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Hecla Mining Correspondence dated April 28, 2005

April 27, 2005

Via Overnight Courier and
EDGAR

Mr. H. Roger Schwall

Assistant Director

United States Securities and Exchange Commission

Division of Corporation Finance

450 Fifth Street, N.W., Mail Stop 4-6

Washington, D.C. 20549-0405

Re:

Hecla Mining Company

Form 10-K for the fiscal year ended December 31, 2004

File No. 001-08491

Dear Mr. Schwall:

        Hecla
Mining Company (the “Company,” “Hecla” or the “Registrant”),
hereby submits this response to the comments of the Staff, as set forth in your letter
dated April 14, 2005 to Mr. Lewis E. Walde, Chief Financial Officer, on the referenced
Annual Report on Form 10-K. This letter should be read in conjunction with the blacklined
version of Form 10-K/A-1 that accompanies it.

        The
supplemental information set forth in this letter has been supplied by the Company for use
herein, and all of the responses set forth herein to the Staff’s comments have been
reviewed and approved by the Company. For convenience, each of the Staff’s
consecutively numbered comments is set forth in italics, followed by the Registrant’s
response. In this letter, all page references in our responses refer to page numbers in
the blacklined version of Form 10-K/A-1.

Business and Properties,
page 1

          1.

          Comment – Glossary of Certain Terms, page 22: Indicate
          how you calculated the “weighted average prices” used in your
          definition of “Proven and  Probable Ore
          Reserves.” Explain why the prices differ for location. Note that the staff
          encourages issuers to use a three year average.

Response: The
prices differ by location because Hecla Mining Company determines the metals prices to be
used for year-end reserves at the operations where Hecla is the operator, but not at
locations where Hecla is not the operator. Hecla’s approach to establishing reserve
prices for the end of 2004 where Hecla is the operator consisted of review of the average
metal prices for the last three years as of September 30, 2004, review of current metals
price forecasts, and consideration of the current metals price environment. The prices
utilized by Hecla approximate the averages for the prior three years, however, they do
not match exactly due to consideration of these other factors. All

properties operated by
Hecla used the metal prices established by Hecla, using the methodology described above
and applied consistently in past years, when calculating reserves. Prices utilized for
properties operated by Hecla compare to three-year averages as follows:

     3-Year Avg through
12/31/04
     Weighted Average
for Reserves
     Difference

     Gold

       361.00

       350.00

       -3.0
        %

     Silver
       5.41

       5.60

       3.5
        %

     Lead
       0.28

       0.28

       0.0
        %

     Zinc
       0.40

       0.42

       5.0
        %

The
Greens Creek Mine is operated by Kennecott Greens Creek Mining Company, a subsidiary of
Kennecott Minerals, who are responsible for reserve calculations at the property.
Kennecott Minerals establishes its own long term metal prices that are used in reserve
calculations.

Operating properties,
page 23

          2.

          Comment: In your description of your mines, disclose the mining
          systems used at each mine, and the relative cost of those systems versus other
          mining systems used in underground mines.

Response:
Disclosure of the mining methods for each of our operating properties is included in the
relevant property description and we provide cost per ton for mining at each of these
operations in our quarterly earnings releases. For examples, please refer to page 24
regarding the La Camorra mine (“Ore is mined primarily by longhole stoping and is
extracted from the stopes using rubber-tired equipment and hauled to the surface in mine
haulage trucks.”), and similar descriptions of mining methods at pages 32, 36, and
39. Mr. Ian Atkinson, Vice President – Exploration and Strategy spoke with the staff
on Tuesday, April 19, 2005 and discussed this comment and we believe that the existing
disclosure is appropriate.

3.
Comment:
Associated with each of your reserve tables:

Disclose if you had a third
party audit or reviewed your reserve estimates within the last three years.

If you have not had any third
party reviews during that time period, disclose that fact.

Supplementally provide a copy of all third party reviews or audits of your reserves for developed and undeveloped properties
within last three years.

2

Response:

Hecla
has revised pages 27, 29, 35, 38, and 40 of Form 10-K/A accordingly. In addition, copies
of the audit and review reports are enclosed as a supplement to this letter.

Management’s
Discussion and Analysis, page 52

Reconciliation
of Total Cash Costs (non-GAAP) to Cost of Sales and Other Direct Production Costs (GAAP),
pages 67-69

          4.

