SecProbe.io

Mail Stop 3561
  October 11 , 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
Response dated September 22, 2017
File No. 000 -13345

Dear Mr. Learmonth :

We have reviewed  your September 22, 2017  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 the comment  within ten busines s days by provi ding the r equested
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.
Unless we note otherwise, our references to prior comments are to comments in our August 25,
2017  letter .

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

Financial Statements

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

1. We note your response to comment 1. To help us further understand your basis for
inclusion of inferred resources in your computation of depreciation, please address the
following:

Mr. Mark Learmonth
 Caledonia Mining Corporation, Plc
 October 11 , 2017
 Page 2

  Provide your historical rates of converting inferred resources to indicated resources
for the past five years and any interim periods in 2017, to the extent available and
demonstrate your history of economic recovery of inferred resources du ring the same
period.

 Provide us the estimated annual conversion rate of inferred resources included in your
life-of-mine plan for the historical and future periods. Also, provide us the expected
ultimate conversion rate for the total inferred resource inc luded in the life -of-mine
plan.

 Compare the amount of inferred resources planned to be mined to the amount of
inferred resources that you actually mined for the past five years and any interim
periods in 2017, to the extent available.

 Tell us how you com pute inferred resources including the estimation methodologies
employed and geologic data considered.   Please include details such as drill hole
spacing, the percentage of inferred resources interpolated between drill holes versus
extrapolated, and differe nces in confidence levels between the inferred versus
indicated categories.

 Please tell us the extent to which you consider inferred resources in your impairment
testing for the assets where you use inferred resources to estimate their useful lives.

2. Please explain to us why your estimates of inferred mineral resources used to calculate
your units of production depreciation are reliable, as contemplated by paragraph 4.41 of
the Conceptual Framework for Financial Reporting issued by the International
Accou nting Standards Board.

3. Provide us the amount of depletion expense for the Blanket mine with and without the
inclusion of inferred resources in the denominator for the most recently reported 2017
interim period.

4. We note the indicated resource and probable  reserve class tonnes disclosed in Table B of
your response for the year ended December 31, 2014 and 2015 do not agree with such
information included in your Form 20 -F the year ended December 31, 2014 and 2015
respectively.   Please reconcile.

Mr. Mark Learmonth
 Caledonia Mining Corporation, Plc
 October 11 , 2017
 Page 3

 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 Arakwaa

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