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Correspondence Filing

 January 9,
2006

 Mr. Barry Stem

 Senior Assistant Chief Accountant

 United States Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549-7010

RE:
Alliance Resource Partners, L.P.

 Form
10-K, Filed March 15, 2005

 File No. 0-26823

 Dear Mr. Stem:

 By letter, dated November 17, 2005, you, on behalf of the accounting staff (the
“Staff”) of the Securities and Exchange Commission (the “SEC”), requested certain business or accounting records of Alliance Resource Partners, L.P. (the “Partnership”) in order to understand our single reportable
segment accounting presentation. The Staff requested that the Partnership explain how our chief operating decision maker reviews the Partnership’s financial results for purposes of making financial decisions about allocating resources and
assessing performance. This letter sets forth the Partnership’s basis for its conclusion that, as a producer and marketer of bituminous coal to power generators located in the Eastern United States, the Partnership has a single reportable
segment in accordance with the requirements of Statement of Financial Accounting Standards No. 131 Disclosures about Segments of an Enterprise and Related Information (as amended) (“SFAS No. 131”). For ease of reference,
we have set forth below the comment contained in your letter of November 17, 2005, in its entirety, and have presented our response immediately thereafter.

Staff Comment No. 1:

 Form 10-K for the year ended December 31, 2004

1.
We note that all of your coal mining operations are reported as one business segment. Explain to us in detail how your chief operating decision maker reviews the Company’s
financial results for purposes of making financial decisions about allocating resources and for purposes of assessing performance. Provide to us copies of the December 31, 2004 reports of financial results that your chief

 Mr. Barry Stem

 Senior Assistant Chief Accountant

 January 9, 2006

 Page 2 of 11

 operating decision maker reviewed for purposes of making financial decisions about allocating
resources and for purposes of assessing performance.

 If these
reports included information on a mine-by-mine basis, each mine would likely be considered an operating segment under paragraph 10 of SFAS 131. To determine whether such operating segments then qualify for aggregation under paragraph 17, we would
need the analysis requested. If such reports do not include information on a mine-by-mine basis, such analysis is not required. If required, we would expect this analysis to include a tabular presentation that includes the following information:

 List each of your mines and support your aggregation of these
operations under paragraph 17 of SFAS 131. Address each of the following:

 Identify the economic characteristics that are similar.

 Explain in detail why the economic characteristics are relevant to the operating segments and how they are similar.

 Explain how the economic characteristics are similar for all components in each aggregated group.

 Identify each of the five areas of similarity required for aggregation
under paragraph 17 of SFAS 131.

 Explain the manner in
which each of the five areas identified in paragraph 17 of SFAS 131 are similar for each segment aggregated and why.

 Note that your analysis should be by mine. We would expect for you to identify the operating statistics that you use to evaluate each mine and provide a
schedule that identifies these measures over the past five years. State whether these trends by mine, are expected to continue. Additionally, address the economics of each operation in terms of the coal and gas deposits that you are extracting, the
methods used to extract it, the shape and distribution of the deposit, and the expected life of your proven and probable or proved reserves. Also address each encumbering commitments, such as royalties and their impact on the economics of the mining
operation.

 Response to Staff Comment 1:

 Summary Response

 The objective of SFAS No. 131 is to provide users of financial statements with
information that will provide a means to (i) better understand the performance of an

 Mr. Barry Stem

 Senior Assistant Chief Accountant

 January 9, 2006

 Page 3 of 11

enterprise, (ii) better assess the prospects for an enterprise’s future net cash flows and (iii) make informed judgments about an enterprise
as a whole. In meeting these objectives, SFAS No. 131 requires the presentation of information that reflects the structure of the entity’s internal organization and is consistent with the way in which management makes operating decisions
and assesses performance.

 Based on this analysis, management believes that the
Partnership’s presentation of a single reportable segment meets both the objective and the technical requirements of SFAS No. 131. Paragraph 10 of SFAS No. 131 defines an operating segment as a component of an enterprise:

 (a) That engages in business activities from which it may earn revenues
and incur expenses (including revenues and expenses relating to transactions with other components of the same enterprise),

 (b) Whose operating results are regularly reviewed by the enterprise’s chief operating decision maker to make decisions about resources to be
allocated to the segment and assess its performance, and

 (c)
For which discrete financial information is available.

