July 25, 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 Response Letter Dated July 14, 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 Financial Statements Note 18 - Cash Flow, page F-18 1. We have read your response to prior comment two, explaining that a subsidiary of Arch Coal, Inc. holds 99.5% of your membership interests. However, since you have registered debt, we believe its holders would be interested in having your operating cash flows fairly stated. In this regard, the details about operating cash flows included within the condensed consolidating information disclosed in the notes to your financial statements to comply with Rule 3-10 of Regulation S-X should be prepared in accordance with GAAP. We have consulted with our Division Chief Accountant`s Office and continue to believe that you will need to amend your filing to report changes in the note receivable from Arch Coal, Inc. in the investing activities section of your statements of cash flows to comply with paragraph 17(a) of SFAS 95. We reissue prior comment two. 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 25, 2006 Page 2 UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE MAIL STOP 7010