Exhibit 18.1

March 7, 2003

Board of Directors
Millennium Chemicals Inc.
230 Half Mile Road
Red Bank, New Jersey 07701

Dear Directors:

We are providing this letter to you for inclusion as an exhibit to your Form
10-K filing pursuant to Item 601 of Regulation S-K.

We have audited the consolidated financial statements included in the Company's
Annual Report on Form 10-K for the year ended December 31, 2002 and issued our
report thereon dated January 30, 2003, except for Note 8, as to which the date
is March 7, 2003. Note 1 to the financial statements describes a change in
accounting principle from last-in first-out ("LIFO") to first-in first-out
("FIFO") for certain domestic inventories. It should be understood that the
preferability of one acceptable method of accounting over another for inventory
has not been addressed in any authoritative accounting literature, and in
expressing our concurrence below we have relied on management's determination
that this change in accounting principle is preferable. Based on our reading of
management's stated reasons and justification for this change in accounting
principle in the Form 10-K, and our discussions with management as to their
judgment about the relevant business planning factors relating to the change, we
concur with management that such change represents, in the Company's
circumstances, the adoption of a preferable accounting principle in conformity
with Accounting Principles Board Opinion No. 20.

Very truly yours,

/s/ PricewaterhouseCoopers LLP

PricewaterhouseCoopers LLP
Florham Park, NJ