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

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

To Whom It May Concern,

In regards to Greer Limestone's intention to expand their quarry operation towards Hellhole (cave). I am a lifelong caver and a member of the National Speleological Society since 1965 as well as a lifelong resident of West Virginia. All caves in the United States in general (Federal Cave Resources Protection Act), and in West Virginia in particular (Chapter 20, Article 7a Laws of The Division of Natural Resources - Cave Protection) are protected and possess unique irreplaceable qualities as well as providing critical habitat for creatures that must use caves in order to survive.

I am not opposed to proper operation of mining, quarrying and timbering, recognizing the economic and material need for these resources. Over time, federal and state regulations concerning these industries have been developed based on previous experience. But when these operations adversely impact the environment or endangered species then it is time for serious questions to be raised concerning such activities. Aside from the recreational aspects of Hellhole, the cave is probably the most significant habitat, east of the Mississippi River, for the listed Federally Endangered Species Virginia Big Eared Bat Plecotus townsendii virginianus. Federal regulations regarding critical habitat for listed endangered species requires that said proposed impact be investigated.

If the cave is intersected by the quarry operation, several things are immediately possible 1.) The quarry operation could undergo catastrophic highwall collapse endangering the personnel's lives. and 2.) Seriously impacting the airflow patterns in Hellhole making the cave unsuitable for use by Virginia Big Eared Bats and Indiana Bats (Myotis sodalis another listed Federally Endangered Species) severely impacting those bats chances for survival. By their own self-imposed rules, Greer Limestone will not mine within 500 feet of KNOWN cave passages (the Federal limit is 250 feet). Herein lies the problem, it is imperative the scientific access be given to Hellhole to ascertain the true extent of the cave and where KNOWN cave passages do lie in respect to the area proposed for quarrying. When Hellhole was discovered to be over 8 miles in extent and realizing that the cave covers a lot of horizontal development, Greer Limestone forbade any further surveying in the cave. since then, the only access has been for the annual DNR sponsored bat counts. To properly protect the cave and it's inhabitants, it is absolutely necessary that swift, accurate and thorough surveying be commenced immediately in order to establish where the cave runs in it's horizontal course. I request that the WVDEP immediately establish the necessary procedures to begin a properly scientific survey of Hellhole in order to properly assess the potential impact on the cave, it's inhabitants and possibly the entire Karst drainage system in Germany Valley. This needs to be done in order to properly study the situation prior to issuing a Draft Environmental Impact Study.

I have no objections to Greer Limestone pursuing their legitimate quarry operations. However, if this expansion causes the loss of habitat for listed Federal Endangered species, then this is totally unacceptable. Greer itself expresses it's desire to stay 500 feet from KNOWN cave passages and because of this, it is necessary to find out just where UNKNOWN passages in Hellhole DO lie.


Marshall G. Homes
NSS 8183