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Note: 

Charles E. Frost, Jr., Implied Covenants and the Duty to Develop In Underground Coal Gasification, 59 TEXAS L. REV. 1303 (1981). 

Frost argues that current rules governing oil and gas extraction, though suitable for traditional oil and gas mining, work much less well in relation to underground coal gasification projects.  In particular, implied covenant law and the “reasonably prudent operator” standard create certain difficulties when applied to underground coal gasification.  This note proposes pooling and unitization methods that, if embodied in lease provisions, can furnish useful alternatives to reliance on judicial construction of these contracts.