Exhibit 8.1



                                October 31, 2003

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549

Ladies and Gentlemen:

         We have acted as counsel to Arch Western Finance, LLC ("Arch") in
connection with the transactions described in Amendment Number 1 to the
Registration Statement on Form S-4 filed with the Securities and Exchange
Commission on October 31, 2003 (Registration No. 333-107569), of which a
prospectus (the "Prospectus") forms a part. In that capacity, we have been
requested to provide our opinions with respect to certain of the federal income
tax consequences of the transactions described in the Prospectus. Except as
otherwise indicated herein, all terms used in this letter have the meaning
assigned to them in the Prospectus.

         Our opinions are based on our understanding of the relevant facts
concerning the transactions described in the Prospectus. We have examined and
are familiar with (1) the Registration Statement, and (2) such other documents
as we have considered necessary for rendering our opinions. In connection with
rendering our opinions, we have also assumed (without any independent
investigation) that:

         1. Original documents (including signatures) are authentic, documents
submitted to us as copies conform to the original documents, and there has been
(or will be by the consummation of the transactions described in the Prospectus)
due execution and delivery of all documents where due execution and delivery are
prerequisites to effectiveness thereof;

         2. Any statement made in any of the documents referred to herein, "to
the best of the knowledge" of any person or party is correct without such
qualification;

         3. All statements, descriptions and representations contained in any of
the documents referred to herein or otherwise made to us are true and correct in
all material respects and no actions have been (or will be) taken that are
inconsistent with such representations; and

         4. All transactions described in the Prospectus will be consummated in
accordance with the definitive agreements filed as exhibits to the Registration
Statement (without any waiver, breach or amendment of any of the provisions
thereof).

Securities and Exchange Commission
October 31, 2003
Page 2


         5. The transactions described in the Prospectus will be reported by
Arch, any relevant affiliate of Arch and holders of notes for United States
federal income tax purposes in a manner consistent with the opinions expressed
below.

         Our opinions are based on the Internal Revenue Code of 1986, as amended
(the "Code"), regulations promulgated thereunder by the United States Treasury
Department (the "Regulations"), Internal Revenue Service rulings, and court
cases interpreting the Code and the Regulations, all as in effect as of the date
of this letter. Any of the Code, Regulations, rulings, or judicial decisions
relied upon could be changed, perhaps retroactively, to affect adversely the
federal income tax consequences of the transactions described in the Prospectus.
Although the opinions expressed in this letter are based on our best
interpretations of existing sources of law, no assurance can be given that such
interpretations would be followed if they became the subject of judicial or
administrative proceedings.

         We have reviewed the section of the Prospectus entitled "Material U.S.
Federal Income Tax Considerations." In our opinion, subject to the limitations,
exceptions, assumptions and conditions set forth in such section and in this
letter, the legal conclusions contained therein as they relate to United States
federal income tax matters represent our opinion as of the date hereof. We are
expressing our opinions only with respect to the foregoing matters and no
opinion should be inferred as to any other matters.

         We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement. We also consent to the references in the Prospectus made
to Kirkpatrick & Lockhart LLP in connection with the descriptions, discussions
or summaries of United States federal income tax matters, including references
under the heading captioned "Material U.S. Federal Income Tax Considerations."



                                                 Very truly yours,



                                                 /s/ KIRKPATRICK & LOCKHART LLP