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

Why I'm using this unusual approach of an open letter, and asking for endorsements of statements from experts, even for statements supported by cites NASA uses itself

[LAST UPDATED June 27, 2023, NEARLY FINISHED]

The background is NASA published their final PEIS for their samples returned from Mars on June 8th. I understand there is a 30 day mandatory wait period before they finalize the decision on July 8th. I am one of the people who commented, as requested under NEPA, in a timely fashion during both public comments periods.

It is clear from their final PEIS and their response to public comments including their response to a public comment by one of their own experts in probabilistic risk assurance Chester Everline, that NASA have nobody left on their Mars Sample Return team who has basic understanding of biosafety, risk assurance, or the discipline of planetary protection as previously understood. This is not surprising as they dismissed their planetary protection office in 2017 and removed their interagency panel in 2006 turning it into a subcommittee of a science committee which they then removed in 2016.

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

This makes it impossible to resolve issues with public comments as there is nobody left there with basic understanding of the relevant disciplines. They didn't respond to my email.

I have prepared an open letter

Open letter to NASA, ESA and other interested parties:
let’s keep Earth 100% safe and make this an even better mission
- when you return samples from Mars in the 2030s
- do restore communications with planetary protection experts, and
- restore the interagency panel as the Space Studies Board advised, and
- this time listen to what they say, as you are
- missing the planetary protection expertise you need to make a credible biosafety plan for Earth's biosphere and inhabitants without their help, and
- missing the expertise you need to keep the samples themselves clean of terrestrial life in the forwards direction to the levels needed for astrobiology

I am looking for endorsements from experts to hopefully help NASA to realize they are asking too much of their team. Their responses to public comments that raised serious issues under NEPA were not adequate.

Dear NASA, your final PEIS for samples returned from Mars and replies to public comments show
- for all your excellence on space science
- your team is unfamiliar with essential planetary protection concepts
- for example, your Mars meteorite argument is central to this EIS
- but your own National Academy of Sciences cite for this argument rebuts it!
- one of numerous basic mistakes in the EIS itself and responses to public comments
- this needs to be tackled at a higher level than your Mars Sample Return team
- you are correct to tell me NEPA doesn't require peer review
- but NEPA does require scientific integrity and expertise in the relevant disciplines, in this case planetary protection
- my suggested alternative is one solution that plays to your strengths as an organization
- a miniature life detection lab above GEO based on NASA's Europa lander proposal, with all samples returned to Earth sterilized

We wouldn't go to NASA to prepare a response to an outbreak of bird flu, or ebola. Similarly NASA shouldn't expect to have the necessary competence to prepare a biosafety plan to protect Earth's biosphere and its inhabitants without help from experts in relevant disciplines.

As a couple of examples.

The most central argument in the EIS is the Mars meteorite argument which states that if there is life in the sample tubes returned by Perseverance it already got here as a result of giant impacts into Mars (most recently about 700,000 years ago). This argument is widely believed by enthusiasts for humans to Mars but was disproved long ago including disproved in the very cites NASA uses.

See: First clear example of the lack of anyone from the discipline of planetary protection (at least as normally understood)
- your most important planetary protection sentence, the Mars meteorite argument,
- was proved invalid long ago, for instance in the National Academy of Sciences 2009 study
- and your 2019 National Academy of Sciences cite also rebuts this argument for samples from Mars
NASA declare as an opinion that a HEPA filter can fulfill the ESF requirement to contain 100% of particles at all sizes above 0.05 microns (1/8th of the wavelength of violet light) and use this opinion as a reason not to mention the ESF requirement in the EIS. Such filters are only certified to contain 99.97% of particles at the maximum penetrating size. How can a NASA opinion be a reason not to mention a requirement that HEPA filters are not certified for?

See: An example which shows a lack of familiarity with basic concepts of biosafety
- you rejected my request for the EIS to consider the requirement from the ESF study:
- "the release of a particle LARGER THAN 0.05 μm in diameter is not acceptable in any circumstances”
- your response: "NASA does not concur that 0.05 microns (50 nm) particles cannot be managed"
- you will agree that a HEPA filter is not certified to contain 100% of particles at 0.05 microns upwards
- only 99.97% of particles, at the maximum penetrating size
- so how does an opinion by NASA that a HEPA filter can already achieve this requirement
- make it unnecessary to mention this recommendation in your EIS?
- in reality the technology doesn't seem to exist and there doesn't seem to be anyone working on it yet either

Those are just two of numerous VERY SERIOUS issues.

This is extremely serious because the Mars meteorite argument is so central to your planetary protection case in the EIS
- and because along with three other plausible but invalid arguments it means you effectively endorse Robert Zubrin, president of the Mars society
- against John Rummel, your first planetary protection officer, author, co-author or contributor to a large part of the modern planetary protection literature

But there is nobody left on NASA's team who can even see that these are issues.

So I'm using this unusual approach of an open letter with endorsements in order to try to get NASA to see that they are making a mistake and shouldn't finalize the EIS. They don't have the right team to devise a biosafety plan to protect Earth. The EIS lacks any scientific integrity on planetary protection. NASA need to fundamentally rethink their approach.

I have a proposed solution that NASA are not looking at which plays to their strengths. With the proposed solution for all these issues, they don't need to devise a biosafety plan, just to sterilize all samples returned to Earth.

