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

         DIVISION OF
CORPORATION FINANCE
      Mail Stop 7010

      March 17, 2006

Mr. Thomas J. Dostart
Vice President, General Counsel and Secretary
Massey Energy Company
4 North 4th Street
Richmond, Virginia 23219



      Re:	Massey Energy Company
		Registration Statement on Form S-4
      Amendment No. 1 filed March 3, 2006
		File No. 333-131415

Dear Mr. Dostart:

      We have reviewed you response letter dated March 3, 2006 and
the amended 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 information so we may
better understand your disclosure.  After reviewing this
information,
we may 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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.








Material United States Federal Income Tax Considerations, page 68

1. Revise to clearly state that the disclosure under this caption
is
the opinion of your counsel.  The disclosure that in counsel`s
opinion the statements contained therein are "correct in all
material
respects" is not sufficient in this regard.

2. Remove statements, such as "[t]he following general discussion
summarizes material U.S. federal income...," and "[t]his
discussion
is a summary for general information."  Investors are entitled to
rely on the disclosure in this section.

Exhibit 5.1

3. We note that the registrants of the guarantees are incorporated
in
West Virginia, Virginia, and Kentucky.  The opinion must be
revised
to indicate that your counsel`s opinion relating to the guarantees
is
based on the laws of West Virginia, Virginia, and Kentucky.

Exhibit 8.1

4. Revise to indicate clearly that the disclosure in the
registration
statement is the opinion of counsel.  The sentence indicating that
counsel is of the opinion that the statements in the registration
statement are correct in all material respects is not sufficient
in
this regard.

5. Please remove the statement that "this opinion letter is solely
for the information and use of the addressee" and that it "may not
be
distributed, relied upon for any purpose by any other person,
quoted
in whole or in part or otherwise reproduced in any document, or
filed
with any governmental agency without [y]our express written
consent."

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 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 filing to be certain that the
filing includes all information required under the Securities Act
of
1933 and that they have provided all information investors require
for an informed investment 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 staff comments and the declaration
of
effectiveness as a 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
requesting 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.

      If you have any questions, please contact Carmen Moncada-
Terry
at (202) 551-3687 or, in her absence, the undersigned at (202)
551-
3685.
      					Sincerely,



      					Tangela Richter
      Branch Chief

      cc: 	D. Carter (via facsimile 404-888-4190)
      C. Moncada-Terry

Mr. Thomas J. Dostart
Massey Energy Company
March 17, 2006
Page 3