SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE
Mail Stop 7010
 February 28, 2008
Via U.S. Mail and Fax (918) 295-7361

Mr. Brian L. Cantrell
Chief Financial Officer Alliance Resource Partners, L.P. 1717 South Boulder Avenue, Suite 400 Tulsa, OK 74119
 Re: Alliance Resource Partners, L.P.
  Form 10-K for the Fiscal Year Ended December 31, 2006   Filed March 1, 2007   File No. 0-26823

  Form 10-Q for the Period Ended September 30, 2007
  Filed November 9, 2007

Dear Mr. Cantrell:

We have reviewed your response letter  dated January 23, 2008 and have the
following comments. Please provide a written re sponse to our comments.  Please be as
detailed as necessary in your explanation.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.  After
reviewing this information, we may raise additional comments.

Form 10-K for the year ended December 31, 2006

River View, Penn Ridge, Tunnel Ridge, pages 5 & 7
 Coal reserves, page 31

1. In your responses to prior comments number 16 and 17 from our letter dated
December 20, 2007, you indicate that you will pr ovide certain disclosure in future
filings.  Please provide specifi c of examples of the addi tional disclosure you propose
to include in future filings.

Mr. Brian L. Cantrell
Alliance Resource Partners, L.P. February 28, 2008 Page 2
Segment Information, page 41

2. We note your response to prior comment number 5 with respect to your Segment
Adjusted EBITDA Expense non-GAAP measure.  Please further clarify how your measure is meaningful and useful as a m easure of your segment operating expenses.
In this respect, it does not appear that you are currently reporting th is measure as part
of your segment disclosures.  In addition, it does not appear that this measure correlates to your Segment Adjusted EB ITDA profitability measure you report in
accordance with SFAS 131.  Please further clarif y the usefulness of this measure as it
relates to your segments or re vise the description of this measure in future filings to
more accurately reflect the use of the measure.

 Please respond to these comments within  10 business days or tell us when you
will provide us with a response.   Please furnish a letter that keys your responses to our
comments and provides any requested information.  Detailed letters greatly facilitate our
review.  Please understand that we may have  additional comments after reviewing your
responses to our comments.
You may contact Bob Carroll at (202) 551-3362 or Chris White at (202) 551-3461
if you have questions regarding comments on the financial statements and related
matters.  You may contact Ken Schuler at (202) 551-3718 with any engineering
questions.  Please contact Mike Karney at  (202) 551-3847, or the undersigned at (202)
551-3611 with any other questions.

     S i n c e r e l y ,        / s /  A n n e  P a r k e r        Anne Nguyen Parker
Branch Chief