramicrobacteria could be huddled away from the UV in tiny cracks in larger dust grains. And of course it's just as important to contain larger microbes.
100% containment at 0.05 microns and upwards means 100% at all sizes not just at 0.05 microns.
The main way smaller particles are contained is through brownian motion. Smaller particles are more easily disturbed by random jostling of air molecules. They are far smaller than the gaps between the fibers but as particles get smaller they are jostled around more easily and so a higher % of them hit the fibers of the filter. But there are many more small particles than large particles for the same mass. Also this is a random process and some will always get through if you are relying on the jostling of particles by air molecules to trap them.
So, no, it is not possible to achieve 100% containment at 0.05 microns either, never mind at all sizes above 0.05 microns using standard HEPA filters.
Then there's the question of how well experiment matches theory. Though I found papers saying filters can achieve high levels of containment of small particles I didn't find actual filters designed, tested and shown to be able to achieve close to 100% containment even for such very small particles, ignoring the issue of larger particles for now.
I've looked at more recent reviews of air filters. I still find no sign that anyone is working on this technology and I haven't yet found any examples of filters that reach close to 100% even for small particles not attached to larger particles.
None of this is to say that the requirement is impossible to achieve. There just doesn't seem to be an interest in 100% containment of ultramicrobacteria or close to 100% containment of Gene Transfer Agents. The technology doesn't seem to have been developed and there isn't any experimental data yet or any suggested designs, or roadmaps to consult about whether and how it is possible to achieve this goal, as far as I can tell.
Before using an air filter to achieve 100% containment the new standard would need to be designed. Methods for testing it developed. It would be necessary to achieve 100% containment at all stages including when the filter needs to be replaced, which happens often.
One of the first things we'd need to do before we can develop a standard to contain 100% of particles at 0.05 microns is to develop a way to test the filters with challenge aerosols.
This test will also be needed later on as a way to test to see if the filter has been damaged at this sub optical resolution level.
HEPA filters are tested with challenge aerosols such as dioctylphthal (DOP) generated on the intake side of the filter, and measured with a photometer on the discharge side (Richmond et al.., 2000. Primary containment for biohazards: selection, installation and use of biological safety cabinets.:33). These photometers have limited sensitivity to nanoaerosols below 100 nm or 0.1 microns (half the wavelength of light).
In a study of a DOP aerosol using TSI model 8130 Automated Filter Tester in 2008 (Eninger et al., 2008. What does respirator certification tell us about filtration of ultrafine particles?: table III), although particles below 100 nm (0.1 microns) constituted 10% of the count of particles in the test aerosol, and 0.3% of the mass, they provided almost none of the light scatter in the testing photometer (less than 0.01%)
So there is a lot involved in developing filters to contain particles as small as a quarter of the wavelength of light. Though it may be possible to design, develop, test, evaluate and finalize such a new filter standard, I find no attempt even to make a start on it. If we do feel it is needed, the process of developing a new standard for 100% containment of ultramicrobacteria may take many years.
It wouldn't solve the problem anyway because of the issue of lab leaks and quarantine.
