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

October 16, 2000

Dear Sirs;

I offer the following comments to Greer’s proposal to expand their Germany Valley quarry. I am a 59 year old outdoorsman and caver who has been visiting Germany Valley for 38 years and at one time was the manager of “The Cave House” (a cavers hostel) which was located next to Seneca Caverns. I also functioned as liaison for Pendleton County for organized cavers for several years. I’ve dealt with the quarry on several occasions, and do not wish it ill, since it is a major income source for a lot of people in Pendleton County who’ve been nice to me in allowing me to visit their caves. I’m not so friendly towards Greer’s management, since I found them very parsimonious with the truth in my most formal dealing with them. I suggest that any agreements reached with them be nit-pickingly documented and subjected to legal review, since I’m convinced by experience that friendly arrangements not so documented will be subject to “Reinterpretation” at the company’s interest.

I’ve entered Hellhole thirty or forty times in the distant past when it was open to all comers, and have explored new passage there on several trips, along with many other caves in the nearby area. The quarry has already mined one (Warner’s Broken Dome) away without my protest. Another large and well known cave (Schoolhouse) is nearby, and threatened by future mining. It has great historical significance among cavers and is well known locally. However it does not have the large populations of bats, including Big-eared and Indiana bats which are on the Federal Endangered Species List. I can recall ascending a rope up the 150 foot entrance at dusk on several occasions and having great flights of bats circling out of the cave, dodging me, on their way for the nights hunt. I also remember large clusters of sleeping and hibernating bats on the ceiling of various passages, so thick that you couldn’t see the rock they were clinging to.

This cave contains a substantial proportion of the populations of both endangered bat species. I’ll leave it to the biologists, whom I’ve assisted in bat-banding in Hellhole, to develop the exact numbers. Twenty years ago when the quarry was heading in the general direction of Hellhole, a friend of mine was ascending the rope in the entrance when the quarry set off their Saturday blast. He had dried leaves, dirt, and small pebbles fall into the cave as he hung on the rope. Exciting!

An agreement was made shortly thereafter to treat the cave entrance as an occupied dwelling, in hopes of protecting it. The quarry started mining in another direction not too long thereafter, disappearing Warner’s Broken Dome cave as a matter of fact.

As I understand the new permit request, they now want to resume mining in the direction of Hellhole. As there is now no vaguely complete map of the cave, and the new passages are trending towards Judy Spring (which is also a cave enterable by SCUBA and a trout stream), the quarry does not know when it will strike the cave passage and start to seriously endanger the bats. There is also the possibility of a fire, or low order explosion sucking toxic gases into the cave and threaten the bats.

I suggest that prior to approval of this application, Greer be required to:

1, Reopen access to Hellhole to cavers, who will in turn share their maps with the quarry, said cavers being willing to furnish Greer with a “Hold Harmless” agreements for accidents occuring in the cave, but Greer will notify cavers of scheduled blasts;

2, Hire a bat biologist to do a comprehensive bat survey, including locations and numbers by specie, over a one year period since different bats use the cave at different times for different reasons;

3, That Greer install vibration sensors at critical points within the cave to minimize the likelihood of severe vibrations;

4, That Greer hire a biologist to monitor the effect of blasting on the endangered bats at regular intervals when charges were fired, especially when the blasting was approaching known sections of the cave containing the endangered bats;

5, That Greer be bonded so that, if the entrance collapsed while they were mining in Hellhole’s direction, remediation actions would be completely financed by Greer and the bonding company to bring the population of endangered bats back up to the level found prior to the granting of the permit;

6, That Greer pay for annual bat surveys of the endangered bats, and if the number dropped ten percent below that recorded at the start of the mining towards Hellhole, the permit would be automatically revoked and Greer would be liable for the costs of remediation.

I realize that these are relatively severe conditions, but I am told the limestone mined is very popular for its low silicon content. I estimate the amount to be bonded to be in the ten million dollar range for possible entrance collapse. I also think that the State of West Virginia as well as Greer would be legally liable, if it did not take serious protective action for these endangered species. As a long time member of the West Virginia Highlands Conservancy, I would contribute to such a suit if necessary.

Thomas J. C. Williams Jr.

7096 Leewood Forest Drive

Springfield, VA 22151