Edward A. Devine 13329 Deerbrook Drive Potomac, Maryland 20854 October 24, 2000

Permit Supervisor
West Virginia Division of Environmental Protection
105 Railroad Street
Suite 301
Philippi, West Virginia 26416

Dear Sir,
      This letter is written in response to the permit renewal application (No. O-2036-86) submitted by Greer Lime Co. for expansion of its Pendleton Co., quarrying operations.

The proposed quarry expansion tract is located adjacent to a major system of caves, including Hellhole and Schoolhouse Cave, which may potentially be intersected by the proposed quarry expansion. These caves are incompletely explored. The last exploration and survey trip into Hellhole, conducted in 1997 under the direction of the WV Division of Natural Resources, discovered thousands of feet of new cave passage, in places exceeding 100 feet in width and 70 feet in height. Numerous large leads were left unexplored.

I request that the issuance of this quarry renewal permit be delayed until the exploration and mapping of Hellhole can be completed sufficiently to assure the continued protection of the cave system and its biological resources. Hellhole is the largest cave known in northeastern West Virginia and is also one of the deepest caves in the entire state. Hellhole is an exceptional world-class cave well known for its unusual large-passage development, impressive mineral formations and biological resources.

Hellhole is the largest bat cave hibernation site in the Mid-Atlantic region with over 100,000 hibernating bats documented by the WVDNR. Hellhole contains the largest known population of federally-endangered Virginia big-eared bats (Corynorhinus townsendii virginianus, formerly, Plecotus townsendii virginianus), the largest population of federally-endangered Indiana bats (Myotis sodalis) in the mid-Atlantic region, and a major population of little brown bats (Myotis lucifugus).

Cold air trapped within the caves is thought to be a major factor influencing the suitability of these hibernation sites. Thus, the breaching of undiscovered, but interconnected cave passages through quarrying operations is a major concern, as it may cause detrimental changes to air flow and temperature characteristics of these hibernation sites. I am a U.S. Navy structural engineer and have been one of the principal explorers and cartographers involved with the WVDNR-sanctioned explorations of Hellhole since 1986. As such, I strongly suspect that major undiscovered, interconnected portions of both Hellhole and Schoolhouse Cave may exist under or close to the proposed quarry expansion tract.

I am not opposed to limestone quarrying or the expansion of the Greer Lime operation, and, indeed, I commend Greer Lime for its careful attention to protection of the caves with its current operations. However, I feel that eastward expansion of the quarry should be delayed until the exploration and mapping of these caves can be completed sufficiently to assure the continued protection of the cave system.

Sincerely, Edward A. Devine