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Hecla Mining Correspondence dated June 7, 2005

June 8, 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

Response letter dated April 27, 2005

Form 10-Q for the first quarter ended March 31, 2005

File No. 001-08491

Dear Mr. Schwall:

        Hecla Mining Company
(“we” or “our”) hereby submits this response to the comments of the Staff, as set forth in your letter dated
May 24, 2005 to Mr. Lewis E. Walde, Chief Financial Officer, on the referenced Annual Report on Form 10-K, response letter dated
April 27, 2005 and the Quarter Report on Form 10-Q. This letter should be read in conjunction with the blacklined version of Form
10-K/A-1 that accompanies it.

        We have supplied the
supplemental information set forth in this letter for use herein, and have reviewed and approved all of the responses set forth
herein to the Staff’s comments. For convenience, each of the Staff’s consecutively numbered comments is set forth in
italics, followed by our response. In this letter, all page references in our responses refer to page numbers in the blacklined
version of Form 10-K/A-1. All new text is underlined, while deleted text displays a strikethrough font.

10-K for the year ended December 31, 2004

Management’s Discussion and Analysis, page 52

General

1.

Comment:   We have given consideration
to your response to prior comment 5 regarding your treatment of gold as a by-product at the San Sebastian unit and believe that,
in addition to your non-GAAP reconciliation table, you should expand your MD&A to clearly indicate that you generate
by-product revenues on certain of your operating units. In addition, explain why you believe that presentation of these revenue
streams as a by-product is appropriate, given the percentages at the San Sebastian unit of the by-product to total revenue previously
identified in our prior comment 5.

Response:  We have expanded our MD&A
to indicate that we generate by-product revenues from our Lucky Friday and Greens Creek units, in the same manner as our prior
disclosure for San Sebastian. In addition, we have explained why we believe that the presentation of these revenues as by-products
is appropriate. Please see the text under the MD&A headings The Mexico Segment, Greens Creek, Lucky Friday,
and By-Product Credits,  beginning on pages 62, 63, 64, and 84 within the 10-K/A-1, reproduced below:

The Mexico Segment

       The total cash cost per silver ounce at San Sebastian increased during 2004 to $0.21, from a negative $0.25 during 2003.
While value from by-product gold is significant, contributing 45% and 50% of revenues in 2003 and 2004 for San Sebastian , we believe that identification of silver as the primary product, with gold as a by-product, is
appropriate because:

•

 We have historically presented San Sebastian as a producer primarily of silver based on the original analysis that justified putting the project into
production, and believe that consistency in disclosure is important to our investors, regardless of the relationships of metals prices and production from year to year;

•

 San Sebastian is in a mining district historically identified with silver;

•

 Exploration has been directed toward silver, and recent exploration results have shown a predominant silver content; and

•

 Our mining methods and production planning target silver as our primary product which has been accompanied by a significant gold presence.

 In addition to our treatment of gold as a by-product, we disclose an analysis of San Sebastian total cash cost per ounce on a co-product basis, in which our
total cash costs are allocated to silver and gold based on the revenues generated by each. Please refer to Note 3 of our Reconciliation of Total Cash Costs to Costs of Sales and Other Direct Production Costs and Depreciation,
Depletion, and Amortization (GAAP).

Because we consider gold to be a by-product of our silver production, it offset the increase in average total cash costs during the comparable periods due
primarily to a higher average gold price than in 2003. For the years ended December 31, 2004 and 2003, gold by-product credits were approximately $6.61 per silver ounce and $4.25 per silver ounce, respectively.

Greens Creek

       The total cash costs per silver ounce decreased by approximately 4%, to $1.13 per silver ounce during 2004, from $1.18
per silver ounce during 2003. The decrease in the cost s  per ounce  are is primarily due to increased by-product credits primarily from higher average gold, silver
and base metals prices during 2004. While value from zinc, lead, and gold by-products is significant, we believe that
identification of silver as the primary product, with zinc, lead, and gold as by-products, is appropriate because:

•

 We have historically presented Greens Creek as a producer primarily of silver based on the original analysis that justified putting the project into
production, and believe that consistency in disclosure is important to our investors, regardless of the relationships of metals prices and production from year to year;

•

 Silver accounts for a higher proportion of revenue than any other metal and is expected to do so in the future;

•

 Metallurigal treatment maximizes silver recovery;

•

 The Greens Creek deposit is a massive sulfide deposit containing an unusually high propertion of silver; and

•

 In most of its working araes, Greens Creek utilizes selective mining methods in which silver is the metal targeted for highest recovery.