I covered these and other issues in detail in my "Many serious mistakes" in these sections which presumably were left out as "nonsubstantive" based on your opinion that HEPA filters can contain all particles at 0.05 microns and larger:
HEPA and ULPA filters are not tested for such small particles as 0.05 microns and not required to contain them
(Walker, 2022, So many serious mistakes : 156)
Example of best available nanofilter technology from 2020, not yet commercially available, filters out 88% of ambient aerosol particles at 0.05 microns - far short of the ESF requirement to filter out 100% at this size – though this standard can be met with nanoparticles in water under high pressure
(Walker, 2022, So many serious mistakes : 157)
Challenges for maintenance for future 0.05 micron compliant nanoscale filters – need to be designed for sterilization before any potential extraterrestrial biology is known, and may be easily damaged and hard to replace without risking release of nanoparticles
(Walker, 2022, So many serious mistakes : 159)
The ESF study says that the size limit needs to be reviewed regularly – at a decade later in 2022 it is definitely necessary to review a limit set in 2012 which dramatically reduced the 0.2 micron limit set in 1999 to 0.05 micron
(Walker, 2022, So many serious mistakes :s 160)
A size limits review board can be expected to consider research into synthetic minimal cells, and protocells – and ideas for simpler RNA world “ribocells” without ribosomes or proteins would be revisited as a result of research since 2012
(Walker, 2022, So many serious mistakes : 161)
If Mars has mirror life, returning it could potentially cause a similar large scale transformation of terrestrial ecosystems by gradually converting organics to mirror organics – an example worst case scenario
(Walker, 2022, So many serious mistakes :127)
A single mission can’t resolve this question as it may not return life at all – and life that is safe for Earth may co-exist with other life that can never be returned safely which we could encounter in future missions on a planet with total surface area similar to the land area of Earth – it will take more future missions to resolve this question
(Walker, 2022, So many serious mistakes : 130)
If we want to conclude from the meteorite evidence that microbial species from Mars are safe for Earth we need ALL Martian species to get to Earth on meteorites – example of barn swallows that can cross the Atlantic and are native to North America, while European starlings can’t and are non native – natural processes can’t transfer the surface dust, dirt, ice and salts of Mars to Earth
(Walker, 2022, So many serious mistakes :
131)
Example of fresh water diatoms that can’t cross oceans on Earth
(Walker, 2022, So many serious mistakes : 132)
Chroococcidiopsis as an example of a species that wouldn’t survive transfer by impacts from modern Mars based on an analysis by Charles Cockell
(Walker, 2022, So many serious mistakes : 134)
A mirror life chroococcidiopsis analogue as a worst case example of a pioneer species that would have adaptations that let it survive almost anywhere on Earth if returned from Mars and that could never be returned safely as it would risk transforming terrestrial organics to mirror organics that most life can’t use 136
(Walker, 2022, So many serious mistakes : 136)
NASA fail to consider at all the potential for microhabitats in Jezero crater not detectable from orbit such as the Curiosity brines which could be habitable to biofilms or martian life able to tolerate conditions too old for terrestrial life
(Walker, 2022, So many serious mistakes : 136)
NASA fail to consider at all the potential for winds to transfer microbes imbedded in a grain of dust to Jezero crater shielded from the UV by the global dust storms
(Walker, 2022, So many serious mistakes : 144)
Your most important argument in the EIS, the Mars meteorite argument, which you refer to in almost all the planetary protection discussions, is rebutted by the very National Academy of Sciences cite you use to support it and your team doesn't have the necessary understanding of or interest in planetary protection to notice this
Using three other arguments to support it though one is rebutted by its own cite, two have cites with counter examples to the sentence they are cited to, and the fourth has counterexamples that are easy to find in the literature on planetary protection
[WILL ADD MORE LINKS TO THE SECTIONS IN THIS PAGE - MID EDIT AND A FEW SECTIONS ON THIS PAGE INCOMPLETE]
See no need for a specific plan to respond to lab leaks just commenting we can leave it all up to NASA to devise an appropriate plan to contain any potential extraterrestrial life
See no need for special consideration of quarantine to try to keep out mirror life, fungal pathogens, ultramicrobacteria, gene transfer agents and unfamiliar diseases that may have lifelong symptomless spreaders or a latency period of decades and unable to see the distinction even when all these issues are raised as an issue by the public
Plan to base your containment measures for extraterrestrial life on the plans worked out in previous Environmental Impact Statements for BSL-4s submitted to the US by other organizations when no BSL-4 has ever considered a need to contain all possible forms of extraterrestrial biology in their Environmental Impact Statements
Lack of understanding of how HEPA filters work or of the sizes of organisms displayed clearly when you present an opinion without proof that HEPA filters can already achieve 100% containment of all particles of 0.05 microns and all larger sizes than 0.05 microns (only tested down to 0.2 microns and doesn't achieve 100% containment at any size) and use this as a reason why you never mention the recommendation by the European Space Foundation for greatly increased levels of assurance and much smaller size limits than the 0.2 microns of the previous Mars sample return assessment in 1999
Inability to work with levels of risk and risk assurance, inability to communicate understanding of risk to the general public
Not able to understand that or why the general public sees protecting Earth's biosphere and its inhabitants as of equal or more importance than fulfilling mission priorities
Inappropriately setting mission objectives as a need or purpose, especially setting it as a need to return unsterilized samples and using this need to explicitly rule out for consideration any plan where samples are returned to Earth already sterilized
Requiring samples returned to Earth already sterilized need a "safety assessment" using other samples returned unsterilized - this defies basic logic as sterilized samples are already safe while unsterilized samples add to the risk
From the history of the mission, this may be due to an undeclared need to return unsterilized samples which you think will prove that it is safe to send humans to Jezero crater
No knowledge of the extensive literature by astrobiologists who say we achieve far more science return for their discipline by in situ searches on Mars than by returning samples when we don't yet know how to select samples intelligently on Mars even though this literature is cited and quoted from in attachments presented by the public (myself).
