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SEC Comment Letter for ALLIANCE RESOURCE PARTNERS LP (ARLP) (CIK 0001086600) (ARLP) — Dec 2, 2011

ALLIANCE RESOURCE PARTNERS LP (ARLP) (CIK 0001086600)
Date: Dec. 2, 2011 · CIK: 0001086600 · Accession: 0000000000-11-069512

Financial Reporting Regulatory Compliance Related Party / Governance

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File numbers found in text: 000-26823

Date
December 2, 2011
Author
John Reynolds
Form
UPLOAD
Company
ALLIANCE RESOURCE PARTNERS LP (ARLP) (CIK 0001086600)

Letter

December 2, 2011 Via E-mail Joseph W. Craft III President and Chief Executive Officer Alliance Resource Partners, L.P. 1717 South Boulder Avenue, Suite 400 Tulsa, Oklahoma 74119 Re: Alliance Resource Partners, L.P. Form 10-K for the year ended December 31, 2010 Filed February 28, 2011 File No. 000-26823

Dear Mr. Craft:

We have reviewed your filing and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure.

Please respond to this letter within te n business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts a nd circumstances, please tell us why in your response. After reviewing the information you provide in response to this comment, we may have additional comments.

Form 10-K for the Fiscal Year ended December 31, 2010

Grant of Plan-Based Awards Table, page 125

1. We note that several named executive offi cers have received non-equity incentive compensation in 2010; however, disclosure has not been included in the Grants of Plan Based Awards Table. Please confirm that in future filings you will include disclosure in the Grants of Plan Based Awards Table and provide us with draft disclosure . We urge all persons who are responsible for th e accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules requir e. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.

Joseph W. Craft III Alliance Resource Partners, L.P. December 2, 2011 Page 2

In responding to our comments, please provi de a written statement from the company acknowledging that:  the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federa l securities laws of the United States.

Please contact Ruairi Regan, Staff Attorn ey, at (202) 551-3269 or Pamela Howell, Special Counsel, at (202) 551-3357 if you ha ve questions regard ing our comments. S i n c e r e l y , /s/ James Lopez (for) John Reynolds A s s i s t a n t D i r e c t o r cc (via email): David Oelman Vinson & Elkins LLP

Show Raw Text
December 2, 2011
 Via E-mail

Joseph W. Craft III President and Chief Executive Officer  Alliance Resource Partners, L.P. 1717 South Boulder Avenue, Suite 400 Tulsa, Oklahoma 74119
 Re: Alliance Resource Partners, L.P.
  Form 10-K for the year ended December 31, 2010   Filed February 28, 2011
File No. 000-26823

Dear Mr. Craft:

We have reviewed your filing and have the following comment.  In our comment, we
may ask you to provide us with information so we may better understand your disclosure.

Please respond to this letter within te n business days by providing the requested
information, or by advising us when you will provide the requested response.  If you do not believe our comment applies to your facts a nd circumstances, please tell us why in your
response.
 After reviewing the information you provide in response to this comment, we may
have additional comments.

Form 10-K for the Fiscal Year ended December 31, 2010

 Grant of Plan-Based Awards Table, page 125

 1. We note that several named executive offi cers have received non-equity incentive
compensation in 2010; however, disclosure has not been included in the Grants of Plan
Based Awards Table.  Please confirm that in future filings you will include disclosure in the Grants of Plan Based Awards Table and provide us with draft disclosure .
 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Joseph W. Craft III Alliance Resource Partners, L.P. December 2, 2011 Page 2

  In responding to our comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

Please contact Ruairi Regan, Staff Attorn ey, at (202) 551-3269 or Pamela Howell,
Special Counsel, at (202) 551-3357 if you ha ve questions regard ing our comments.
        S i n c e r e l y ,
 /s/ James Lopez (for)
        John Reynolds         A s s i s t a n t  D i r e c t o r   cc (via email): David Oelman   Vinson & Elkins LLP