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7621 Provincial Dr. #105
McLean, VA 22102
October 17, 2000
Division of Environmental Protection
105 Railroad Street, Suite 301
Philippi, West Virginia 26416
To Whom It May Concern:
I am writing in regard to Quarry Article 4 Application No. O-2036-86 recently submitted to your offices by Greer Lime Co. I wish to address an issue that exists in the current position Greer Lime Co. takes toward Hellhole and offer an alternative solution that strikes a reasonable balance between all parties concerned. The issue revolves around the proximity of Hellhole to the quarry operations conducted by Greer Lime Co. in Germany Valley, Pendleton County, near Riverton, West Virginia.
Hellhole is a well-known hibernaculum for two endangered (and federally protected) species of bat (Plecotus townsendii virginianus and Myotis sodalis) and habitat for two bat species classified as "species of concern". In addition, two more species of rare invertebrate (one of which was first identified in Germany Valley) use Hellhole for habitat.
The development of Hellhole is unique and critical to the cave's success as a hibernaculum. The only known entrance, located at the highest point in the cave, is a funnel-shaped pit entrance on the lower slopes of North Fork Mountain. All other passages in Hellhole are below this elevation and it is this configuration that allows Hellhole to be an efficient "sink" and trap for cold air. Each winter, cold air flows off the slopes of North Fork Mountain and collects in the cave's extensive passages (8.5 miles surveyed to date). The ability to maintain colder than normal cave temperatures (compared to other regional caves) is the primary reason for Hellhole's success as a bat hibernaculum. The two endangered species of bat described above depend upon these conditions for successful winter hibernation. There is no other cave in the region that provides conditions capable of supporting such large numbers of the endangered bats.
Hellhole's passages are developed predominantly in a layer of limestone known as the New Market. This same limestone is of remarkable commercial quality and is the primary target of Greer Lime Co. mining operations. Hellhole's development through much of the New Market limestone, combined with the proximity of Greer Lime Co.'s mining activities, put the cave at severe risk of penetration. Such a penetration would undoubtedly occur at an elevation in the cave lower than that of the entrance.
The effect of such an event would be similar to putting a hole in the bottom of a bucket of water. All the water would drain from the bucket and it would no longer be usable. In the case of Hellhole however all the cold air would drain from the cave and it would never again support the endangered species that depend upon its cold natured habitat. Worse still, the same effect of a large penetration could be achieved by the collection of several smaller penetrations. That is to say intersection of multiple narrow fissures connected to Hellhole would damage the cave's integrity as much as breaking open one large passage.
Hellhole passages have proven complex in their development. They traverse in many directions and to this date are not fully explored nor understood. It is by good fortune that past quarry operations have not intersected some piece of unknown passage in Hellhole. Beginning in 1986, when Greer Lime Co. leased the land surrounding the entrance to Hellhole and placed severe limitations upon the pace of exploration in the cave, the risk to the endangered species in Hellhole began to increase. This risk is not immediately attributable to quarry operations so much as to "lack-of-knowledge" vis-à-vis Hellhole's proximity to quarry excavations.
In 1997 explorers in Hellhole surveyed extensive new passage in an area that had not previously been known to contain any Hellhole passage. To this date there are a large number of passages extending into the unknown from this same region of the cave. Greer Lime Co. routinely denies explorers the opportunity to investigate these "leads" under the pretext that previously discovered cave has made the limestone "unmineable".
I submit that, due to the presence of federally protected species, the limestone is inherently unmineable until proven otherwise, through the completion of survey, exploration and study. Greer Lime Co. would appear to take the position that ignorance of the cave's presence maintains the "mineability" of a unit of limestone. In fact, this lack of knowledge only serves to increase the risk that accidental intersection of the endangered species habitat will occur. Knowledge of what lies in the limestone could actually be used to help the quarry operate in a manner that would protect the Hellhole hibernaculum.
To reiterate, Greer Lime Co. would rather not allow the cave to be fully studied because that would make limestone unmineable. Citizens and Agencies concerned for the health of the endangered species maintain that the limestone is already unmineable, and can only be proven mineable if exploration shows that Hellhole does not penetrate into a given region of limestone.
Greer Lime Co. quarry operations are conducted immediately to the west of known passage within Hellhole. At present Greer Lime Co. is seeking a permit that would allow them to expand their operations in both southerly and northerly directions in their property holdings. Hellhole cave is known to possess unexplored passages that lead toward, and could possibly penetrate both the southerly and northerly units of limestone that Greer Lime Co. seeks to operate within.
I submit that all parties concerned would be best served by the following actions:
Mutually verifiable exploration and documentation of the full extent of Hellhole should be conducted before quarrying operations are permitted to progress toward areas where the cave has potential to penetrate.
The information gained from such exploration should be shared among all the concerned parties.
In the event certain parcels of limestone are confirmed to be unmineable, the potential for remediation by the government to Greer Lime Co., or other affected mineral rights owner, should be considered.
Quarry operations planners and representatives of the constituents of Hellhole work together with the information gained from exploration to determine where mining will have the least potential to impact the Hellhole ecosystem.
The watershed and surface areas that feed into Hellhole (including air-flow) should be protected from development that would impact air and water quality within the cave.
It is my firm belief that the careful consideration and application of guidelines such as these will strike the greatest balance between the economic success of Greer Lime Co. and the ecological considerations of the endangered species that inhabit Hellhole.
Devin S. Kouts
Senior Computer Systems Engineer
Science Applications International Corporation