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NATURAL RESOURCE PARTNERS L.P.

601 JEFFERSON STREET, SUITE 3600

HOUSTON, TEXAS 77002

(713) 751-7507

October 11, 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:

     On October 3, 2005, Natural Resource Partners L.P. responded to the comments of the staff (the
“Staff”) of the Securities and Exchange Commission in its comment letter dated September 28, 2005.
We indicated in our response letter that we would make certain changes to the disclosure in our
2005 Form 10-K. Per our subsequent discussion with Ken Schuler of the Staff, we have included as
Exhibit A to this letter the form of the proposed revised language as it will appear in our
2005 Form 10-K.

     The revisions include expanded tabular disclosure with information related to the sub-regions
of Appalachia, including average royalty revenue per ton calculated on a regional basis. We have
also included statements that all of the reserves presented in the tables are “recoverable”
reserves determined in accordance with Industry Guide 7 and that a specified percentage of the
reserves are leased to third parties. In addition to the attached disclosure, we will also include
maps in our 2005 Form 10-K that are substantially similar to those maps currently on our website at
www.nrplp.com.

     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

EXHIBIT A

Coal Royalty Revenues, Reserves and Production

     The following table sets forth coal royalty revenues and average coal royalty revenue per ton
from the properties that we own or control for the years ending December 31, 2005, 2004 and 2003.
Coal royalty revenues were generated from the properties in each of the areas as follows:

    Average Coal Royalty

    Coal Royalty Revenues

    Revenue Per Ton

    Year Ended December 31,

    2005

    2004

    2003

    2005

    2004

    2003

    (In thousands)

    ($ per ton)

    Area

    Appalachia

    Northern

    Central

    Southern

    Total Appalachia

    Illinois Basin

    Northern Powder River Basin

    Total

     The following table sets forth production data and reserve information for the properties
that we own or control for the years ending December 31, 2005, 2004, and 2003. All of the reserves
reported below are recoverable reserves as determined by Industry Guide 7. As of December 31,
2005, in excess of      % of the reserves listed below were leased to third parties. Coal
production data and reserve information for the properties in each of the areas is as follows:

    Proven and Probable

    Production and Reserves

    Reserves at

    Year Ended December 31,

    2005

    2004

    2003

    2005

    2004

    2003

    (Tons in thousands)

    Area

    Appalachia

    Northern

    Central

    Southern

    Total Appalachia

    Illinois Basin

    Northern Powder River Basin

    Total

     We classify low sulfur coal as coal with a sulfur content of less than 1.0%, medium
sulfur coal as coal with a sulfur content between 1.0% and 1.5% and high sulfur coal as coal with a
sulfur content of greater than 1.5%. Compliance coal is coal which meets the standards of Phase II
of the Clean Air Act and is that portion of low sulfur coal that, when burned, emits less than 1.2
pounds of sulfur dioxide per million Btu. As of December 31, 2005, approximately      % of our
reserves were compliance coal. Unless otherwise indicated, we present the quality of the coal
throughout this Form 10-K on an as-received basis, which assumes 6% moisture for Appalachian
reserves, 12%

moisture for Illinois Basin reserves and 25% moisture for Northern Powder River Basin
reserves. We own both steam and metallurgical coal reserves in Central and Southern Appalachia, and
we own steam coal reserves in Northern Appalachia, the Illinois Basin and the Northern Powder River
Basin. In 2005, approximately      % of the coal royalty revenues from our properties was from
metallurgical coal.

     The following table sets forth our estimate of the sulfur content, the typical quality of our
coal reserves and the type of coal in each area as of December 31, 2005.

Sulfur Content, Typical Quality and Type of Coal

    Sulfur Content

    Typical Quality

    Type of Coal

    Low

    Medium

    High

    Compliance

    (less than

    (1.0% to

    (greater

    Heat Content

    Sulfur

    Area

    Coal(1)

    1.0%)

    1.5%)

    than 1.5%)

    Total

    (Btu per pound)

    (%)

    Steam

    Metallurgical(2)

    (Tons in thousands)

    (Tons in thousands)

    Appalachia

    Northern

    Central

    Southern

    Total Appalachia

    Illinois Basin

    Northern Powder
River Basin

    Total

    (1)

    Compliance coal meets the sulfur dioxide emission standards imposed by Phase II of the
Clean Air Act without blending with other coals or using sulfur dioxide reduction
technologies. Compliance coal is a subset of low sulfur coal and is, therefore, also reported
within the amounts for low sulfur coal.

    (2)

    For purposes of this table, we have defined metallurgical coal reserves as reserves located
in those seams that historically have been of sufficient quality and characteristics to be
able to be used in the steel making process. Some of the reserves in the metallurgical
category can also be used as steam coal.

     Forecasts of our future performance are based on, among other things, estimates of our
recoverable coal reserves. We base our estimates of reserve information on engineering, economic
and geological data assembled and analyzed by our internal geologists and engineers and which is
periodically reviewed by third party consultants. There are numerous uncertainties inherent in
estimating the quantities and qualities of recoverable reserves, including many factors beyond our
control. Estimates of economically recoverable coal reserves depend upon a number of variable
factors and assumptions, any one of which may, if incorrect, result in an estimate that varies
considerably from actual results. These factors and assumptions include:

    •

    future coal prices, mining economics, capital expenditures, severance and excise taxes,
and development and reclamation costs;

    •

    future mining technology improvements;

    •

    the effects of regulation by governmental agencies; and

    •

    geologic and mining conditions, which may not be fully identified by available
exploration data and may differ from our experiences in other areas of our reserves.

     As a result, actual coal tonnage recovered from identified reserve areas or properties may
vary from estimates or may cause our estimates to change from time to time. Any inaccuracy in the
estimates related to our reserves could result in decreased royalties from lower than expected
production by our lessees.