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Case 16-42529 Doc 28 Filed 04/13/16 Entered 04/13/16 11:32:40 Main Document <br />Pg6of31 <br />Essential Suppliers perform services necessary for the Debtors to comply with their legal and <br />regulatory obligations to reclaim previously mined lands and to remediate the environmental <br />impact of their mining operations. Any interruption in the services these essential suppliers <br />provide could result in immediate regulatory or legal action (e.g., fines or shutting down mines) <br />against the Debtors by the federal and state agencies overseeing the Debtors' reclamation and <br />remediation obligations. Accordingly, the Debtors are requesting authority to pay in their <br />discretion: (a) Essential Supplier Claims in an amount not exceeding the Essential Suppliers Cap <br />(as defined below); and (b) 20 -Day Administrative Claims without an aggregate monetary limit <br />as these claims if allowed would be entitled to administrative priority pursuant to section <br />503(b)(9) of the Bankruptcy Code. <br />11. Second, certain other vendors provide goods and services to the Debtors that are <br />also essential to the continual and timely production and delivery of coal upon which the <br />Debtors' viability depends. The Debtors, however, have concluded that the Court likely can <br />compel these vendors to provide those goods and services if they refuse to do so. Accordingly, <br />the Debtors' are requesting that the Court approve procedures set forth in paragraph 29 below for <br />resolving disputes with such vendors. While the Debtors will try to resolve any dispute with <br />these vendors without the Court's assistance, the streamlined procedures will enable the Court to <br />nimbly provide its assistance in the hopefully limited circumstances where it will be necessary. <br />The Essential Suppliers <br />12. Essential Suppliers generally fall into the following categories: <br />13. Suppliers of Safety Goods and Services. These suppliers provide specialized <br />technology, goods and services that are necessary for the Debtors to maintain safe working <br />conditions at their mines and to comply with governmental safety laws and regulations. Mine <br />RE <br />