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Western Uranium & Vanadium Corp.

330 Bay Street, Suite 1400

Toronto, Ontario

Canada M5H 2S8

August 9, 2024

Division of Corporation Finance

Office of Energy & Transportation

Securities and Exchange Commission

Washington, D.C. 20549

 Re: Western Uranium & Vanadium Corp.

Form 10-K for the Fiscal Year ended
December 31, 2023

Filed April 16, 2024

File No. 000-55626

Dear Securities and Exchange Commission,

On
behalf of Western Uranium & Vanadium Corp. (“Western” or the “Company”), we hereby respond as follows to
the comment letter from the staff of the Securities and Exchange Commission (the “Staff”) dated July  19, 2024,
relating to the above-referenced Form 10-K for the Fiscal Year ended December 31, 2023 (the “Form 10-K”). Captions and
page references herein correspond to those set forth in the Form 10-K, a copy of the relevant portion of which has been marked with
our proposed changes from the original filing of the Form 10-K and provided as Appendix 1.

Comment:

Form 10-K for the Fiscal Year ended December 31, 2023

Item 9A Controls and Procedures

Management’s Annual Report on Internal Control Over Financial Reporting, page 53

 1. Please amend your filing to include disclosure of management’s assessment of the effectiveness of
your internal control over financial reporting (“ICFR”) as of December 31, 2023. The disclosure should include a statement as
to whether or not it was found to be effective, and should identify the framework used by management to evaluate the effectiveness of
your ICFR. Refer to Item 308(a) of Regulation S-K.

Response:

In response to the Staff’s comment, Western proposes to
amend Item 9A as indicated in Appendix 2. In this draft, we have amended our disclosure for Management’s Annual Report on Internal
Control Over Financial Reporting to include an assessment of the effectiveness of our internal control over financial reporting (“ICFR”)
as of December 31, 2023 and such amendment includes a statement that identifies the framework used by management to evaluate the effectiveness
of our ICFR.

If you have any questions, please do not hesitate
to contact me.

    Sincerely,

    /s/ Robert Klein

    Chief Financial Officer

    1-908-872-7686

    rklein@western-uranium.com

APPENDIX 1

ITEM 9A. CONTROLS AND PROCEDURES

Evaluation of Disclosure Controls and Procedures

As of the end of the period covered
by this report, our principal executive officer and principal financial officer evaluated the effectiveness of our disclosure controls
and procedures (as defined in Rules 13a-15(e) and 15d-15(e) under the Securities Exchange Act of 1934, as amended (the “Exchange
Act”)). Based on their evaluation of our disclosure controls and procedures, our principal executive officer and principal financial
officer concluded that our disclosure controls and procedures were not effective as of December 31, 2023, to ensure that information required
to be disclosed by the Company in the reports that we file or submit under the Exchange Act is (a) recorded, processed, summarized and
reported within the time periods specified in the SEC’s rules and forms and (b) accumulated and communicated to management, including
our principal executive officer and principal financial officer, as appropriate to allow for timely decisions regarding required disclosure.

Description
of Material Weakness

Management has concluded that the Company’s
disclosure controls and procedures were not effective as of December 31, 2023, due to the failure to report disclosures on a timely basis.

Remediation of Material Weakness

Management
has developed a plan and related timeline for the Company to design a set of control procedures and the related required documentation
thereof in order to address this material weakness. However, its implementation was delayed as a decline in commodity prices caused the
Company to pursue aggressive cost cutting and de-staffing which has increasingly concentrated duties on the remaining staff. Until the
Company has the proper staff in place, it likely will not be able to remediate its material weaknesses.

Management’s Annual Report on Internal Control
Over Financial Reporting

Our management
is responsible for establishing and maintaining adequate internal control over financial reporting. Internal control over financial reporting
is a process designed under the supervision and with the participation of our management, including our Chief Executive Officer and Chief
Financial Officer, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements
for external purposes in accordance with accounting principles generally accepted in the United States of America.

