Germany Valley Karst Survey, Surveying Caves, Karst and Karst Features of Germany Valley, West Virginia

October 24, 2000

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

RE: Article 4 Quarry Permit Number O-2036-86
Renewal Application
Greer Lime Company

Dear Sir or Madam,

Germany Valley Karst Survey (GVKS) is providing this letter to comment on the renewal application submitted by Greer Lime Company to extend their current quarrying operations in Germany Valley, West Virginia. GVKS has reviewed the permit application, which has been available for public review in Franklin, West Virginia. Based on our understanding of the renewal application, Greer Lime Company is requesting a permit to continue quarrying operations to the east and south of their current mining operation, which is located approximately three (3) miles northeast of Riverton, West Virginia.

We offer the following concerns regarding the proximity of the proposed quarrying operations to one of the most important caves in the State of West Virginia, known as Hellhole. As founder of GVKS, I have been involved with geologic and geomorphologic studies in Germany Valley for over ten years. I have also been intregal in the survey of the cave in that period, and was present at the recent discoveries at both the northern and southern extensions of the cave. GVKS has been surveying the caves, karst, and karst features in this area of West Virginia for over one year in preparation for publishing a peer-reviewed monograph on the valley's caves and associated geology. Hellhole is located directly to the east of the Greer Lime Company's Germany Valley Quarry.

Hellhole

The current length of the cave is reported to be approximately 8.5 miles long. However, based on survey information obtained during past survey trips authorized by the West Virginia Department of Natural Resources (DNR) and Greer Lime Company, unmapped cave passages have been identified throughout Hellhole. At this point in time, no one knows the true extent of the cave, or where all the passages are in relation to the quarry wall.

Closing

GVKS is concerned that Greer Lime Company's renewal application will be granted prior to any discussion regarding the ramifications of the quarry intersecting unknown cave passage. The company's application clearly states that the new headwall will be located more than 250 feet west of known cave passages. However, the true extent of Hellhole is unknown due to an incomplete survey of the cave's passages.

Therefore, GVKS respectfully requests that West Virginia Department of Environmental Protection (DEP), DNR, and USFWS, discuss the possibility of completely surveying the cave, and documenting the known passages prior to, or, at a minimum, in concurrence with issuance of the mining permit. A complete survey will result in the protection of this important habitat from possible destruction, and allow Greer Lime Company to formulate their future expansion plans with no fear or liability of intersecting the cave.

Thank you for your attention in this matter. If you have any questions regarding any of the above-referenced information, please feel free to contact me at (703) 379-2480 x217 or (703) 288-3889. I am also available by electronic mail at braces@ioip.com.

Respectfully submitted,
Germany Valley Karst Survey

Gordon S. Brace
Founder

cc:      Mr. Craig Stihler, West Virginia Department of Natural Resources
          Mr. Bill Tolland, United States Fish and Wildlife Service