SecProbe.io

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<TYPE>LETTER
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      November 10, 2005

via U.S. Mail
Vaughn R. Groves, Esq.
Vice-President General Counsel
Alpha Natural Resources, Inc.
406 West Main Street
Abingdon, VA 24210

Re:	Alpha Natural Resources
      Form S-1
		File No. 333-129030
      Filed October 14, 2005
      Annual Report for the Fiscal Year Ended
      December 31, 2004
      Filed March 30, 2005
      File No. 1-32423

Dear Mr. Groves:

      We have limited our review of the above filings to only the
areas commented on below.  Where indicated, we think you should
revise your document in response to these comments.  If you
disagree,
we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with supplemental information so we may better
understand your disclosure.  After reviewing this information, we
may
raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter

Form S-1

Summary, page 1

Nicewonder Acquisition, page 2

1. Please update the disclosure throughout the prospectus to
reflect
the recently announced closing of the Nicewonder acquisitions and
related transactions.  For example, we note that the credit
agreement
entered into in connection with the financing of the transaction
was
for $525 million and not $500 million as currently disclosed.
Please
revise the prospectus, including the description of indebtedness
disclosure, accordingly.

Risk Factors, page 20

Risks Relating to Our Business, page 20

"Our coal mining production and delivery is subject to
conditions...," page 20

2. We note in the Form 8-K filed on November 3, 2005, disclosure
regarding your ongoing attempt to assess the damage and impact to
your operations caused by Hurricane Katrina with respect to your
New
Orleans facilities. If currently known, please update and further
supplement the risk factor disclosure to quantify the dollar
amount
of the damage caused by or related to the impact of the recent
hurricanes.

Principal and Selling Stockholders, page 120

3. Consistent with the requirements of Regulation S-K, please
provide
the information required by Item 507, inclusive of disclosure of
the
number of shares being offered by the selling stockholders.

4. Please disclose if any selling stockholder is a registered
broker-
dealer or affiliate of a registered broker-dealer.  If you
determine
that a selling stockholder is a registered broker-dealer, please
revise your disclosure to indicate that such selling stockholder
is
an underwriter, unless such selling stockholder received its
securities as compensation for investment banking services.  If
any
selling stockholder is an affiliate of a registered broker-dealer,
please disclose, if true, that such selling stockholder acquired
its
shares in the ordinary course of business and at the time of the
acquisition did not have any arrangements or understandings with
any
person to distribute the securities.  If not, you must indicate
that
such selling stockholder is an underwriter.

Underwriting, page 141

5. Please provide the disclosure required by Item 508 of
Regulation
S-K regarding the identity of the underwriters and the
compensation
arrangements in connection with the offering by the selling
shareholders.

Closing Comments

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your response to our
comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  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.

	Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and
* the company may not assert this action as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in connection with our review of your filing
or
in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

	We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of an amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

	You may contact Ryan Milne, Staff Accountant at (202) 551-
7315
or April Sifford, Accounting Branch Chief at (202) 551-3684 if you
have questions regarding comments on the financials statements and
related matters. Please contact Mellissa Campbell Duru, at (202)
551-
3757 or Tangela Richter, Branch Chief at (202) 551-3685 with any
other questions.

							Sincerely,

							H. Roger Schwall
							Assistant Director
cc: 	via facsimile
	Polly Swartzfager, Esq.
	Bartlitt Beck Herman Palenchar & Scott LLP
	(303) 592-3140

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Mr. Groves
Alpha Natural Resources, Inc.
November 10, 2005
page 4

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010

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