 While each of the
Partnership’s individual mines may be considered a component of the Partnership that engages in business activities from which it earns revenues and incurs expenses and for which discrete financial information is available, the
Partnership’s operating results are not regularly reviewed on a mine-by-mine basis by the Partnership’s chief operating decision maker to make resource allocation decisions and assess performance. The Partnership defines discrete financial
information as revenue and profit or loss margin information. Mr. Joseph W. Craft III, the Partnership’s President, Chief Executive Officer and chief operating decision maker, does not use such information to make decisions related to
the allocation of resources or to assess the performance of the Partnership’s separate mining operations. Therefore, as discussed below, effective December 31, 2005, reports regularly reviewed by Mr. Craft include discrete financial
information only on a consolidated basis.

 To substantiate our conclusion that
the Partnership’s presentation of a single reportable segment is consistent with the general objectives and appropriate under the technical requirements of SFAS No. 131, we will discuss the way management analyzes:

•

Marketing Decisions

•

Operational Decisions

•

Informational Requirements of the Financial Community

 Mr. Barry Stem

 Senior Assistant Chief Accountant

 January 9, 2006

 Page 4 of 11

 As part of our discussion, we have outlined the reports regularly received by Mr. Craft and summarize the manner
in which these reports are used in his analysis and decision making processes.

 Discussion

 Marketing Decisions. We believe the Partnership makes marketing decisions consistent with single reportable segment financial reporting.
Mr. Craft’s management focus is designed to insure that the Partnership meets its primary business objective of achieving sustainable, capital-efficient growth in consolidated cash flow, which will allow for increasing distributions by the
Partnership to its unitholders. In attempting to meet this objective, Mr. Craft manages the Partnership on an enterprise-wide basis for purposes of allocating resources and assessing performance. Mr. Craft’s operating decisions are
made from a market-based perspective and reflect a long-term view of the (i) movement of U.S. coal production into coal markets, particularly those in the Eastern-half of the United States, (ii) current and anticipated demand for the
Partnership’s coal production, and (iii) the Partnership’s ability to supply coal production to meet this demand. The Partnership’s organizational structure is, therefore, designed to provide this operational flexibility. The
Partnership’s operations produce bituminous coal and are located in the Eastern U.S. coal field. The Partnership’s presence in this producing area allows Mr. Craft to maintain a macro view of the coal markets as a whole in this
geographical area.

 Reflecting Mr. Craft’s view of its coal
operations, the Partnership’s marketing function is centralized thereby allowing Mr. Craft to insure that the Partnership as a whole is able to meet the demands of customers in and across various markets. With centralized marketing, the
Partnership is able to allocate coal shipments between the Partnership’s various mining operations to its various customers across the Eastern United States based on the shipment mix that maximizes consolidated cash flows. Assigning coal
shipments in this manner to maximize overall Partnership financial results can and does penalize the profitability of an individual mine(s) with a corresponding benefit for another mine(s). Consequently, Mr. Craft uses consolidated
profitability as a measure to assess performance or for purposes of making resource allocation decisions.

 As summarized below, the attached Exhibit “A” contains examples of the reports used by Mr. Craft for making marketing decisions. Exhibit “A” is provided under separate cover together with a
request under Regulation 200.83 that such information be held in confidence by the SEC. These reports are:

 Sales Production Forecast – (Exhibits “A-1-A” and “A-1-B”): Attached are examples of a report published weekly that
provides budgeted and actual production statistics, plant recovery, saleable product, coal inventories and revenues. This report also reflects sales by coal quality, customer contract and spot market (i.e., “unidentified” or
“UI”) and the

 Mr. Barry Stem

 Senior Assistant Chief Accountant

 January 9, 2006

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transfer of coal sales between mines. Mr. Craft uses this report to monitor coal production, coal inventory, coal available for sale, and coal flows
between our mines and to our customers. Mr. Craft also uses the revenue information contained in the report to determine if, on an enterprise-wide basis, consolidated revenues for a particular quarter are on track to meet consolidated financial
guidance provided to the investment community and internal expectations for consolidated cash flow requirements.

