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Case 16-42529 Doc 28 Filed 04/13/16 Entered 04/13/16 11:32:40 Main Document <br />Pg5of31 <br />regulatory requirements, without the continuing services of specialized service providers, <br />including providers of environmental and engineering services. <br />9. The Debtors are making every effort to avoid production and delivery <br />interruptions and the adverse effects that even a temporary disruption could have on their <br />businesses. However, some of these vendors may make threats that, unless paid on account of <br />their prepetition debt, they will cease to supply the Debtors with the goods and services <br />necessary to maintain the operation of the Debtors' businesses. Refusal to deliver goods or <br />services by any one of those vendors could severely disrupt the production process, jeopardize <br />critical business relationships and cause the Debtors to incur significant costs in locating and <br />securing replacement goods and services. Disruptions to the Debtors' coal production and <br />delivery operations would have an immediate and harmful impact on revenues while <br />simultaneously eroding customer relations and goodwill. <br />10. Because certain vendors may refuse to perform if the Debtors do not pay for the <br />good and services those vendors provided prepetition, the Debtors are asking the Court to <br />provide them with the tools necessary to deal with recalcitrant vendors. First, the Debtors <br />request authority to pay prepetition claims of certain vendors that provide the Debtors with <br />essential goods and services (the "Essential Suppliers"). The Essential Suppliers include <br />(a) vendors that the Court likely could not compel to provide goods and services to the Debtors <br />and (b) vendors that provide the debtors with reclamation and remediation services. The goods <br />and services that the Essential Suppliers provide to the Debtors are essential to preserving the <br />value of the Debtors' estates and necessary for the Debtors' successful reorganization. The <br />Essential Suppliers, however, may be unwilling or unable to provide their essential goods and <br />services if the Debtors fail to pay the Essential Suppliers' prepetition claims. The remaining <br />-5- <br />