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

         DIVISION OF
CORPORATION FINANCE
Mail Stop 7010

      February 24, 2006

Mr. Thomas J. Dostart
Vice President, General Counsel and Secretary
Massey Energy Company
4 North 4th Street
Richmond, Virginia 23219



      Re:	Massey Energy Company
		Registration Statement on Form S-4
      Filed January 31, 2006
		File No. 333-131415

Dear Mr. Dostart:

      We have limited our review of your filing to those issues we
have addressed in our comments.  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 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.








Certain United States Federal Income Tax Considerations, page 68

1. As you have not filed as an exhibit your tax opinion, we assume
that you intend to file a short-form opinion.  Please note that
the
executed short-form opinion must be filed as an exhibit prior to
effectiveness.  The opinion must state that the disclosure found
in
the registration statement is the opinion of your counsel.

2. Assuming that the disclosure under this caption constitutes the
opinion of your counsel, we note that the opinion must be revised
to
conform to the standards set forth in Item 601(b)(8) of Regulation
S-
K.  The following items should be revised:
* The caption should reflect the fact that your disclosure
addresses
all the material federal income tax consequences;
* The disclosure must include a statement confirming that the
disclosure is the opinion of your counsel;
* The statement "[t]his discussion is a summary for general
information only and does not consider all aspects of U.S. federal
income tax" suggests that not all material tax consequences have
been
discussed; and
* Your counsel`s opinion regarding the matters he is opining upon
must be expressed in a firm, conclusive manner.  Thus, avoid
statements such as "[t]he exchange of outstanding notes should not
be
a taxable exchange."

3. File as an exhibit the consent of the counsel providing the
opinion.

Legality Matters, page 73

4. Please revise to state that Hunton & Williams LLP is also
opining
on the validity of the guarantees underlying the exchange notes.

Opinion of Hunton & Williams LLP

5. We note that the exchange notes are being issued pursuant to an
indenture governed by New York law.  Your counsel`s opinion must
address whether the indenture is a legally binding contract under
New
York law.  Revise the opinion accordingly.

* * * * *
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 amendment and
responses
to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities Act
of
1933 and that they have provided all information investors require
for an informed investment 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 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.

	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 any 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.


      If you have any questions, please contact Carmen Moncada-
Terry
at (202) 551-3687 or, in her absence, the undersigned at (202)
551-
3685.


      					Sincerely,



      					Tangela Richter
      Branch Chief


cc: 	D. Carter (via facsimile 404-888-4190)
      C. Moncada-Terry

Mr. Thomas J. Dostart
Massey Energy Company
February 24, 2006
Page 2