        We periodically
review our proven and probable reserves to ensure that reporting of primary products and by-products is appropriate. Because we
consider zinc, lead, and gold to be by-products of our silver production, the values of these metals offset increases in operating
costs due to increased prices from 2003 to 2004. For the years ended December 31, 2004 and 2003, zinc, lead, and gold by-product credits net of treatment and freight costs, totaled $5.27 per silver ounce and $4.02 per silver ounce, respectively.

2

       For the year ending
December 31, 2005, we forecast production to total approximately 2.8 million silver ounces, 23,000 gold ounces, and 6,900
tons of lead, and 21,000 tons of zinc.

Lucky Friday

       Due primarily to
increases in operating costs and longer ore haulage, partially offset by higher prices for lead and zinc by-products, the total
cash costs per silver ounce for 2004 increased to $5.12, compared to $4.86 during 2003. While value from lead and zinc
by-products is significant, we believe that identification of silver as the primary product, with zinc and lead as by-products, is
appropriate because:

•

 Silver accounts for a higher proportion of revenue than
any other metal and is expected to do so in the future;

•

 The Lucky Friday unit is situated in a mining district
long associated with silver production; and

•

 The Lucky Friday unit utilizes selective mining methods to
target silver production.

        We periodically
review our proven and probable reserves to ensure that reporting of primary products and by-products is appropriate. Because we
consider lead and zinc to be by-products of our silver production, the values of these metals offset increases in operating costs
due to increased prices from 2003 to 2004. For the years ended December 31, 2004 and 2003, lead and zinc by-product credits, net of treatment and freight costs, totaled $3.29 per silver ounce and $2.52 per silver ounce, respectively.

       For the year ending
December 31, 2005, we forecast production from the Lucky Friday mine to total approximately 3.0 million silver ounces, 16,000 tons
of lead and 4,000 tons of zinc.

By-product Credits  at the San Sebastian Unit in Mexico

        Cash costs per
ounce of silver include significant credits from by-product metals production, including gold, lead, and zinc. Our current view of
our proven and probable reserves indicates that our treatment of gold, lead, and zinc as by-products at the San Sebastian, Greens
Creek, and Lucky Friday units continues to be appropriate. However, management periodically assesses the relationships between
metals produced to ensure that presentation of by-product credits in our calculation of cash costs
per ounce remains appropriate.

3

       Cash costs per ounce
of silver at the San Sebastian unit include significant by-product credits from gold production and the continued increase in the
price of gold. Cash costs per ounce are calculated pursuant to standards of the Gold Institute and are consistent with how costs
per ounce are calculated within the mining industry. For the year ended December 31, 2004, the total cash cost was $0.21 per
silver ounce, compared to a negative $0.25 per silver ounce in 2003, and $1.09 per silver ounce in 2002. For the years ended
December 31, 2004, 2003 and 2002, gold by-product credits were approximately $6.61, $4.25, and $3.76 per silver ounce,
respectively. By-product credits at the San Sebastian unit are deducted from operating costs in the calculation of cash costs per
ounce. If our accounting policy were changed to treat gold production as a co-product, the following total cash costs per ounce
would be reported:

     2004
     2003
     2002

     Silver

     $   3.42

     $   2.14

     $   2.67

     Gold
     $   208

     $   160

     $   181

        Significant
by-product credits are also used in calculation of cash costs per ounce of silver at the Greens Creek and Lucky Friday units. For
these operations, we view zinc, lead, and gold strictly as by-products because:

•

 We have historically presented San Sebastian, Greens Creek, and Lucky Friday as producers primarily of silver based
on the original analyses that justified putting the projects into production, and believe that consistency in disclosure is important to our investors, regardless of the relationships of metals prices and production from year to year;

•

 Silver represents a higher value than any other
metal;

•

 Silver is the primary object of the cost structures at
Greens Creek and Lucky Friday, which utilize selective mining methods for recovery of silver rather than bulk methods for recovery
of lower-value base metals; and

•

 By-products include two other metals for Lucky Friday, and
three other metals for Greens Creek.

