So many serious mistakes in NASA's Mars Samples Environmental Impact Statement it needs a clean restart - omits major impacts – uses old science later overturned – statements cited to sources that say the opposite – no response to significant public concerns – “Purpose and need” should permit a sterilized return as a reasonable alternative action - and size limit needs a new review first, a decade after the ESF in 2012 reduced the size of particle to contain from 0.2 to 0.05 microns
Authors: Walker Robert 
Published: December 2022

The cites for this draft NASA EIS are so flawed that it’s unsalvageable. The statements they make contradict the findings of numerous panels of experts in the Mars sample return studies including the ones they themselves cite.If NASA uses this as their final EIS, and it gets taken to the courts, NASA won’t have a case, It will fail basic review, just checking the EIS’s own cites.However, I suggest with some changes the proposed action can go ahead in a way that is safe for the environment and maximizes return for astrobiology and geology.What this EIS proposes is similar to building a house without smoke detectors. But a house for nearly 8 billion people, most of whom are not aware that this decision is being made for them by NASA. This smoke detector analogy is from Margaret Race from her contribution "No Threat? No Way" (Rummel et al., 2000) We need to examine this properly and if it is needed we need to install those smoke detectors. To do this requires an adequate EIS that uses the sources correctly and it needs to consider alternatives designed to protect Earth with 100% safety, and not just “no action”In this proposal NASA plan to return unsterilized Mars samples to a biosafety level 4 facility on Earth – and to examine them for life sciences using BSL-4 precautions and then sterilize samples that are taken out of the BSL-4 facility.The European Space Foundation determined in 2012 that Mars samples should be contained to far higher standards than BSL-4 to protect Earth. This draft EIS doesn’t cite the ESF report which reduced the size limit from 0.25 to 0.05 microns. Even a decade later the technology the ESF require doesn’t yet exist even for experimental filters in laboratories, today. For details see this section and the following sections (below):We do know how to contain known hazards such as anthrax safely. However until we know what’s in the sample we can’t discount the possibility of something far harder to contain than anthrax.The worst case would be starvation limited ultramicrobacteria which have been observed to pass through 0.1 micron nanopores, or perhaps even a hypothetical ribocell which may be able to pass through a 0.02 micron nanopore. Research since 2012 makes ribocells more plausible than it was then and the ESF study in 2012 said it needs regular review. It is not at all clear that a new review would decide that a 0.05 micron standard is sufficient.NASA haven’t commissioned any new review and they haven’t even consulted the 2012 review. In this EIS they are relying on a review conducted in 2009 which is 13 years ago. A lot has changed in scientific understanding of microbes, extremophiles and the possibilities for extraterrestrial life in those 13 years.This proposal surely shouldn’t go ahead until we have had an updated review of what is needed. It is impossible to evaluate the technology requirements until we know the size limit that needs to be targeted.A simple way to install those “smoke detectors” is to require the lab for UNSTERILIZED materials and potentially viable martian microbes to be in orbit or somewhere unconnected with Earth's biosphere - unless we can prove that -there is no life in the sample OR -the life can’t harm Earth in any way OR-we know how to contain the life after return to Earth with truly zero risk.The lab also has to have no connection with Earth’s biosphere so all sample handling has to be done remotely from Earth using telerobotics. Quarantine won’t work to protect Earth from, say, a mold that is harmless to humans but attacks crops, or mirror ultramicrobacteria.Sterilized samples can return to Earth and be studied in normal labsThis leads to 100% safe sample return. Why have less than 100% safety when there is even a tiny chance of large scale effects for the whole Earth in an ultra low probability worst case?As Carl Sagan once put itThe likelihood that such pathogens exist is probably small, but we cannot take even a small risk with a billion lives.