It is possible that tidal dissipation in an ice crust on Europa preserved a liquid water layer beneath it, provided that the three‐body orbital resonance for Io, Europa, and Ganymede is ancient. The liquid water layer could be a continuing source of the observed surface frost. If Europa's water mantle were ever completely frozen, heating by tidal dissipation would not exceed that produced by radioactive elements, and the mantle would remain frozen.
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Cassen et al. (1979) studied this question.
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