July 5, 2006




Mr. Robert Messey
Vice President
Arch Western Resources, LLC
One CityPlace Drive, Suite 300
St. Louis, Missouri 63141


      Re:	Arch Western Resources, LLC
Form 10-K for Fiscal Year Ended December 31, 2005
		Filed March 30, 2006
		File No. 333-107569-03

Dear Mr. Messey:

      We have reviewed your filing and have the following
comments.
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.

Form 10-K for Fiscal Year Ended December 31, 2005

General

1. Please submit all correspondence on EDGAR, including your May
5,
2006 response letter and your response letter to this comment
letter.






Financial Statements

Note 18 - Cash Flow, page F-18

2. We have read the disclosure made in your quarterly report in
response to prior comment 4, explaining that you reclassified
changes
in the note receivable from Arch Coal, Inc. from operating
activities
to investing activities in the statements of cash flows, while
indicating the change would have increased cash flows from
operations, and decreased cash flows from investing activities,
when
compared to the previously reported amounts, by $187.3 million,
$318.8 million, and $62.7 million in 2005, 2004 and 2003.

The changes appear to impact the previously reported measures of
operating cash flows by 527 percent, 157 percent and 94 percent in
2005, 2004 and 2003; and the previously reported measures of
investing cash flows by 472 percent, 367 percent, and 157 percent
in
these same years.  Given the significance of these revisions,
coupled
with the implications for the condensed consolidating information
in
Note 19, and selected financial data on page 29, we believe that
you
should amend your annual report on Form 10-K to correct the
reporting
of these cash flows.  Since an amendment to your annual report is
required, we believe you should also address the other reporting
issues identified in our prior letter in the amended filing as
well,
notwithstanding the changes implemented in your recent quarterly
report on Form 10-Q.

Please include error correction disclosures in your amended
filing,
with a reconciliation of the as previously reported to the
restated
amounts for each of the measures of operating and investing cash
flows.  Any columnar headers over information including those
measures should include "restated" labels.  Please consult with
your
auditors on the language necessary for the audit opinion to comply
with AU Section 420.12.

Closing Comments

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  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.



      You may contact Tracie Towner at (202) 551-3744 if you have
questions regarding comments on the financial statements and
related
matters.  Please contact me at (202) 551-3686 with any other
questions.

								Sincerely,



								Karl Hiller
								Branch Chief
Mr. Robert Messey
Arch Western Resources LLC
July 5, 2006
Page 1




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

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010