It has been argued that neutrinos originating from ultra-high energy cosmic rays produce black holes deep in the atmosphere in models with TeV-scale quantum gravity. Such black holes would initiate quasi-horizontal showers of particles far above the standard model rate, so that the Auger Observatory would observe hundreds of black hole events. This would provide the first opportunity for experimental study of microscopic black holes. However, any phenomenologically viable model with a low scale of quantum gravity must explain how to preserve protons from rapid decay mediated by virtual black holes. We argue that unless this is accomplished by the gauging of baryon or lepton number, the suppression of proton decay will also suppress quantum gravity mediated lepton-nucleon scattering, and hence black hole production by scattering of ultra-high energy cosmic ray neutrinos in the atmosphere.