          Comment: We note that you are providing a reconciliation
          between the non-GAAP measure you present as “Total cash cost per ounce
          produced” to “Cost of sales and other direct production
          costs” for your gold and silver operations, as well as for each of your
          individual silver operating properties. As we are unable
          to determine how the schedules you present reconcile directly to the line item
          presented in your Consolidated Statements of Operations
          and Comprehensive Income (Loss), please provide us with a detailed analysis of
          how you have complied with the requirements of Item 10(e)
          of Regulation S-K and/or Regulation G. In addition, support your use of
          “Cost of sales and other direct production costs” as the most directly
          comparable financial measure. In this regard, we believe
          that it would be more appropriate to reconcile to an amount that is fully
          burdened with depreciation, depletion and amortization
          related to the production of ore consistent with SAB Topic 11:B.

Response:

... we are unable to determine how the schedules you present
reconcile directly to the line item presented in your Consolidated Statements of Operations
and Comprehensive Income (Loss) ...

In
the Company’s 10-K/A-1, the above-referenced reconciliation of total cash costs
(non-GAAP) to Cost of Sales and Other Direct Production Costs (GAAP) now concludes with a
table which reconciles to the GAAP amount on the face of the income statement. The total
for the table matches Cost of Sales and Other Direct Production Costs on the Company’s
Consolidated Statements of Operations and Comprehensive Income (Loss), and includes a
referencing caption.

... please provide us with a detailed analysis of how you have
complied with the requirements of Item 10(e) of Regulation S-K and/or Regulation G.

The
Company has disclosed

The most directly comparable financial measure computed in accordance with GAAP

A reconciliation of the differences between the non-GAAP measure and its most directly
comparable GAAP-calculated counterpart (clarified in the 10-K/A-1, as described above)

The reasons why it believes that non-GAAP measures provide useful information to
investors, and how it uses the measures (for which discussion is expanded in the 10-K/A-1;
please refer to discussion directly below)

3

The Company
believes that none of the prohibitions of utilization of non-GAAP measures is applicable.

.
. . support your use of “Cost of sales and other direct production costs” as
the most directly comparable financial measure.

The Company
has expanded the discussion in the opening paragraph of its Reconciliation of Total
Cash Costs (non-GAAP) to Cost of Sales and Other Direct Production Costs (GAAP) so
that the former sentence

Cost of
sales and other direct production costs is the most comparable financial measure
calculated in accordance with GAAP to total cash costs.

        now
reads

Cost of
sales and other direct production costs, which excludes depreciation, depletion, and
amortization, is the most comparable financial measure calculated in accordance
with GAAP to total cash costs. Total cash cost per ounce provides investors and management
with a consistent measure of cash flows generated by operations, and is in frequent use
by publicly-traded precious metals mining companies. “Total cash cost per
ounce” is a measure developed by gold companies in conjunction with the Gold Institute
in an effort to provide a comparable standard, however, there can be no assurance that
Hecla’s reporting of this non-GAAP measure is similar to that reported by
other mining companies.

In
this manner, the Company has maintained a measure in frequent use in the industry and has
clarified its applicability.

In
this regard, we believe it would be more appropriate to reconcile to an amount that is
fully burdened with depreciation, depletion, andamortization related to the production of
ore consistent with SAB Topic 11:B.

The
Company believes it has complied with SAB Topic 11:B as follows:

To the opening sentence of its Reconciliation of Total Cash Costs (non-GAAP) to Cost of
Sales and Other Direct Production Costs (GAAP), the company has added the phrase
“which excludes depreciation, depletion, and amortization” immediately after
“Cost of sales and other direct production costs” (please refer to the
discussion immediately above).

The Company’s Consolidated Statements of Operations and Comprehensive Income
(Loss) discloses depreciation, depletion, and amortization immediately below its line
“Cost of sales and other direct production costs.”

Depreciation, depletion, and amortization is not positioned on the income statement in a
manner which results in reporting a figure for income before depreciation.

          5.

          In footnote (3) to your non-GAAP reconciliation, you indicate that you treat
          gold as a by-product at the San Sebastian unit. We note, however, that
          gold revenue represented between 45% — 50.1% of your total revenues at
          this unit for 2002 – 2004. Based on these percentages, please tell us why
          you  consider gold to be a by-

4

product of the San Sebastian unit for accounting purposes rather than a co-product. We also note your disclosure in
MD&A on page 56, “For the years ended December 31, 2004 and 2003, gold by-product credits were
approximately $6.61 per silver ounce and $4.35 per silver ounce, respectively.” Please add disclosure in
both your MD&A and non-GAAP reconciliation to make clear the dollar amount of gold by-product that you are
crediting to “Cost of sales and other direct production costs.” Additionally, expand your accounting policy to
disclose how you classify by-product revenue and the amount of such revenue for each period reported.