The proposal is to return samples to a small life detection lab above GEO based on plans they themselves considered for in situ life detection as far away as Jupiter's moon Europa and to sterilize all samples returned to Earth. I cover this plan briefly near the start of the endoresements page (and in more detail in the open letter, attachments to the NEPA comments, and preprint):

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

However NASA are not interested in this suggestion of a reasonable alternative and don't mention it in the EIS, not even to dismiss it from consideration.

They also don't mention their own employee Chester Everline's suggestion to do in situ study on Mars until we know enough about the samples to be better able to return them safely, not even to dismiss it from consideration.

NASA do mention but immediately dismiss from consideration the alternative to sterilize all samples that contact Earth's biosphere suggested by many members of the public in public comments and don't do any analysis of it saying that it is a mission need to be able to return unsterilized samples for safety testing - even though there is no need for safety testing if all sample are sterilized before they reach Earth.

Your team also doesn't see the need to analyse the reasonable alternative of samples sterilized before they reach Earth's biosphere
- because your purpose and need section sets a requirement for the samples to be returned unsterilized for "safety testing"
- even though a sterilized sample doesn't require a safety analysis
- it is not permitted under NEPA to add requirements to the Needs and Purpose that exclude reasonable alternatives
- there is no need to test already sterile samples for safety, they can be released immediately to geologists
- you seem unable to see this point in your replies to members of the public who suggested sterilizing samples returned to Earth

NASA believe that through use of the Mars meteorite argument and other invalid arguments they have demonstrated that the environmental effects would not be significant and health impacts from any lab leak would be negligible. See:

This is very serious because as a result of this and other invalid arguments you conclude there is no need to consider any details of how the Sample Return Facility would work in your EIS
- you have only a few sentences in the entire EIS about the sample receiving facility
- you state that as long as your Sample Receiving Facility copies what other BSL-4s have done to protect human health the risk of harm to human health is negligible

As a result, NASA omit many sections in the EIS that would be required if they concurred with the consensus in the literature of a small risk of large-scale harm. They don't consider

impact on the environment,
impact on the oceans,
impact on the great lakes,
escape of invasive species,
lab biosecurity against theft

and many others (NASA Facilities Design Guide)

They also don't consider:

Lab leaks (being of the opinion that they just need to copy what other BSL-4s do when the time comes to build it)
Quarantine (how do you use quarantine to keep out mirror life or a novel fungus?)
Potential for large-scale impact on human health

There are many things NASA would need to look at that are either not mentioned or dismissed in a sentence or two as a result of their conclusion that environmental effects would not be significant and any health impacts negligible.

The consensus in the literature is of a risk similar in level of risk to a house fire but also similar in level of seriousness to a house fire. A risk with a likely small but not demonstrably zero potential to affect Earth's biosphere and human health globally. Indeed if you look at possible consequences in detail, for instance the scenario of returning mirror life, there is potential for unprecedented levels of harm and an irreversible change in how our biosphere functions for all future time in the low risk but very worst case scenarios.

Why I’m asking NASA to re-examine plans for its Mars sample return mission - like asking an architect to install a smoke detector - remote chance of house fire - but a house of billions of people - and at some point for sure they will have to do it

NASA believe, and state in their EIS, that the consensus is that the environmental effects would not be significant even though their own cites say clearly that the worst case though considered unlikely is highly significant.

This is why I'm using the unusual approach of an open letter to NASA and asking for endorsements even for statements that would be seen as totally uncontroversial to the relevant experts and supported by cites of the highest integrity including cites used by NASA itself in their EIS.

Message to ESA

I will also be sending this open letter to ESA. As equal partners with NASA, you also are directly responsible for returning the samples from Mars to a desert in the USA. All the member countries of ESA have ratified the Biodiversity Convention which gives you obligations to consider the potential for invasive species for any of your actions. EU also has a directive simlar to NEPA and many memeber states also subscribe to the Espoo conventions and there are other international responsibilities.

So you have some say in this mission too and NASA can't go ahead with their mission as planned without your active participation in many ways.

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

I hope that my reasonable alternative of returning the samples to a miniature life detection lab above GEO will appeal to ESA. You are the only space agency that has seriously considered in situ searches on Mars as recommended by astrobiologists in recent decades.

You were going to send LDChip2 to Mars but sadly it was descoped.

ExoMars was going to drill to a depth of 2 meters which astrobiologists say is essential to examine samples that are not severely degraded by surface ionizing radiation.

I hope you may have some influence on NASA to consider the suggestion of bonus samples of dirt, dust and atmosphere and a pebble from a recently excavated crater. This is a relatively straightforward addition to your ESA fetch lander that would greatly enhance the astrobiological interest of this mission.

I hope you may have more understanding than the current NASA Mars Sample Return Team of the reason for this suggestion of bonus samples to rescue this mission

It's also important to manage public expectations. This is only the second step (after Viking) of what is likely to be dozens or even hundreds of landers on Mars to resolve central questions about whether Mars has a biosphere, and if so, how it functions and what forms of biology there are on Mars. There may be many surprises as astonishing as the CO2 geysers.

Message to experts in relevant topics and disciplines who are intersted to endorse

If you are a recognized expert on a relevant topic or discipline and wish to endorse any of the statements I rely on in this open letter please contact me. For some of the statements you can endorse see:

Endorsements by experts of statements relevant to their expertise in my public comments
- submitted under NEPA for NASA's Environmental Impact Statement
- which raise major issues with NASA's plans to return samples from Mars in the early 2030s
- and suggest a reasonable alternative to resolve those issues
- also endorsements to support the Space Studies Board when they highlight NASA's need for external peer review for matters beyond their own sphere of excellence

For details see the navigation links at the top and bottom of this page.

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