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Case 16-42529 Doc 28 Filed 04/13/16 Entered 04/13/16 11:32:40 Main Document <br />Pg7of31 <br />safety is of paramount importance to the Debtors, the Debtors' employees and governmental <br />mine regulators. For instance, certain laws and regulations require the Debtors to (a) install and <br />maintain safety systems for their mines and mining equipment and (b) construct barriers or seals <br />in certain portions of their mines. These safety requirements are subject to strict regulation, <br />including periodic inspections by regulators to ensure the Debtors' compliance. Further, certain <br />of these goods and services are available only on a single -source basis (i.e., where, due to <br />considerations of price, quality and/or availability, it is impracticable for the Debtors to source <br />such supplies from alternative vendors). <br />14. If any suppliers of essential safety goods or services refused to do business with <br />the Debtors, the Debtors (a) would be required to invest significant time in obtaining necessary <br />safety goods and services from alternative providers; (b) could be required to pay significantly <br />more for such goods (assuming alternative suppliers were available) and (c) could be forced to <br />idle mines until replacement safety goods and services are obtained. The Debtors simply cannot <br />afford the costs and delays they would incur if their existing relationships with suppliers of <br />safety-related goods and services were compromised. <br />15. Environmental Service Providers. These service providers assist the Debtors with <br />certain environmental obligations, such as reclaiming mined land (i.e., restoring formerly -mined <br />land to its pre -mining condition), remediating the environmental impact of mining operations <br />and complying with air and water regulations. The Debtors are required to undertake such <br />reclamation and remediation activities, and comply with other environmental requirements, <br />under applicable federal and state laws and regulations. Few companies exist that are qualified <br />to assist the Debtors in satisfying these obligations or undertake reclamation activities on the <br />scale required by the Debtors' operations, and the Debtors' current suppliers of these services <br />-7- <br />