Response:

... please tell us why you consider gold to be a by-product of the San Sebastian
unit for accounting purposes rather than a co-product.

The
Company believes that classification of gold as a by-product in its non-GAAP
cost-per-ounce measures is appropriate for the San Sebastian unit:

The Company discloses a pro forma co-product analysis for the San Sebastian unit in
footnote (3) of its Reconciliation of Total Cash Costs  (non-GAAP) to Cost of
Sales and Other Direct Production Costs (GAAP) (See page 69 of Form 10K/A-1).

On a consolidated basis, the Company discloses gold and silver costs per ounce for the
company as a whole in its MD&A, and believes that this distinction provides greater
clarity for investors.

Identification
of co-products in non-GAAP cost-per-ounce disclosures is not in common use among other
silver and gold mining companies save for Newmont, which discloses co-product costs per
unit for two locations whose primary value is from the sale of base metals produced by
distinct concentrate products.

Please
add disclosure in both your MD&A and non-GAAP reconciliation to make clear the dollar
amount of gold by-product that you are crediting to “Cost of
sales and other direct production costs.”

The
Company discloses gold by-product value in the San Sebastian Unit section of its Reconciliation
of Total Cash Costs (non-GAAP) to Cost of Sales and Other Direct Production Costs
(GAAP) in its MD&A in the line item titled “By-product credits.” In
addition, the Company has added a concluding table which discloses total by-product
credits for all operations, as described above under the response to comment 4. We
note that you are providing a reconciliation between the non-GAAP measure. . .

Additionally,
expand your accounting policy to disclose how you classify by-product revenue and the
amount of such revenue for each period reported.

The
Company has addressed how it classified by-product revenue by expanding its accounting
policy in two areas of its 10-K/A-1.

First,
the opening sentence of financial statement note 1-L has been modified as follows on page
F-13 of the 10-K/A-1, with modifications underlined:

Sales
of all metal products sold directly to smelters (including by-products) are
recorded as revenues when title and risk of loss transfer to the smelter at
forward prices for the estimated month of settlement for the Greens Creek unit, and atcurrent
metals spot prices for the Lucky Friday unit.

5

Second,
the opening sentence of Revenue Recognition under Critical Accounting Policies in the MD&A
has been modified on page 74 of the 10-K/A-1 as follows, with modifications underlined:

Sales
of concentrates and precipitates (including by-products) from the Greens Creek,
Lucky Friday, and San Sebastian units are sold directly to smelters and
recorded as revenues, with recorded amounts adjusted to month-end metals prices until
final settlement.

The
Company has addressed the amount of such revenue within each operation’s Reconciliation
of Total Cash Costs (non-GAAP) to Cost of Sales and Other Direct
Production Costs (GAAP) in a line captioned “by-product credits.” In
addition, a new table has been added in its 10-K/A-1 at page 67 which totals this value
for all operations.

Critical Accounting
Policies, page 73

          6.

          Comment – Revenue Recognition: You state that your revenue
          recognition policy with respect to sales of metal products sold directly to
          smelters is  to record the transaction “at current spot metals
          prices” and that “Due to the time elapsed from the transfer to the
          smelter and the final  settlement with the smelter,” you are
          required to estimate the price your metals will be sold in reporting
          profitability and cash flow. You further  state that “Recorded
          values are adjusted monthly until final settlement at month-end metals prices
          and final metal content.” We note that you have a  similar policy
          for your sales of concentrates and precipitates from the Greens Creek, Lucky
          Friday and San Sebastian units. Based on these  disclosures, tell us how
          you have considered the applicable guidance for embedded derivative instruments,
          commonly referred to as  provisionally-priced metals contracts in the
          industry, in paragraph 12 of SFAS 133. Further note that provisionally priced
          revenue should be  measured using the forward rate. Refer to Topic VII of
          the September 25, 2002 AICPA SEC Regulations Committee meeting highlights, at
          the following  website address:
          http://www.aicpa.org/download/belt/2002_09_25_highlights.pdf.

Response:

Revenues
for the Greens Creek unit are recorded at forward prices for the estimated month of
settlement for all periods reported in the Company’s 10-K. For its Lucky Friday unit,
however, the Company has for many years employed the practice of recording monthly
adjustments to provisionally-priced revenue to reflect current spot prices. The difference
between the Co