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2 Assessment of the PPIRB's Findings and Recommendations
Pages 14-40

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From page 14...
... In keeping with its statement of task, the committee reviewed whether the PPIRB's findings and recommendations are consistent with the 2018 report. In cases where the PPIRB report considered issues not addressed in 1  Planetary Protection Independent Review Board (PPIRB)
From page 15...
... GENERAL AND OVERARCHING FINDINGS AND RECOMMENDATIONS The PPIRB's first seven findings and recommendations consider the advent of new types of private-sector missions, the evolution of the scope of planetary protection policy, scientific and technological advancements, and the need for independent, outside advice to NASA on planetary protection issues. Major Finding: With the advent of private sector robotic and human planetary missions, as well as new ultra-low-cost (e.g., CubeSat-class)
From page 16...
... The PPIRB report has one major finding and one major recommendation that focus on the NASA Office of Planetary Protection (OPP) :5 Major Finding: The PPIRB applauds SMD's [Science Mission Directorate's]
From page 17...
... The PPIRB report contains six findings or recommendations regarding the clarity and timeliness of the development and implementation of planetary protection requirements. With respect to clarity, the report states as follows: Major Finding: There is a general lack of clarity concerning PP requirements and implementation pro­ cesses, particularly for non-NASA missions; this impedes the development of private sector planetary exploration.
From page 18...
... For future new situations such as private sector missions to other bodies or human exploration of Mars, the policies and their potential impacts should be evaluated and examined well in advance of a mission start. The 2018 report made clear its view that it is more appropriate to define planetary protection requirements by their intended goal and not by specific implementation methods in its discussion of the European Space Agency's (ESA's)
From page 19...
... The "General/Overarching" section of the PPIRB report presents one finding and one recommendation pertaining to COSPAR. The finding states: Supporting Finding: COSPAR PP guidelines have evolved to be an internationally recognized, voluntary standard for protection of scientific interests in celestial bodies.
From page 20...
... It is not the purpose of the Panel to specify the means by which adherence to the COSPAR planetary protection policy is achieved; the best and most cost effective means to adhere to the COSPAR planetary protection requirements is reserved to the engineering judgment of the organization responsible for the planetary mission."10 After Supporting Finding [18] on COSPAR, the first section of the PPIRB report turns to three findings and three recommendations addressing the scientific basis of planetary protection requirements.
From page 21...
... The PPIRB report does not cite any examples of such cases, but the committee is aware that such cases have happened and may occur again.11 The two reports are consistent in that both identify cases in which planetary protection requirements that have been levied on missions are unrealistically demanding and costly, and that evidence-based openness to flexibility and innovation in implementing planetary protection requirements is desirable in preventing such situations from causing delays and unneeded mission costs. Three recommendations in this section of the PPIRB report build on the idea of being open to new techniques and approaches for meeting both forward and back contamination objectives: Supporting Recommendation: The PPO should exploit new discoveries and new technologies to better categorize exploration targets, create better forward and backward PP implementation protocols, and lower PP cost and schedule impacts on projects.
From page 22...
... The PPIRB report devotes one finding and recommendation to concerns about streamlining planetary protection measures for ultra-low-cost missions, as follows: Supporting Finding: Without further changes to streamline low-cost mission PP implementation, ultra low-cost planetary missions (e.g., CubeSats) will likely have a PP implementation cost burden that is a larger percentage of their total budget than larger missions, which in turn could threaten their low cost, particularly for those missions beyond PP Category II.
From page 23...
... Finally, the committee notes that, as a general rule, all missions can benefit from approaches designed to streamline implementation of planetary protection measures and minimize their costs. The PPIRB report has findings and recommendations regarding enforcement of reporting requirements and contractual requirements for planetary protection.
From page 24...
... The 2018 report described how planetary protection policy has, in fact, changed significantly over time in light of new scientific information about solar system bodies. However, the PPIRB report perpetuates confusion about planetary protection terminology.
From page 25...
... Yano, "COSPAR's Planetary Protection Policy," Space Research Today, Number 200, December 2017, https://cosparhq.cnes.fr/assets/uploads/2019/12/PPPolicyDecember-2017.pdf. 20  Private communication from J
From page 26...
... However, if missions intended to land anywhere in large areas of the Moon could receive a Category I, spacecraft such as Beresheet would have a logical destination where the payload was of no consequence. Mars Missions The PPIRB report makes two recommendations and offers one finding concerning the planetary protection categorization of Mars missions: Major Recommendation: NASA should reconsider how much of the Martian surface and subsurface could be Category II versus IV by revisiting assumptions and performing new analysis of transport, survival and amplification in order to reassess the risk of survival and propagation of terrestrial biota on Mars.
From page 27...
... To accommodate the competing interests of robotic science and human exploration missions, so-called "exploration zones" have been proposed. Both the human exploration and science communities have participated in initial workshops in recent years to identify potential exploration zones.28 The research citations noted in the PPIRB report (see Supporting Finding [40]
From page 28...
... Previous OPP and COSPAR planning documents have recommended research on these topics, but such studies have not yet been funded.31 Answers to these and related questions would advance the needs of future science, commercial activities, and human exploration. Small Bodies The PPIRB report makes one recommendation and offers one finding concerning the planetary protection categorization of missions to small bodies in the solar system: Supporting Recommendation: In cases of missions to Solar System destinations where there is a large population of similar Category I and II objects (e.g., comets, asteroids, Kuiper Belt Objects)
From page 29...
