MASSEY ENERGY COMPANY
4 North 4th Street
Richmond, Virginia 23219
May 15, 2006
VIA EDGAR AND FACSIMILE (202) 772-9203
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: | Ms. Tangela Richter Division of Corporation Finance Mail Stop 7010 |
Massey Energy Company
Registration Statement on Form S-4
(File No. 333-131415)
Ms. Richter:
Pursuant to Rule 461 of the Securities Act of 1933, as amended, Massey Energy Company and its Co-Registrants hereby request acceleration of effectiveness of the above-referenced Registration Statement on Form S-4 to 12:00 p.m. on May 17, 2006 or as soon thereafter as practicable.
Very truly yours,
MASSEY ENERGY COMPANY | ||
| By: | /s/ Thomas J. Dostart | |
Name: Thomas J. Dostart Title: Vice President, General Counsel & Secretary | ||
| A.T. MASSEY COAL COMPANY, INC. | ||
| By: | /s/ Thomas J. Dostart | |
Name: Thomas J. Dostart Title: Vice President, General Counsel & Secretary | ||
ALEX ENERGY, INC. ARACOMA COAL COMPANY, INC. BANDMILL COAL CORPORATION BANDYTOWN COAL COMPANY BARNABUS LAND COMPANY BELFRY COAL CORPORATION BEN CREEK COAL COMPANY BIG BEAR MINING COMPANY BIG SANDY VENTURE CAPITAL CORP. BLACK KING MINE DEVELOPMENT CO. BLUE RIDGE VENTURE CAPITAL CORP. BOONE EAST DEVELOPMENT CO. BOONE WEST DEVELOPMENT CO. BOONE ENERGY COMPANY CENTRAL PENN ENERGY COMPANY, INC. CENTRAL WEST VIRGINIA ENERGY COMPANY CERES LAND COMPANY CLEAR FORK COAL COMPANY CRYSTAL FUELS COMPANY DEHUE COAL COMPANY DELBARTON MINING COMPANY DEMETER LAND COMPANY DOUGLAS POCAHONTAS COAL CORPORATION DRIH CORPORATION DUCHESS COAL COMPANY DUNCAN FORK COAL COMPANY EAGLE ENERGY, INC. ELK RUN COAL COMPANY, INC. FEATS VENTURE CAPITAL CORP. GOALS COAL COMPANY GREEN VALLEY COAL COMPANY GREYEAGLE COAL COMPANY HADEN FARMS, INC. HAZY RIDGE COAL COMPANY HIGHLAND MINING COMPANY HOPKINS CREEK COAL COMPANY INDEPENDENCE COAL COMPANY, INC. JACKS BRANCH COAL COMPANY JOBONER COAL COMPANY KANAWHA ENERGY COMPANY | ||
| By: | /s/ Richard R. Grinnan | |
Name: Richard R. Grinnan Title: Secretary | ||
KNOX CREEK COAL CORPORATION LAUREN LAND COMPANY LAXARE, INC. LOGAN COUNTY MINE SERVICES, INC. LONG FORK COAL COMPANY LYNN BRANCH COAL COMPANY, INC. MAJESTIC MINING, INC. MARFORK COAL COMPANY, INC. MARTIN COUNTY COAL CORPORATION MASSEY COAL SALES COMPANY, INC. MASSEY GAS & OIL COMPANY MASSEY TECHNOLOGY INVESTMENTS, INC. NEW MARKET LAND COMPANY NEW RIDGE MINING COMPANY NEW RIVER ENERGY CORPORATION NICCO CORPORATION NICHOLAS ENERGY COMPANY OMAR MINING COMPANY PEERLESS EAGLE COAL CO. PERFORMANCE COAL COMPANY PETER CAVE MINING COMPANY PILGRIM MINING COMPANY, INC. POWER MOUNTAIN COAL COMPANY RAVEN RESOURCES, INC. RAWL SALES & PROCESSING, CO. ROAD FORK DEVELOPMENT COMPANY, INC. ROBINSON-PHILLIPS COAL COMPANY RUM CREEK COAL SALES, INC. RUSSELL FORK COAL COMPANY SC COAL CORPORATION SCARLET DEVELOPMENT COMPANY SHANNON-POCAHONTAS COAL CORPORATION SHENANDOAH CAPITAL MANAGEMENT CORP. SIDNEY COAL COMPANY, INC. SPARTAN MINING COMPANY ST. ALBAN’S CAPITAL MANAGEMENT CORP. STIRRAT COAL COMPANY STONE MINING COMPANY SUPPORT MINING COMPANY SYCAMORE FUELS, INC. | ||
| By: | /s/ Richard R. Grinnan | |
Name: Richard R. Grinnan Title: Secretary | ||
T.C.H. COAL CO. TALON LOADOUT COMPANY TENNESSEE CONSOLIDATED COAL COMPANY TENNESSEE ENERGY CORP. THUNDER MINING COMPANY TOWN CREEK COAL COMPANY TRACE CREEK COAL COMPANY VANTAGE MINING COMPANY WHITE BUCK COAL COMPANY WILLIAMS MOUNTAIN COAL COMPANY WYOMAC COAL COMPANY, INC. | ||
| By: | /s/ Richard R. Grinnan | |
Name: Richard R. Grinnan Title: Secretary | ||
| MASSEY COAL SERVICES, INC. | ||
| By: | /s/ Richard R. Grinnan | |
Name: Richard R. Grinnan Title: Assistant Secretary | ||
| HANNA LAND COMPANY, LLC | ||
| By: | ALEX ENERGY, INC., its manager | |
| By: | /s/ Richard R. Grinnan | |
Name: Richard R. Grinnan Title: Secretary | ||
| SHANNON-POCAHONTAS MINING COMPANY | ||
| By: | SHANNON-POCAHONTAS COAL CORPORATION, a partner | |
| By: | /s/ Richard R. Grinnan | |
Name: Richard R. Grinnan Title: Secretary | ||
| By: | OMAR MINING COMPANY, a partner | |
| By: | /s/ Richard R. Grinnan | |
Name: Richard R. Grinnan Title: Secretary | ||
| TUCSON LIMITED LIABILITY COMPANY | ||
| By: | A.T. MASSEY COAL COMPANY, INC., Its manager | |
| By: | /s/ Richard R. Grinnan | |
Name: Richard R. Grinnan Title: Assistant Secretary | ||
MASSEY ENERGY COMPANY
4 North 4th Street
Richmond, Virginia 23219
May 15, 2006
VIA EDGAR AND FACSIMILE (202) 772-9203
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: | Ms. Tangela Richter Division of Corporation Finance Mail Stop 7010 |
Massey Energy Company (the “Company”)
Registration Statement on Form S-4 filed January 31, 2006 (the “Filing”)
File No. 333-131415
Dear Ms. Richter:
In connection with the Company’s response to the comments of the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”) contained in its comment letters to Mr. Thomas J. Dostart, Vice President, General Counsel & Secretary of the Company, dated February 24, 2006 and March 17, 2006, the Company acknowledges the following:
| • | 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 Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Very truly yours,
MASSEY ENERGY COMPANY | ||
| By: | /s/ Thomas J. Dostart | |
Name: Thomas J. Dostart Title: Vice President, General Counsel & Secretary | ||
