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2016-04-25_GENERAL DOCUMENTS - C1982056 (12)
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2016-04-25_GENERAL DOCUMENTS - C1982056 (12)
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Last modified
8/24/2016 6:21:05 PM
Creation date
4/26/2016 1:13:53 PM
Metadata
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Template:
DRMS Permit Index
Permit No
C1982056
IBM Index Class Name
General Documents
Doc Date
4/25/2016
Doc Name
Motion of the Debtors and Debtors in Possession Pursuant to Sections
From
United State Bankruptcy
To
DRMS
Permit Index Doc Type
General Correspondence
Email Name
MPB
JRS
JLE
Media Type
D
Archive
No
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Case 16-42529 Doc 28 Filed 04/13/16 Entered 04/13/16 11:32:40 Main Document <br />Pg8of31 <br />have extensive and highly -specialized knowledge that is essential to providing these necessary <br />environmental services. Without the continuation of the Debtors' business relationships with <br />their environmental service providers, the Debtors would not be able to maintain compliance <br />with statutory and regulatory requirements. As a result, federal and state regulators may levy <br />fines or worse, shut down the Debtors' mining operations. <br />16. Chemical and Mineral Suppliers. The Debtors' coal mines depend on regular <br />deliveries of specialized chemicals and minerals used in coal processing. These chemicals and <br />minerals required by the Debtors are also used to maintain compliance with certain statutory <br />requirements or meet customer specifications on the specific mixture of coal deliveries. <br />17. If the Debtors were forced to locate alternative suppliers of coal processing <br />chemicals or minerals, the Debtors would incur burdensome costs because locating the necessary <br />replacement suppliers could cause the Debtors to idle operations or significantly delay the <br />Debtors' processing and sale of coal. For example, if the Debtors were required to replace <br />certain suppliers of minerals and chemicals, the Debtors may be forced to (a) obtain approval <br />from a range of customers and railroads concerning use of a replacement chemical supplier; <br />(b) obtain new equipment, as certain substitute chemicals are incompatible with certain of the <br />Debtors' current equipment; and (c) pay significantly more for certain minerals and chemicals. <br />For all of these reasons, it is critical that the Debtors' relationships with existing chemical and <br />mineral suppliers are maintained to prevent the idling of mining and coal production operations <br />that would occur if the delivery of these necessary supplies were interrupted. <br />18. Suppliers of Specialized Goods and Providers of Specialized Services Required <br />for Coal Production and Processing. The Debtors have longstanding business relationships with <br />certain suppliers of highly -specialized mining equipment, parts and supplies — such as engines, <br />
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