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Correspondence

 VIA Facsimile

 March 16, 2006

 Kimberly Calder

 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

 Letter dated February 27, 2006

 File No. 0-26823

 Dear Ms. Calder:

 On behalf of
Alliance Resource Partners, L.P. (the “Partnership”), we are responding to comments made by the accounting staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) (a) in a letter transmitted to
Mr. Joseph W. Craft II on February 27, 2006 and (b) during conference calls with certain members of the Partnership’s management on March 7, 2006.

 As discussed during our conference call, we confirm that our chief operating decision maker (“CODM”) received discrete financial information on a mine-by-mine basis for eleven months during the year 2005.
Modifications to reports received by our CODM were made as of December 31, 2005 that we believe eliminate discrete financial information on a mine-by-mine basis. Based on the changes to the reports currently received by our CODM and consistent
with our conversations, we understand that we may discuss with the Staff our view that for the year 2006 we have a single operating and reportable segment under SFAS 131, paragraph 10.

 As a result of our dialogue with the Staff, we confirm that the Partnership will provide segment disclosure in accordance with Statement of Financial Accounting Standard No. 131 Disclosures about Segment of an
Enterprise and Related Information (“SFAS 131”) in a note to its consolidated financial statements that will be included in its Year 2005 Form 10-K. The form of the segment disclosure is attached as Exhibit “A”.

 Kimberly Calder

 Assistant Chief Accountant

 March 16, 2006

  Page
 2
 of 5

 Proposed Segment Reporting Format

 As explained in the narrative contained in the proposed segment information note, the Partnership is presenting the following three segments: Illinois Basin, Central Appalachia and Northern Appalachia. The Illinois
Basin is comprised of the Dotiki, Gibson, Hopkins, Pattiki and Warrior coal mines. Central Appalachia is comprised of the Pontiki and MC Mining mines. Northern Appalachia is comprised of the Mettiki, Mountain View and Tunnel Ridge mines.

We have included Dotiki in the Illinois Basin. We acknowledge that the Staff expressed a preliminary view that Dotiki should be presented as a separate segment.
However, management believes that Dotiki should be included in any presentation of the Illinois Basin, in particular because of the significant overlap of customers. Shipments on many of our coal supply agreements sourced from the Illinois Basin are
routinely substituted between the Illinois Basin mines (particularly between Dotiki, Hopkins, Pattiki and Warrior). The overlap of customers requires significant coordination between the Illinois Basin mines.

 Dotiki is the first mine operated by the Partnership and has the largest coal reserve base of our active mines. Dotiki’s lower cost per ton reflects, in part,
economies of scale made possible by its large reserve base. Dotiki has the highest number of mining units which contributes to operating efficiencies. We note that despite Dotiki’s advantages with economies of scale, we have made significant
investments in all of our other Illinois Basin mines. Significant investments in other Illinois Basin mines include (a) the purchase of Hopkins in 1998, (b) the development of the current mine shaft access at the Pattiki mine that was
necessitated by a fault line that divides Pattiki’s coal reserve base, (c) the development of Gibson beginning in 1999 with full year production beginning in 2001, and (d) the purchase of Warrior in 2003. These investments reflect our
view of strong profit opportunities in the Illinois Basin and a corresponding allocation of resources to the Illinois Basin.

 We acknowledge that the Staff
expressed a preliminary view that it would be appropriate to aggregate Mettiki with the Illinois Basin. Assuming Dotiki is included in the Illinois Basin, we believe geographical considerations should factor into the aggregation of Mettiki.
Consequently, Mettiki (including Mountain View, which will be the replacement of Mettiki), Tunnel Ridge and Penn Ridge are aggregated as Northern Appalachia.

 As disclosed in previous filings with the SEC, Mountain View is currently being developed and will eventually replace production from the Mettiki mine, which is expected to deplete its reserves at the end of 2006. We purchased Tunnel Ridge
in January 2005 and in December 2005 our newly formed subsidiary, Penn Ridge, entered into a coal lease and sales agreement with affiliates of Allegheny Energy, Inc. The Penn Ridge coal reserves are contiguous to Tunnel Ridge. Coal reserves were the
primary assets purchased in the Tunnel Ridge acquisition. We have initiated the permitting process for both Tunnel Ridge and Penn Ridge properties to allow for the future development of these mines. All three of these properties are located in the
coal field referred to as Northern Appalachia and we believe this presentation provides users of the financial statements the most meaningful aggregation.

 Kimberly Calder

 Assistant Chief Accountant

 March 16, 2006

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 Regulation S-K, Item 101 Considerations

 Assuming the Staff will not object to the segment presentation as reflected in Exhibit “A”, we believe that our Year 2005 Form 10-K will satisfy the
requirements of Item 101 after adding a cross reference to the segment disclosure note in the consolidated financial statements.