As of December
31, 2023, our management assessed the effectiveness of our internal control over financial reporting using the criteria set forth by the
Committee of Sponsoring Organizations of the Treadway Commission, or COSO, in Internal Control-Integrated Framework (2013). Based on this
assessment, management, under the supervision and with the participation of our Chief Executive Officer and Chief Financial Officer, concluded
that, as of December 31, 2023, our internal control over financial reporting was not effective based on those criteria.

Based
upon its assessment as of December 31, 2023, management identified the following material weaknesses in its internal control over financial
reporting, inclusive of the control weakness related to disclosure controls and procedures:

 1. The lack of sufficient dedicated accounting personnel, resulting in
delays around the timely collection of inputs and the preparation and review of financial reporting, as well as the inability to provide
for effective segregation of duties, and

 2. The lack of formal documentation of the design of the control environment
and the related control processes and procedures.

Management
is responsible for establishing and maintaining adequate internal control over financial reporting. Internal control over financial reporting
is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial
statements for external purposes in accordance with generally accepted accounting principles. A company’s internal control over
financial reporting includes those policies and procedures that (i) pertain to the maintenance of records that, in reasonable detail,
accurately and fairly reflect the transactions and dispositions of the assets of the company; (ii) provide reasonable assurance that transactions
are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles, and
that receipts and expenditures of the company are being made only in accordance with authorizations of management and directors of the
company; and (iii) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition
of the company’s assets that could have a material effect on the financial statements.

This annual report does not include
an attestation report of our independent registered public accounting firm regarding internal control over financial reporting. Management’s
report was not subject to attestation by our independent registered public accounting firm pursuant to a provision under the Dodd- Frank
Wall Street Reform and Consumer Protection Act that grants a permanent exemption for non-accelerated filers from complying with Section
404(b) of the Sarbanes-Oxley Act of 2002.

Changes in Internal Control over Financial Reporting

There have been no changes in our internal control over financial reporting
identified in connection with the evaluation required by paragraph (d) of Rules 13a- 15 or 15d-15 under the Exchange Act that occurred
during the Company’s fourth fiscal quarter that have materially affected,, or are
reasonably likely tomaterially affect, our internal control over financial reporting.

APPENDIX 2

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549

FORM 10-K/A

(Amendment No. 1)

(Mark One)

☒ANNUAL REPORT PURSUANT TO SECTION 13
OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the fiscal year ended December 31, 2023

or

☐TRANSITION REPORT PURSUANT TO SECTION
13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the transition period from ______________to
______________

Commission File Number 000-55626

WESTERN URANIUM & VANADIUM CORP.

(Exact Name of Registrant as Specified in Its Charter)

    Ontario, Canada

    98-1271843

    (State or Other Jurisdiction of

Incorporation or Organization)

    (I.R.S. Employer

Identification Number)

    330 Bay Street, Suite 1400

Toronto, Ontario, Canada

    M5H 2S8

    (Address of Principal Executive Offices)

    (Zip Code)

    (970) 864-2125

(Registrant’s Telephone Number, Including
Area Code)

Securities registered pursuant to Section
12(b) of the Act:

    Title of each class

    Trading Symbol(s)

    Name of exchange on which registered

    N/A

Securities registered pursuant to Section
12(g) of the Act:

    Common Shares

(Title of Class)

Indicate by check mark if the registrant is a well-known seasoned issuer,
as defined in Rule 405 of the Securities Act. Yes ☐ No ☒

Indicate by check mark if the registrant is not required to file reports
pursuant to Section 13 or 15(d) of the Act. Yes ☐ No ☒

Indicate by check mark whether the registrant
(1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months
(or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements
for the past 90 days. Yes ☒ No ☐

Indicate by check mark whether the registrant
has submitted electronically every Interactive Data File required to be submitted pursuant to Rule 405 of Regulation S-T (§ 232.405
of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit such files). Yes
☒ No ☐

Indicate by check mark whether the registrant
is a large accelerated filer, an accelerated filer, a non-accelerated filer, a smaller reporting company, or an emerging growth company.
See the definitions of “large accelerated filer,” “accelerated filer,” “smaller reporting company,”
and “emerging growth company” in Rule 12b-2 of the Exchange Act.