Not able to understand the significance for planetary protection of my suggested alternative of a miniature telerobotic life detection lab above GEO using a centrifuge to let instruments operate at Mars gravity and otherwise similar to the life detection lab that NASA devised for in situ life detection as far as Europa just referring me to your arguments against returning samples to the ISS or a lab staffed by human technicians on the Moon, unable to recognize the difference for planetary protection of a miniature lab of similar cost to a small satellite above GEO with zero risk to human technicians as there are no humans on board
Not able to understand the significance of my suggestion to develop 100% sterile landers for your undeclared need to find out if Mars or Jezero crater is safe for humans - that you can do Sagan's biological exploration of Mars which he said correctly would take dozens of missions and with our more complex understanding of Mars but far better technology could take just a few more missions but hundreds of 100% sterile rovers landed on Mars and broadband communications with the in situ rovers and landers from EArth
Unable to understand that you do need members on your team in the relevant disciplines to develop a biological safety plan for Earth and to find out if it is safe to send humans to Mars or to respond to these questions
Unable to recognize that we can't know at this time that it WILl be safe to land humans on Mars and return them safely
I commented that there are many scenarios for a biology on Mars that can never be returned safely to Earth and these sections in my attachments were omitted as "nonsubstantive"
Understandable lack of competence to assess your own ability to respond to our questions, rather as if experts from the CDC or the DoA were tasked with overseeing a mission to send a spacecraft to Mars and due to lack of any understanding of the complexities of mission planning were unable to see any problems with their executive decisions and their responses to those who raise issues with their plans
In conclusion all these major mistakes which persisted all through to the final PEIS demonstrate that you are not ready to submit any EIS on a Mars sample return mission at this moment in time. The only course of action available is to withdraw this EIS, fix the issues and start again. This will require a systemic change of some sort and an EIS can't be done with your current team as you lack anyone in the relevant disciplines to devise a biosafety plan to protect Earth's biosphere and its inhabitants, human, animals, plants, insects and all the organisms that make up our biosphere.
You can do a much simpler mission that doesn't require new expertise by simply sterilizing all samples returned to Earth as suggested in several of the public comments. This has far less effect on your plans than one might think due to most of the samples having much more than a sterilizing dose of ionizing radiation on Mars already and because the high levels of contamination make the samples sadly of virtually no interest to astrobiology for the past or present on Mars.
The suggestion for a reasonable alternative I provided in my public comment under NEPA of a telerobotic miniature life detection lab above GEO plays to your strengths. This is well within the competence of NASA and your team and would protect Earth 100% (no appreciable risk) so long as a level of sterilization is devised accordingly.
If you add bonus samples in clean containers to the ESA fetch lander and use the two Marscopters to return pebbles and ideally salts from the region within their range to a sterile container to return to Earth this greatly enhances the value of this mission as a preliminary astrobiology mission for exciting missions to follow in the 2030s and 2040s.
