open letter to NASA | Planetary protection issues abstract | main points in open letter in more depth | finding an inspiring future | executive summary of preprint | this is like asking an architect to install a smoke detector | NASA's legal requirements under NEPA | About me

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

Abstract – Summary of the main planetary protection issues - MID EDIT

This is a short summary of the major planetary protection issues in NASA's draft EIS to accompany the open letter. See alsoNASA's legal requirements under NEPA.

I’m Robert Walker I was author of one of the last two public comments on your Environmental impact statement for samples returned from Mars. I found many mistakes in it. However I’ll start with the comment you received from your employee Chester Everline, co-author of your handbook on probabilistic risk assurance (Probabilistic risk assessment procedures guide for NASA managers and practitioners). He found that the EIS didn’t state clearly what level of risk NASA is prepared to take for Earth’s biosphere.

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

…

If the MSR 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.

 

However, if this cannot be convincingly demonstrated [IT CAN’T AS WE WILL SEE] the MSR Campaign should seriously consider not returning samples using the technology described in the PEIS (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

(Comment posted December 20th)

I checked the report. NASA were not prepared to give an answer to the question from the comments received from the general public:

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?

(MSR DRAFT EIS 3–3),

NASA just said

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

[then deflect away from the question] The safety case for MSR safety is based on ...

(MSR DRAFT EIS 3–3),

So it’s as Chester Everline said. You can’t do probabilistic risk assurance without a target probability clearly – so this EIS isn’t doing probabilistic risk assurance.

I contacted Chester Everline via email – to ask if we could liase. He doesn’t have expertise in planetary protection. When he did that comment he didn’t know the asteroid argument was disproved long ago. After all why would he expect NASA to missummarize the literature in an Environmental Impact Statement. He’d naturally assume a basic scientific integrity – but that is not what we find in this EIS.

It was refuted 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

(Assessment of planetary protection requirements for Mars sample return missions : 47).

 

The Space Studies Board panel goes on to say (SSB, 2009: 48):

 

… 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.

(Assessment of planetary protection requirements for Mars sample return missions : 48).

It is also refuted in the very cite you use from 2019. Your EIS says:

“The natural delivery of Mars materials 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), …” (MSR DRAFT EIS 3–3),

Your 2019 cite for “potential Mars microbes would be expected to survive ejection forces and pressure “ says:

“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.”

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

This goes against the most basic requirement for an Environmental Impact Statement.

It was a remarkable discovery around the turn of the century that some exceptionally hardy terrestrial microbes can withstand the ejection forces and pressure.

Whereas this harsh environment sets a definite barrier for most microorganisms known,

…These characteristics make spores and anhydrobiotic bacteria especially prepared for coping with the extreme conditions of space

(Natural transfer of viable microbes in space: 1. From Mars to Earth and Earth to Mars : 392).

On the probability of harm resulting from life returned from Mars, Margaret Race, a biologist working on planetary protection and Mars sample return for the SETI Institute and specialist in environmental impact analysis used the analogy of a smoke detector. She wrote this in response to non-peer-reviewed suggestions by the space colonization enthusiast and leader of the Mars Society Robert Zubrin to drop all planetary protection for samples returned from Mars:

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

Hazardous Until Proven Otherwise, in (Opinion: No Threat? No Way : 5)

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

(Smoke detector graphic from The EnergySmart Academy)

Carl Sagan is one of my heroes and I have the same focus as him in this respect. Enthusiastic about space science. Keen on space exploration, including both robotic and human exploration. Watched the Apollo landings in amazement in the 1960s. Marvelled at the Voyager “grand tour” of the solar system. But I also greatly value Earth’s biosphere and its inhabitants.

For me, the value of Earth and its inhabitants is essentially infinite.

Carl Sagan was a pioneer in planetary protection - first paper in 1960 (Biological contamination of the Moon). He put it like this:

“I, myself, would love to be involved in the first manned expedition to Mars. But an exhaustive program of unmanned biological exploration of Mars is necessary first.