... human spaceflight program, such as the Augustine report, noted that "science can be enhanced by human exploration, particularly of complex environments, and by providing the ability to service scientific facilities in space."32 The decadal survey for solar system exploration added, "On the basis of the importance of questions relating to life, the committee concluded that for the more distant future, human explorers with robotic assistance may contribute more to the scientific exploration of Mars than they can to any other body in the solar system."33 Eight PPIRB findings and recommendations then deal with the immaturity of planetary protection policy for human exploration and the need to develop the policy expeditiously. Those findings and recommendations address forward contamination, crew return and back contamination, national policy, and communications with the public, as follows: Major Finding: PP planning for human missions to Mars and the communication of those plans to the public are presently immature.
From page 30...
... government reviews and approves space activities that could potentially have large-scale adverse environmental effects on Earth was established through a presidential directive issued in 1977.38 The 2018 report found that this directive is out of date and recommended that it be revisited "in light of NASA plans for Mars sample-return missions and human-crewed missions to Mars and revise or replace its provisions for engaging relevant federal agencies in developing back-contamination protection policies."39 The PPIRB report also recommends paying more attention to how to conduct astrobiological studies in the presence of human activities: Major Recommendation: Special attention should be paid to assess how astrobiological research can be carried out in the presence of human activities.
From page 31...
... , the PPIRB report says Mars sample return "policies should take into consideration current understanding of the ongoing natural transport of material from Mars to Earth since the formation of the planets ~4.5 billion years ago." Scientists have identified more than 220 meteorites on Earth that are believed to have originated on Mars because of their unique isotopic signatures and the presence of trapped gases matching those found in the martian atmosphere but not in Earth's. Analyses of such objects have led to claims of the detection of organic compounds and even controversial claims concerning the presence of ancient martian "microfossils."42 While the case for the presence of organic compounds of martian origin have stood the test of time, meteorite experts and astro­ biologists now discount the findings about microfossils as contamination from impact on Earth, misinterpretation of surface morphology, and inorganic processes.
From page 32...
... [53] By contrast, the 2018 report found that the legal problems facing planetary protection in connection with private-sector space activities having no NASA involvement went beyond "misperceptions of legal uncertainty" about federal "regulatory frameworks." The 2018 report noted that the FAA questioned whether its legal authority 44  See PPIRB report Supporting Finding [40]
From page 33...
... However, the PPIRB report also included a recommendation that more closely tracked the conclusions of the 2018 report on legal and regulatory issues: Supporting Recommendation: For space activities without significant NASA involvement (including private sector robotic and human planetary missions) , NASA should work with the Administration, the Congress, and private sector space stakeholders to identify the appropriate U.S.
From page 34...
... The PPIRB report identified the growing importance of private-sector interest in space activities and the planetary protection implications of that interest: Supporting Finding: Several private space companies are rapidly advancing technologies and plans for robotic and human planetary missions, including plans to land cargo and humans on the surface of the Moon and Mars. These developments provide important considerations for updating NASA and other U.S.
From page 35...
... ROBOTIC MARS SAMPLE RETURN The findings and recommendations of the PPIRB report are broadly consistent with the 2018 report and previous NASA reports on Mars sample return. Planning for the 2020 Mars sample collection mission is well advanced, and NASA is already implementing some of the PPIRB's recommendations on Mars sample return.
From page 36...
... In particular, the 2018 report noted that "planetary protection requirements for the sample containment, verification of containment, return vehicle, and sample receiving facility are not yet in place" and the need to develop such requirements as a key part of the overall Mars sample return mission.59 The two reports are, thus, consistent in emphasizing the need for further work on planetary protection policy planning and implementation for the Mars Sample Receiving Facility. The 2018 report did not address the specific plans or details concerning the building of the Mars Sample Return Facility, but other reports from the National Academies have done so, albeit not recently.60 The PPIRB report also focused on the need for a public outreach strategy in connection with the Mars sample return mission: Major Recommendation: NASA should begin work with other government agencies to develop a MSR PP public outreach, communications, and engagement plan.
From page 37...
... The PPIRB report next addressed sterilization techniques in connection with the Mars sample return mission: Supporting Finding: Some types of sterilization of Mars samples are antagonistic to many important types of scientific measurements.
From page 38...
... , the project devised the means to ensure a very low probability of contamination of a Europan ocean.63 The PPIRB report's supporting finding and recommendation on ocean worlds are as follows: Supporting Finding: Category IV is currently assigned to landed ocean world missions when there is a significant probability of contamination of the liquid interior oceans. However, the situation for each ocean world environment is very different and limited information exists for each of these worlds regard­ ing ice shell composition and thickness, ocean composition and habitability, interfaces/communication between the surface and ocean, and any transport of material across the surface.
From page 39...
... The 2018 report concluded that, at the level of domestic law, the United States has a "regulatory gap" because no federal agency has the explicit authority to regulate planetary protection issues. The PPIRB report also noted the need to identify an appropriate federal agency to regulate the private sector in the planetary protection domain (see Supporting Recommendation [58]
From page 40...
... On the other hand, the PPIRB recommendation for communicating COSPAR's long-established role and relationship to NASA is consistent with the 2018 report's description of the history of planetary protection policy. The 2018 report observed that "NASA science and policy have, to date, provided the basis for practically all substantive COSPAR guidelines."69 Put differently, history of the development of COSPAR's planetary protection policies is the story of the international adoption of Space Studies Board science and NASA policy.70 As noted above, NASA has consistently defined planetary protection policy to focus on forward contamination to protect astrobiological science's search for extraterrestrial life and prebiotic chemical evolution and backward contamination to protect Earth's environment from potential harm by replicating extraterrestrial organisms.


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