 Conclusion

 In light of the chief operating decision maker’s receipt of discrete financial information for a majority of the year in 2005 and as we
consider the objective and basic principles of SFAS 131 in assisting users of financial statements to (a) better understand the enterprise’s performance, (b) better assess its prospects for future net cash flows and (c) make more
informed judgments about the enterprise as a whole, we believe that our proposed segment aggregation represented by the Illinois Basin, Central Appalachia and Northern Appalachia provides the best view through management’s eyes and is the
aggregation users of the financial statements would most expect and, therefore, find most useful.

 ***

 Please feel free to call me at 918.295.7673 if you have any questions.

 Sincerely,

 /s/ Brian L. Cantrell

 Brian L. Cantrell

 Senior Vice President and

 Chief Financial Officer

 Exhibit “A”

 20. SEGMENT INFORMATION

 The Partnership operates in the eastern United States as a
producer and marketer of coal to major United States utilities and industrial users, also located in the eastern United States. The Partnership has the following three reportable segments: the Illinois Basin, Central Appalachia and Northern
Appalachia. The segments also represent the three major coal deposits in the eastern United States. Coal quality, coal seam height, transportation methods and regulatory issues are similar within each of these three segments. The Illinois Basin
segment is comprised of the Dotiki, Gibson, Hopkins, Pattiki and Warrior mines. Central Appalachia segment is comprised of the Pontiki and MC Mining mines. Northern Appalachia segment is comprised of the Mettiki, Mountain View, Tunnel Ridge and Penn
Ridge mines. The Mountain View mine is currently being developed to eventually replace production from the Mettiki mine, which is expected to deplete its coal reserves in late 2006. The Partnership is in the process of permitting the Tunnel Ridge
and Penn Ridge properties for future mine development.

 Operating segment results for the years ended December 31,
2005, 2004 and 2003 are presented below. Other and Corporate, includes marketing and administrative expenses, the Mt. Vernon Transfer Terminal and coal brokerage activity.

 Illinois

 Basin

 Central

 Appalachia

 Northern

 Appalachia

Other and
Corporate (1)

Consolidated

(in thousands)

 Operating segment results for the year ended December 31, 2005 were as follows:

 Total revenues

$
553,908

$
157,203

$
120,423

$
7,184

$
838,718

 Selected production expenses (2)

289,720

94,909

62,425

3,606

450,660

 Segment Adjusted EBITDA (3)

183,075

41,583

36,047

2,924

263,629

 Total assets

274,437

91,853

73,789

92,608

532,687

 Capital expenditures (4)

70,353

23,451

24,435

1,642

119,881

 Operating segment results for the year ended December 31, 2004 were as follows:

 Total revenues

$
391,005

$
147,361

$
112,251

$
2,672

$
653,289

 Selected production expenses (2)

224,540

98,162

51,304

585

374,591

 Segment Adjusted EBITDA (3)(5)

121,763

28,953

41,141

1,432

193,289

 Total assets

216,739

64,241

46,168

85,636

412,784

 Capital expenditures

32,870

14,465

6,605

773

54,713

 Operating segment results for the year ended December 31, 2003 were as follows:

 Total revenues

$
328,586

$
116,443

$
89,933

$
7,785

$
542,747

 Selected production expenses (2)

184,112

77,840

44,521

6,748

313,221

 Segment Adjusted EBITDA (3)

95,351

23,962

27,288

624

147,225

 Total assets

189,079

65,395

43,127

38,853

336,454

 Capital expenditures

26,243

12,134

4,408

219

43,004

(1)
Revenues included in the Other and Corporate column are attributable to Mt. Vernon Transfer Terminal transloading revenues and brokerage coal sales.

(2)
Selected production expenses is comprised of operating expenses and outside purchases (as reflected in the Consolidated Statements of Income), excluding production taxes and
royalties that are incurred as a percentage of coal sales or volumes.

(3)
Segment adjusted EBITDA is defined as net income before income tax expense (benefit), interest expense and interest income, depreciation, depletion and amortization, and general and
administrative expense.

(4)
Capital expenditures includes items received but not yet paid, which is disclosed as non-cash activity, purchase of property, plant and equipment in the supplemental cash flow
information in the Consolidated Statements of Cash Flows.

(5)
The Illinois Basin’s year 2004 segment adjusted EBITDA includes $15.2 million for the net gain from insurance settlement associated with the Dotiki Fire Incident.

Year Ended December 31,

2005

2004

2003

(in thousands)

 Reconciliation of Segment Adjusted EBITDA to net income:

 Segment Adjusted EBITDA

$
263,629

$
193,289

$
147,225

 General & administrative

(33,484
)

(45,400
)

(28,270
)

 Depreciation, depletion and amortization

(55,637
)

(53,664
)

(52,495
)

 Interest expense

(11,816
)

(14,963
)

(15,981
)

 Income taxes

(2,682
)

(2,641
)

(2,577
)

 Net Income

$
160,010

$
76,621

$
47,902

 Reconciliation of Selected Production Expenses to Combined Operating Expenses and Outside Purchases:

 Selected Production Expenses

$
450,660

$
374,591

$
313,221

 Production taxes and royalties

85,941

71,793

64,122

 Combined operating expenses and outside purchases

$
536,601

$
446,384

$
377,343