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United States securities and exchange commission logo





                             June 30, 2022

       Brian L. Cantrell
       Senior Vice President - Chief Financial Officer
       Alliance Resource Partners LP
       1717 South Boulder Avenue, Suite 400
       Tulsa, Oklahoma 74119

                                                        Re: Alliance Resource
Partners LP
                                                            Form 10-K for the
Fiscal Year ended December 31, 2021
                                                            Filed February 25,
2022
                                                            File No. 000-26823

       Dear Mr. Cantrell :

              We have reviewed your June 14, 2022 response to our comment
letter and have the
       following comments. In some of our comments, we may ask you to provide
us with information
       so we may better understand your disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

              After reviewing your response to these comments, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       May 3, 2022 letter.

       Form 10-K for the Fiscal Year ended December 31, 2021

       Summary of Coal Mineral Resources and Reserves, page 58

   1.                                                   We understand from your
response to prior comment 1, that you will disclose the coal
                                                        pricing assumptions for
the Illinois and Appalachian basin resource and reserve estimates.
                                                        However, you indicate
that the pricing range utilized for the Illinois basin resource
                                                        estimate was from
$36.27 to $51.26 per short ton, while the pricing range utilized for the
                                                        same location reserve
estimate was $36.08 to $44.01 per short ton.

                                                        Tell us the reasons for
having different price assumptions when estimating resources
                                                        compared to reserves
and provide a similar explanation in your disclosures.
 Brian L. Cantrell
Alliance Resource Partners LP
June 30, 2022
Page 2
Exhibits 96.1, 96.2, 96.3, 96.4 and 96.5
Section 19 - Economic Analysis, page ES-19

2.       We note that you have arranged to obtain revised technical report
summaries from
         the engineering consultants to address prior comments 5 through 10 and
12, and that you
         propose to file those reports with your second quarter report.
However, as the exhibits are
         required with the annual report and considering the nature of the
content deficiencies, we
         believe that you should amend your annual report with the amendments
to these exhibits.
3.       We note your response to prior comment 11, regarding your tax status,
and that you made
         an election during the first quarter of 2022 for the subsidiary
holding your oil and gas
         interests, Alliance Minerals, LLC, to be taxed as a corporation.

         Please address the likelihood of making any similar elections that
would apply to income
         from your coal mining operations and if other than remote, obtain and
file amendments to
         the technical report summaries that include sensitivity analyses based
on this variant,
         along with discussions of the impact on the results of the economic
assessments, to
         comply with Item 601(b)(96)(iii)(B)(19)(iii) of Regulation S-K.

         If there is a reasonable likelihood of income from your coal mining
operations
         becoming subject to income taxes, as a result of elections or
otherwise, also address this
         uncertainty in MD&A to comply with Item 303(a) of Regulation S-K.
4.       We note your response to prior comment 12 indicating that the
qualified persons will
         modify the various technical report summaries to include tabulations
of the annual cash
         flow forecasts based on the annual production schedules for the life
of the projects.

         Please ask the qualified persons to clearly label each of the cash
flow tables in the
         technical report summaries as pre-tax cash flow, and to disclose the
rationale for the
         assumption regarding income taxes within Section 19 and the Executive
Summary.
        You may contact Ken Schuler, Mine Engineer, at (202) 551-3718, or Karl
Hiller, Branch
Chief, at (202) 551-3686 with any questions.



FirstName LastNameBrian L. Cantrell                            Sincerely,
Comapany NameAlliance Resource Partners LP
                                                               Division of
Corporation Finance
June 30, 2022 Page 2                                           Office of Energy
& Transportation
FirstName LastName
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