SecProbe.io

Mail Stop 3561
  August 25, 2017

Via E -mail
Mr. Mark Learmonth
Chief Financial  Officer
Caledonia Mining Corporation Plc
3rd Floor, Weighbridge House
Weighbridge , St Helier
Jersey, Channel Islands,  JE2 3NF

Re: Caledonia Mining Corporation Plc
 Form 20-F for the Year Ended  December 31, 2016
Filed March 3 0, 2017
File No. 000 -13345

Dear Mr. Learmonth :

We have reviewed your filing an d have the following comment .  In our comment , we
may ask you to provide us with information so we may better understand your disclosure.

Please respond to the comment  within ten busines s days by provi ding the requested
information or advise  us as soon as possible  when you wil l respond .  If you do not believe our
comment  applies  to your facts a nd circumstances, please tell us why in your response.

After reviewing you r response to the comment , we may have  additional comments.

Form 20 -F for the Year Ended December 31, 2016

Financial Statements

Notes to the Consolidated Financial Statements
4. Significant Accounting Policies
(e) Property Plant and Equipment
(iv) Depreciation, page F -14

1. You state on note 3(a)(i) on page F -7 that i n instances where management is able to
demonstrate the economic recovery of such resources with a high level of confidence,
such additional resources, are included in the calculation of depreciation.  To enhance our
understanding of your accounting policy, please:

 Tell us the percentage and amount of measured, indicated and inferred resources that
you include in the calculation of depreciation.

Mr. Mark Learmonth
 Caledonia Mining Corporation, Plc
 August 25 , 2017
 Page 2

  Tell us how you determine d the economic reco very of the  resources with a high level
of confidenc e to include  in the calculation of depreciation.   Please provide us with
your history  that demonstrates economic recovery of  such resources.
 If inferred resources have been included, please separately address your history of
economic recovery of inferred resources. P lease  tell us your basis for their inclusion
given that the tonnage, grade and mineral content can typically only be estimated with
a low level of confidence and explain to us how you compen sated for this lower
confidence level.
 Tell us the extent to which these resources are currently accessible and the extent to
which future  capital improvements are required to conver t and gain access to them.
Please also tell us whether or not the future capital improvements are included in your
depletion computations and explain your rationale.
 Provide us the amount of depletion expense for each producing mine with and
without the inclusion of inferred resources in the denominator  for the year ended
Decem ber 31, 2016  and the most recently reported 2017 interim period.

            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

You may contact Raj Rajan  at 202-551-3388 or Nasreen Mohammed  at 202 -551-3773  if
you have questions regarding comments on the financial statements and related matters.

 Sincerely,

 /s/Craig Arakawa

Craig Arakawa
Accounting Branch Chief
Office of Beverages, Apparel and
Mining