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

quote from: (The Cosmic Connection – an Extraterrestrial Perspective)

ALL the major studies for a Mars sample return are in agreement, there is a risk of large-scale effects though it is believed by experts to be low . This runs through the planetary protection literature from the beginnings of the discipline, in the late 1950s to 60s, with Joshua Lederberg, Carl Sagan and others, onwards (When Biospheres Collide : 35, 420)

The most recent European Space Foundation (ESF) Mars sample return study in 2012 concurs with the 2009 Mars sample review and indeed all the major sample return studies to date:

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

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

In more detail they say:

… it is not possible to estimate a probability that the sample could be harmful or harmless in the classical frequency definition of probability.

However it is possible to establish the risk as low, as a consensus of the beliefs of the experts in the field as represented by their experience.

(Mars Sample Return backward contamination–Strategic advice and requirements : 24)

The 2012 ESF study goes on to say Mars samples should be treated like risk group 4 organisms (high individual and community risk, highly infectious, no treatment available) until we know more. I.e. we should treat them as significant.(Mars Sample Return backward contamination–Strategic advice and requirements : 24)

Cassie Conley, former NASA planetary protection officer from 2006 - 2018 summarized it like this:

“that means we are going to contain the samples as if they were the most hazardous Earth organisms that we know about, Ebola virus.”

at 1:02 into this official NASA video

The EIS doesn’t mention this which is not even a majority view, it’s a consensus of ALL Mars sample return studies to date. This fails another requirement of an Environmental Impact Statement

I sent an email to Chester Everline to ask if we could liase – combining his expertise in probabilistic risk assurance and my familiarity with the planetary protection literature – but I was not surprised when he responded saying as a NASA employee he couldn’t engage.

It was the same when I contacted your first planetary protection officer John Rummel. He was the obvious academic to contact as principle author, co-author, or contributor to nearly all the major studies on a Mars sample return, including the 2009 Mars sample return study I just mentioned which refuted the meteorite argument - and indeed much of the literature on the topic for the last several decades. But I can’t liase with him either.

He just said he has retired and said I should contact the planetary protection office (which has not replied).

This was puzzling at the time but I now understand why it happened from a very helpful history in the most recent Space Studies Board report from 2018 and an article from 2017.

I found out you closed down your planetary protection office, which operated from 1997 to 2017 (With planetary protection office up for grabs, …), after first closing down the interagency panel in 2006 (Review and Assessment of Planetary Protection … : 26) which could have advised you, for instance on public health, and the planetary protection subcommittee in 2016.

Your current planetary protection engineer says your priority for planetary protection now is to prepare the way for humans to go to Mars as fast as possible, and you want other agencies to help support this goal (SMA Leadership Profile: Nick Benardini). He is now an employee in your Office of Safety and Mission Assurance, with no independence from NASA.

The Space Studies Board’s recommendation is very clear. In 2018 they said you need to re-establish an appropriate advisory body and process – amongst other things – for critical peer review.

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

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

The roles of the advisory body include the following:

[other roles] …

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

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

I now understand why I found so many mistakes in the EIS. You have nobody left on your team who understands the basics of planetary protection. This is a failing of another requirement of a valid EIS:

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.”

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

They are clear and major mistakes.

One basic mistake pervades the report - the EIS looks at best case scenarios for planetary protection throughout. But we need to look for worst case scenarios, as with the analogy of a smoke detector.

I saw no awareness even of worst case scenarios previously discussed in the planetary protection literature – such as for example Tetanus – this is not adapted to an infectious lifestyle in any organism but kills thousands of unvaccinated newborns ever year (Tetanus). This example is not mentioned anywhere, or any examples of terrestrial analogues that illustrate how microbes from Mars could harm humans or our environment. This is one of numerous examples mentioned by Warmflash et al. (Assessing the Biohazard Potential of Putative Martian Organisms for Exploration Class Human Space Missions, 14–15)

Warmflash et al. are discussing what we should do if we find opportunistic diseases of humans when we explore Mars. They suggest we contain them as far as possible, through biological .containment on Mars and quarantine on return to Earth., writing:

Since the discovery and study of Martian life can have long-term benefits for humanity, the risk that Martian life might include pathogens should not be an obstacle to human exploration.

. (Assessing the Biohazard Potential of Putative Martian Organisms for Exploration Class Human Space Missions, 2)

But your EIS doesn’t make this argument. It didn’t find ANY worst case scenarios.

[TO BE CONTINUED]

open letter to NASA | main points in open letter in more depth | finding an inspiring future | executive summary of preprint | this is like asking an architect to install a smoke detector | NASA's legal requirements under NEPA | About me

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