The main challenge in both cases would be to work out a level of sterilization that is widely seen as acceptable.
It is not suitable for NASA to devise a level of sterilization of samples returned to Earth given the issues with this EIS so this should be done by an international team. Sterilization using ionizing radiation equivalent to perhaps 10 to 100 million years worth of surface ionizing radiation would have virtually no effect on either the geology or the astrobiology of Perseverance's samples due to the high levels of forwards contamination for astrobiology and given that any geological changes such as colour changes of halite and quartz crystals have already happened at those doses.
Planetary protection experts are confident we can devise a method of sterilization that can work with any form of extraterrestrial biology that works even remotely like terrestrial biology by breaking up the covalent bonds that hold large molecules together. But determine an appropriate level of sterilization is a complex task given that we will want to minimize the levels used. I think everyone would agree that if we used, say, the equivalent of a billion years of surface ionizing radiation there would be nothing viable in any conceivable exobiology. But the details of whether lower levels of say 10 million years equivalent is enough or 100 million years equivalent needs more careful research.
To work out a minimal effective level of sterilization that can be sure to keep Earth safe, with no appreciable risk, the team also needs to be interdisciplinary involving expertise in fields such as:
Experts on the effects of ionizing radiation and any other methods used (for instance a combination of moderate heating not enough to destroy interest of the samples with ionizing radiation increases its effectiveness, and gamma rays may have different effects from X-rays which can be tuned to precise frequencies that may be more effective at lower doses)
Synthetic biology to look at the effects of sterilization on unfamiliar life such as the harder to sterilize PNA or other forms of XNA
Origins of life experts to look at sterilization for life that may depend on different principles (could an organism use genetic coding in material more resilient than DNA, similar to prions?)
Experts in planetary protection "of the past" as it is normally understood to give their expert perspective on all this
Set up international fora to engage with the public
Experts in communication and experts with social communication skills to keep the public informed, respond to questions, listen to concerns, identify those with expert suggestions to contribute to the project, running live Q/As, doing risk maps, social media communication with the public and so on as public acceptance is essential to success of this mission
Experts in communication are essential whatever path you follow and this is one of the most important skills and disciplines that I see to be completely lacking in your current team. This lack of expertise is clear throughout all your responses to the public comments and from your responses when I alert you to the issue, there is also a lack of any understanding of the need for this expertise.
This is an urgent need to fulfill to achieve mission success, and should be your top priority. It shouldn't be a difficult need to fulfill since there are many excellent experts available. Additional expertise in public communication has been developed especially during the COVID pandemic and the need to respond to the infodemic, for instance the need to work closely with social media to flag misinformation, encourage reporting of misinformation and make accurate information easily available on social media. Another innovation is the WHO's use of live Q/As responding to questions submitted via tags on social media. You need to be prepared for the risk of an infodemic associated with this mission as it gets more public attention, and prepare for and respond to this in advance pro-actively and to do this you need the relevant expertise on your team or working closely with your team.
So you do have a solution you can adopt that does not require a systematic change in NASA. Either of these alternatives is also an excellent precedent for other countries to follow. My suggestion of a miniature life detection lab above GEO can be the start of an international collaboration like the one for the ISS but in astrobiology in miniature life detection modules above GEO. We can combine this with 100% sterile landers on Mars, which also plays to your strengths in engineering and in this way we all work together to achieve an understanding of Mars and any biosphere it might have quickly, enabling dozens,even hundreds or thousands of sterilized in situ landers on Mars deployed from larger ships in orbit in the 2030s and humans perhaps in orbit around Mars operating them all in the 2040s or 2050s. As I explain in the Open Letter we do have to be prepared for the possibility that Mars has life that we can never return safely to Earth such as mirror life and that this would stimulate and invigorate space exploration and is a future we should embrace as a possibility rather than try to prove to be impossible with inadequate information.
