UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

       DIVISION OF
CORPORATION FINANCE



November 4, 2004

via U.S. mail

Peter T. Socha
President and Chief Executive Officer
James River Coal Company
901 E. Byrd Street, Suite 1600
Richmond, Virginia 23219


Re:	James River Coal Company
	Form S-1 amendment 1 filed October 19, 2004
	File No. 333-118190


Dear Mr. Socha:

	We have reviewed your filing and have the following 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
supplemental information so we may better understand your disclosure.
After reviewing this information, we may or may not 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 any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the
end of this letter.


General

1. We note your response to our prior comment number 2.  It remains
unclear to us how your financial statements are not materially
different as of May 6, 2004 compared to April 30, 2004.  Our position
on the presentation of financial information as of a date other than
the effective date of your emergence from bankruptcy is predicated
upon a lack of material financial statement differences.  It appears
your senior secured credit facility represents an amount that is
material to your financial statements.  As you have not demonstrated
to us a lack of material financial statement differences, it appears
you should amend your filing to present financial information as of
May 6, 2004.

Financial statements

Note - 1 (h) Impairment of Long-Lived Assets, page F-12

2. In our prior comment number 9, we requested an understanding of
the timing of your determination to no longer mine the area you had
referenced.  It appears from your response that you may have
overlooked this aspect of our prior comment.  Please provide a clear
timetable of events relative to your Bledsoe and McCoy Elkhorn
operations and any other operations that contributed significantly to
your abandonment charges, including the date operations were
suspended, the periods of assets being idle, the timing of reserve
determination as being either depleted or uneconomic, and the date of
the abandonment decision.

Note-1 (u) Adoption of New Accounting Pronouncements, page F-15

3. We note your reconciliation of your 2003 asset retirement
obligations.  Tell us the reasons you indicate that no liabilities
were incurred in 2003.  It appears from your disclosures that mining
activities were ongoing during the year, thus it is unclear how no
amount of asset retirement obligations were incurred.


*	*	*


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 supplemental 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 filings reviewed by the staff to be
certain that they have provided all information investors require for
an informed 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 this action as 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 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.

Please direct questions regarding accounting issues and related
disclosures to Kevin Stertzel at (202) 824-5374 or Jill Davis,
Accounting Branch Chief, at (202) 942-1966.  Direct all questions
regarding engineering comments to Ken Schuler, Mining Engineer, at
(202) 824-5527.  Direct questions relating to all other disclosure
issues to Michael McCoy at (202) 942-1908 or, in his absence, to
Timothy Levenberg at (202) 942-1896.   Address replies to us at the
following zip code: 20549-0405.


						Sincerely,



						H. Roger Schwall
						Associate Director


cc:	via facsimile
	David A. Stockton, Esq.
(404) 541-3470 fax
(404) 815-6444 tel.

Jill Davis
Michael McCoy
Kevin Stertzel
Ken Schuler
Tim Levenberg
James River Coal Company
November 4, 2004
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