JAMES RIVER COAL COMPANY
901 East Byrd Street
Suite 1600
Richmond, Virginia  23219-4529
804-780-3000

November 10, 2004

VIA EDGAR AND FACSIMILE

Timothy S. Levenberg
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549

Re: James River Coal Company
Registration Statement on Form S-1
File No. 333-118190 – Acceleration Request

Dear Mr. Levenberg:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, James River Coal Company (the “Company”) hereby requests the Securities and Exchange Commission (the “Commission”) to accelerate the effective date of the above-referenced Registration Statement (the “Registration Statement”), and declare the Registration Statement, as may then be amended, effective as of 12:00 p.m., Washington, D.C. time, on Friday, November 12, 2004, or as soon thereafter as practical.

The Company also requests the Commission to specifically confirm such effective date and time to the Company in writing.

The Company acknowledges the following:

a.            Should the Commission or its Staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

b.            The action of the Commission or its Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

c.            The Company may not assert the Commission’s acceleration of the effective date of the Registration Statement as a defense in any proceeding initiated by the Commission or any person under the federal laws of the United States.

Sincerely,

James River Coal Company

/s/ Peter T. Socha
Peter T. Socha
President and Chief Executive Officer

cc:            Kilpatrick Stockton LLP