This pessimism has been tempered by research. Studies by Robert Haberle and Manoj Joshi of NASA's Ames Research Center in California have shown that a planet's atmosphere (assuming it included greenhouse gases CO2 and H2O) need only be , for the star's heat to be effectively carried to the night side. This is well within the levels required for photosynthesis, though water would still remain frozen on the dark side in some of their models. Martin Heath of Greenwich Community College, has shown that seawater, too, could be effectively circulated without freezing solid if the ocean basins were deep enough to allow free flow beneath the night side's ice cap. Further research—including a consideration of the amount of photosynthetically active radiation—suggested that tidally locked planets in red dwarf systems might at least be habitable for higher plants.