 The values of all by-products per ounce of silver produced, net of treatment and freight costs, were:

     2004
     2003
     2002

      Greens Creek
      $     5.27

      $     4.02

      $     2.80

      Lucky Friday
      $     2.26

      $     0.62

      $     0.23

4

       Cash costs per ounce
of silver or gold represent measurements that management uses to monitor and evaluate the performance of
 its  our mining operations that are not in accordance with GAAP. We believe cash costs per ounce of silver or
gold produced provide management and investors an indicat ion or of net cash flow, after consideration of
the realized price received for production sold. Management also uses this measurement for the comparative monitoring of
performance of our mining operations.  generation at each location and on a consolidated basis, as well as providing a
meaningful basis to compare our results to those of other mining companies and other mining operating
properties.  A reconciliation of this non-GAAP measure to cost of sales and other direct production costs and depreciation,
depletion and amortization , the most comparable GAAP measure, can be found under Reconciliation of Total Cash Costs to Costs
of Sales and Other Direct Production Costs and Depreciation, Depletion, and Amortization (GAAP).

2.

Comment:   Include a trend
analysis to identify the amount and type of by-product revenue generated for each period presented and indicate whether or not you
believe, based on your best estimate, that presentation of these revenue streams as by-products will continue to be appropriate in
the future. Refer to Item 303(a)(3)(ii) of Regulation S-K for guidance.

Response:   We have included a trend
analysis showing the effect by-products have on costs per ounce for all operations with by-products in the four sections of the
MD&A reproduced in the foregoing response. We have also indicated in the section By-product Credits that management
periodically assesses the relationships between metals produced to ensure that presentation of by-product credits in calculation
of cash costs per ounce remains appropriate.

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

3.

Comment:   We have reviewed the
revised reconciliation that you will present in an amendment to your 2004 Form 10-K in response to prior comment 4 and continue to
believe that presenting a reconciliation to a GAAP measure that is not fully burdened with depreciation, depletion and
amortization is not the most directly comparable GAAP measure and is not contemplated by SAB Topic 11:B.

Response:   We have amended the
document as indicated below, to reconcile total cash costs (non-GAAP) to cost of sales and other direct production costs and
depreciation, depletion and amortization (GAAP):

On pages ii, 4, 28, 37, 40, 43, 61, 74 and 86 within the document,
the sentence …Reconciliation of Total Cash Costs (non-GAAP) to Cost of Sales and Other Direct Production Costs
(GAAP) has been changed to read …Reconciliation of Total Cash Costs (non-GAAP) to Cost of Sales and Other
Direct Production Costs and Depreciation, Depletion and Amortization (GAAP).

5

On pages 4, 28, 37, 40, 43, 61, 74 and 86 within the document, the
sentence A reconciliation of this non-GAAP measure to cost of sales and other direct production costs, the most comparable GAAP
measure…, has been changed to read A reconciliation of this non-GAAP measure to cost of sales and other direct
production costs and depreciation, depletion and amortization , the most comparable GAAP measure...

On pages 75 and 76 within the reconciliations, depreciation,
depletion and amortization expense has been added directly beneath total cash costs to arrive at Cost of Sales and Other Direct
Production Costs and Depreciation, Depletion and Amortization (GAAP).

On pages 75 and 76 within the reconciliations, both treatment and
freight costs and by-product credits have been increased by the same amount, for Lucky Friday and Greens Creek, with no effect on
reported costs per ounce within the document. During the course of an examination of costs per ounce, we determined that smelter
deductions related to silver had been attributed to by-product values and believe it is more appropriate to display these costs as
a component of treatment and freight charges. The resulting change does not affect the reported costs per ounce within the
document.

On page 74, the opening paragraph as amended in the referenced
Response letter has been changed to the following:

The following tables present reconciliations between non-GAAP
total cash costs to cost of sales and other direct production costs and depreciation, depletion and amortization (GAAP) for our gold (the Venezuela segment only) and silver operations (the Mexico and United States
segments), as well as a reconciliation for each individual silver operating  property  unit , for the years ended December 31, 2004, 2003 and 2002 (in thousands, except costs per ounce).  We
believe cash costs per ounce of silver or gold provide an indicator of cash flow generation at each location and on a consolidated basis, as well as providing a meaningful basis to compare our results to those of other mining
companies and other operating mining properties.   Total cash costs include all direct