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Case 16-42529 Doc 1478 Filed 10/24/16 Entered 10/24/16 20:24:17 Main Document <br />Pg 3 of 99 <br />agreements. In the United States alone, as of December 31, 2015, the Debtors held an estimated <br />5.5 billion tons of proven and probable coal reserves, and the Debtors generated sales of <br />approximately 180 million tons of coal. <br />The Debtors operate in a competitive and highly regulated industry that has <br />experienced strong headwinds and precipitously declining demand and pricing in recent years <br />due, in part, to the rise of low priced alternative energy sources — including an abundance of <br />natural gas. Combined with these factors, slowing global economic growth drove a wide range <br />of goods prices lower in 2015 and resulted in the largest broad market decline since 1991. <br />Indeed, demand from electric utilities in the United States alone declined approximately 110 <br />million tons in 2015. These market conditions, in connection with lower realized pricing in the <br />United States and Australia, resulted in a 21.0 million ton decline in the Debtors' and their non - <br />debtor subsidiaries' coal sales during 2015. <br />Facts Relevant to This Motion <br />The Leases <br />6. As detailed in prior filings, the Debtors' businesses are vast and complex, <br />with coal mining operations located throughout the United States. In connection with these <br />operations, the Debtors estimate that, as of the Petition Date, the Debtors were lessee, sublessee <br />or party to more than 6,600 leases, surface leases, subleases, land use licenses, rights of way, <br />easements and/or similar agreements, including any modifications, amendments, addenda or <br />supplements thereto. Much of the value of the Debtors' businesses derives from, or is otherwise <br />related to, leases providing them with the right to mine. <br />NAI -1502082594x7 <br />