    Large accelerated filer ☐
    Accelerated filer ☐

    Non-accelerated filer ☒
    Smaller reporting company ☒

    Emerging growth company ☒

If an emerging growth company, indicate by check
mark if the registrant has elected not to use the extended transition period for complying with any new or revised financial accounting
standards provided pursuant to Section 13(a) of the Exchange Act. ☐

Indicate by check mark whether the registrant
has filed a report on and attestation to its management’s assessment of the effectiveness of its internal control over financial
reporting under Section 404(b) of the Sarbanes-Oxley Act (15 U.S.C. 7262(b)) by the registered public accounting firm that prepared or
issued its audit report.  ☐

If securities are registered pursuant to Section
12(b) of the Act, indicate by check mark whether the financial statements of the registrant included in the filing reflect the correction
of an error to previously issued financial statements. ☐

Indicate by check mark whether any of those error
corrections are restatements that required a recovery analysis of incentive-based compensation received by any of the registrant’s
executive officers during the relevant recovery period pursuant to §240.10D-1(b). ☐

Indicate by check mark whether the registrant
is a shell company (as defined in Rule 12b-2 of the Exchange Act). Yes ☐ No ☒

As of June 30, 2023, the last business day of
the registrant’s most recently completed second fiscal quarter, the aggregate market value of the registrant’s common stock
held by non-affiliates of the registrant was approximately $29.6 million, based on the closing price of the registrant’s common
stock of $0.76 per share.

As of April 15, 2024, 55,223,113 of the registrant’s
no par value common shares were outstanding.

  Auditor Name:

  Auditor Location

  Auditor Firm ID:

  MNP LLP

  Mississauga, Canada

  1930

EXPLANATORY NOTE

This Amendment No. 1 to our annual report on Form
10-K for the fiscal year ended December 31, 2023, which was filed with the Securities and Exchange Commission on April 16, 2024 (the “Original
10-K”), is being filed to amend information in Part I, Item 9A.

No other amendments are being made to the Original
10-K. This amendment does not reflect events occurring after the filing of the Original 10-K or modify or update the disclosure contained
therein in any way other than as required to reflect the amendments discussed above.

    1

ITEM 9A. CONTROLS AND PROCEDURES

Evaluation of Disclosure Controls and Procedures

As of the end of the period covered
by this report, our principal executive officer and principal financial officer evaluated the effectiveness of our disclosure controls
and procedures (as defined in Rules 13a-15(e) and 15d-15(e) under the Securities Exchange Act of 1934, as amended (the “Exchange
Act”)). Based on their evaluation of our disclosure controls and procedures, our principal executive officer and principal financial
officer concluded that our disclosure controls and procedures were not effective as of December 31, 2023, to ensure that information required
to be disclosed by the Company in the reports that we file or submit under the Exchange Act is (a) recorded, processed, summarized and
reported within the time periods specified in the SEC’s rules and forms and (b) accumulated and communicated to management, including
our principal executive officer and principal financial officer, as appropriate to allow for timely decisions regarding required disclosure.

Management’s Annual Report on Internal Control
Over Financial Reporting

Our management is responsible for
establishing and maintaining adequate internal control over financial reporting. Internal control over financial reporting is a process
designed under the supervision and with the participation of our management, including our Chief Executive Officer and Chief Financial
Officer, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements
for external purposes in accordance with accounting principles generally accepted in the United States of America.

As of December 31, 2023, our management
assessed the effectiveness of our internal control over financial reporting using the criteria set forth by the Committee of Sponsoring
Organizations of the Treadway Commission, or COSO, in Internal Control-Integrated Framework (2013). Based on this assessment, management,
under the supervision and with the participation of our Chief Executive Officer and Chief Financial Officer, concluded that, as of December
31, 2023, our internal control over financial reporting was not effective based on those criteria.

Based upon its assessment
as of December 31, 2023, management identified the following material weaknesses in its internal control over financial reporting, inclusive
of the control weakness related to disclosure controls and procedures:

 1. The lack of sufficient
                                            dedicated accounting personnel, resulting in delays around the timely collection of inputs
                                            and the preparation and review of financial reporting, as well as the inability to provide
                                            for effective segregation of duties, and

 2. The
                                            lack of formal documentation of the design of the control environment and the related control