 Exhibit “A-1-A” is the report Mr. Craft reviewed for the period ended December 31, 2004. Although this report includes discrete
financial information for individual mining operations, Mr. Craft does not use such information in his decision making process for allocating resources or assessing performance. Therefore, effective December 31, 2005, discrete financial
information for individual mines has been removed from the report as indicated by the mark-up of the recent 2005 report reflected in Exhibit “A-1-B”. Please note that certain customer pricing information that reflects current estimated
market prices will be retained in this report. These price estimates are indicators of current market conditions, do not include the impact of premium or penalty adjustments for coal quality, and are not used for determining either actual or
forecasted revenues in accordance with generally accepted accounting principles.

 Coal Sales By Customer – (Exhibits “A-2-A” and “A-2-B”): This report is published monthly and provides actual and budgeted tons of coal sold, contracted and spot, and revenues by
customer. Mr. Craft uses this report to monitor the status of tons of coal sold to our contracted customers and the spot market.

 Exhibit “A-2-A” is the report Mr. Craft reviewed for the period ended December 31, 2004. Although this report includes discrete
financial information for individual mining operations, Mr. Craft does not use such information in his decision making process for allocating resources or assessing performance. Therefore, effective December 31, 2005, discrete financial
information for individual mines has been removed from the report as indicated by the mark-up of the recent 2005 report reflected in Exhibit “A-2-B”. As a result of the modifications to this report, Mr. Craft reviews consolidated
information on a customer-by-customer basis for (i) budgeted contract sales, (ii) spot/planned/unidentified sales and (iii) operating revenues.

Operating Plan Revenue Forecast – (Exhibits “A-3-A” and “A-3-B”): This report is published periodically during the year
and reflects estimates over a five year plan horizon for coal sales, revenue, sales by customer and committed/uncommitted tons on a consolidated and individual mine

 Mr. Barry Stem

 Senior Assistant Chief Accountant

 January 9, 2006

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basis. (Please note that Exhibits “A-3-A” and “A-3-B” contains information for the Dotiki mine, which information is representative of
the information included in the report for each of the Partnership’s mining operations.) Mr. Craft uses this report to monitor consolidated revenue estimates, coal sales activity updates from the previous report, coal inventory levels and
unsold coal positions based on projected coal production.

 Exhibit “A-3-A” is the report Mr. Craft reviewed for the period ended December 31, 2004. Although this report includes discrete financial information for individual mining operations, Mr. Craft does not use such
information in his decision making process for allocating resources or assessing performance. Therefore, effective December 31, 2005, discrete financial information for individual mines has been removed from the report as indicated by the
mark-up of the recent 2005 report reflected in Exhibit “A-3-B”.

 Marketing Report (Exhibit “A-4”): This report initially was created in 2005 and is published monthly to reflect sales and marketing opportunities currently under evaluation by the Partnership, the
status of discussions with existing and potential customers and graphical summaries of marketing data for the prior two months. Mr. Craft uses this report to stay apprised of market trends, customer opportunities and positioning within the
eastern U.S. coal markets. This report does not contain discrete financial information for the Partnership’s separate mining operations.

 Operational Decisions. We believe the way the Partnership makes decisions regarding its coal production is consistent with single reportable segment
financial reporting. Given the Partnership’s commitment to maintaining operational flexibility as a foundation to maximize the Partnership’s consolidated cash flows, the focus for the Partnership’s operations group is on minimizing
controllable costs while maximizing productivity on an aggregate basis. Day-to-day management of the Partnership’s coal production is decentralized, with oversight from Mr. Craft and the Partnership’s chief operating officer.
Mr. Craft focuses on key operating metrics to monitor the ability of mine personnel to effectively minimize controllable costs and maximize productivity.

As summarized below, the attached Exhibit “B” contains examples of the reports used by Mr. Craft for making operational decisions. Exhibit “B”
is provided under separate cover together with a request under Regulation 200.83 that such information be held in confidence by the SEC. These reports are:

 Daily Mine Loading Reports (Exhibit “B-1”): Attached are representative examples of the 2005 versions of these reports as reviewed by
Mr. Craft

 Mr. Barry Stem

 Senior Assistant Chief Accountant

 January 9, 2006

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for the period ended December 31, 2004. These reports are published daily by each mine, which allows Mr. Craft to monitor coal inventory levels,
daily and month-to-date production statistics by unit shift, daily and month-to-date saleable yield statistics, daily