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NATURAL RESOURCE PARTNERS L.P.

601 JEFFERSON STREET, SUITE 3600

HOUSTON, TEXAS 77002

(713) 751-7507

October 3, 2005

Via EDGAR

United States Securities and Exchange Commission

Division of Corporate Finance

100 F Street, NE

Washington D.C. 20549-7010

    Attn:

    H. Roger Schwall

    Re:

    Natural Resource Partners L.P.

Form 10-K, filed February 28, 2005

File No. 001-31465

Dear Mr. Schwall:

     This letter sets forth the responses of Natural Resource Partners L.P. to the comments of the
staff (the “Staff”) of the Securities and Exchange Commission in its comment letter dated September
28, 2005 (the “Comment Letter”). For your convenience, we have repeated each comment of the Staff
exactly as given in the Comment Letter, and set forth below each comment is our response.

     On Friday, September 30, 2005, we discussed the Comment Letter with Ken Schuler and Roger Baer
of the Staff. Based on our conversation, we have agreed to make certain changes to our disclosure
as set forth in the responses below. However, because we do not believe that our investors would
consider any of these changes to be material to an investment decision in Natural Resource
Partners, we do not believe Staff’s comments require an amendment to our 2004 Form 10-K. Instead,
we will agree and commit to include the requested information in our 2005 Form 10-K as indicated in
the responses below.

General

    1.

    Insert a small-scale map showing the location and access to your properties. See Item
102 (3) (B) of Regulation S-K. The maps and the associated groupings as presented on your
website are acceptable. Briefly describe the road, barge and/or railroad access to each of
your properties in the text. Please note that SEC’s EDGAR program now accepts

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October 3, 2005

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    digital maps. So please include these in any future amendments that are uploaded to EDGAR.
It is relatively easy to include automatic links at the appropriate locations within the
document to GIF or JPEG files, which will allow the figures and/or diagrams to appear in the
right location when the document is viewed on the Internet. For more information, please
consult the EDGAR manual, and if you need additional assistance, please call Filer Support
at 202-942-8900. Otherwise provide the map to the engineering staff for our review.

    RESPONSE: As requested by the Staff, we will include in our 2005 Form 10-K maps
similar to those currently presented on our website. The maps will include the major
highway, waterway and rail routes through the major areas where our properties are located.
In addition, the textual disclosure will describe the routes by which our coal travels to
the ultimate customers.

Coal Royalty Revenues, Reserves, and Production, page 6

    2.

    Please provide a table showing the last three years annual production for each of your mines
and the weighted average price received for the coal mined. A mine can be defined as all the
mines that supply a wash plant or the grouping as presented on your website which serve a
common market. It appears that Appalachia in fact serves several markets which should be
separately broken out.

    RESPONSE: As discussed with Mr. Schuler and Mr. Baer of the Staff, because (1) we
are a land company that only owns and leases the coal reserves, (2) do operate any of the
mines located on our properties and (3) do not sell the coal that the operators produce from
our properties, it is extremely difficult for us to determine the weighted average price for
the coal that is mined from our properties. Because we distribute all of our available cash
to our investors, we believe that the more relevant metric is the revenue per ton that we
receive, and this metric is disclosed in our financial statements. However, we do include
disclosure in our MD&A with respect to the general pricing environment in the coal industry
because we believe it is important for our investors to understand the market for our coal.

    With respect to production, our operators do not always report production to us on a mine by
mine basis, so it is difficult for us to track production to specific mines, although we do
track production by leases. We agreed with Mr. Schuler and Mr. Baer that in future filings
we would expand our current disclosure to include production and revenues, including average
gross royalty per ton, for each region in Appalachia as well as the Illinois Basin and the
Northern Powder River Basin.

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October 3, 2005

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    3.

    The production and reserves presented in the tables on page 6 are classified with assumed
moisture contents on an “as-received” basis, rather than in place. The filing states the
moisture assumptions of 6% for Appalachian reserves, 12% for Illinois Basin reserves and 25%
for Northern Powder River Basin reserves. The moisture content of 12% and 25% appear to be
in place moisture measurements and not the salable product delivered. Please check and
verify the “as received” classification for your reserves.

    RESPONSE: We have verified that the moisture content in our current disclosure is
properly classified on an “as-received” basis.

    4.

    In a table, please disclose proven and probable reserves as defined in Industry Guide 7 for
each mine or in grouping similar to that presented on your website serving common markets.

    • Indicate tonnages that are “assigned” to an existing facility and those that have not
been “assigned.”

    • Disclose if the coal is steam or metallurgical, if it is leased or owned, and what is
the BTU content per pound and percentage sulfur. Do not report BTU content as “dry,”
but include natural moisture in the calculation.

    • If coal is reported as tons in the ground, disclose in another column the average
mining and wash plant recoveries in percent; and indicate whether these losses have or
have not been reflected in the total recoverable reserves.

    • In either case, with a footnote clearly disclose if the reserves reported are “in the
ground” or “recoverable.”

    • Provide totals to the table where appropriate.

    By “assigned” and “unassigned,” we mean the following: Assigned reserves means coal which
has been committed by the coal company to operating mine shafts, mining equipment, and plant
facilities, and all coal which has been leased by the company to others. Unassigned
reserves represent coal which has not been committed, and which would require new
mineshafts, mining equipment, or plant facilities before operations could begin in the
property. The primary reason for this distinction is to inform investors which coal
reserves will require substantial investments before production can begin.

    RESPONSE: As disclosed in our response to Comment #2 above, because we are a land
company and do not engage in mining operations, we do not “assign” coal reserves to specific
facilities as our lessees do. We do disclose whether our coal is steam or metallurgical, if
it is leased or owned and the BTU and sulfur content. These disclosures

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October 3, 2005

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    are included on pages 6 and 7 of our 2004 Form 10-K. As we discussed with Mr. Schuler and
Mr. Baer, we will expand these tables to include similar disclosures for each region in
Appalachia. All of the coal reserves that we report are “recoverable” reserves. We will
revise future disclosures to more clearly state this fact. We also agreed to add disclosure
regarding the percentage of our reserves that are currently leased to third parties.

    5.

    Disclose the extent your reserve estimates have been reviewed by third parties, other than
SEC engineers. If you have not used any third parties to review your reserves within the last
three years, disclose this fact. See paragraph (b) (5) of Industry Guide 7.

    RESPONSE: Our reserve estimates were reviewed by independent engineering firms at
the time of our initial public offering in 2002. In connection with the acquisitions that
we have made since our IPO, we have generally relied on third party reserve reports, but as
of the end of 2004, we had not commissioned any new independent studies. In 2005, we have
engaged Marshall Miller to review all of our Appalachian and Illinois Basin reserves and we
have engaged Alan Stagg to review our Montana reserves. We expect this review to continue
through 2006 and will report on the progress of the review in our 2005 Form 10-K.

If you have any questions with respect to the foregoing, please call the undersigned at
713-751-7516 or Kevin Wall, our Vice President and Chief Engineer, at 304-522-5757.

Very truly yours,

/s/ Wyatt L. Hogan

Wyatt L. Hogan

Vice President and General Counsel

cc: Ken Schuler