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February 10, 2023
Michael White
Chief Financial Officer
Piedmont Lithium Inc.
32 North Main Street, Suite 100
Belmont, North Carolina
28012
Re:Piedmont Lithium Inc.
Form 10-KT for the Fiscal Year Ending December 31, 2021
Filed February 28, 2022
File No. 001-38427
Dear Michael White:
            We have reviewed your January 26, 2023 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
November 8, 2022 letter.
Form 10-KT for the Fiscal Year Ending December 31, 2021 Filed February 28, 2022
Item 1. Business, page 5
1.We note your response to prior comment 1, including summary language and a list of
additional information that you will provide for the Carolina Lithium Project, as your only
material property, along with proposed language for non-material properties.

Please confirm your understanding that production projections should not be disclosed
unless supported by a technical report summary, prepared in accordance with Subpart
1300 of Regulation S-K. Also revise to remove ounces of gold or associated estimates
concerning neighboring properties in which you do not own a mineral interest.

 FirstName LastNameMichael White
 Comapany NamePiedmont Lithium Inc.
 February 10, 2023 Page 2
 FirstName LastNameMichael White
Piedmont Lithium Inc.
February 10, 2023
Page 2
2.We note that you submitted tables to be utilized in reporting summary mineral resources
and mineral reserves in response to prior comment 3, although Note 3 to the first table
indicates that mineral resources would be reported inclusive of the mineral reserves.

Please revise the proposed format along with any intended future disclosures as necessary
to report all estimates of mineral resources exclusive of mineral reserves to comply with
Item 1304(d)(2) of Regulation S-K, notwithstanding any election by the qualified persons
to include such aggregated quantities in the technical report summary.
Item 15. Exhibits.
Exhibit 96.1, page 49
3.We note your response to prior comment 5, regarding content of the technical report
summary, and have the following additional points that you should address in consultation
with the qualified persons involved in preparing that report. Please ensure that the
technical report summary conforms to the following guidance:

•Although the qualified person may elect to include estimates of mineral resources
inclusive of mineral reserves, the technical report summary must also
include estimates of mineral resources exclusive of mineral reserves to comply with
Item 601(b)(96)(iii)(B)(11)(ii) of Regulation S-K.

•The table of discounted cash flows submitted with your response should be modified
to include a column for cumulative amounts and footnotes with the equations used to
convert production of the mineral reserves into each of the products listed in the
table, such as spodumene concentrate and lithium hydroxide, along with explanations
of how those formulas were established and found to be reasonable.

•The economic analysis provided in Section 19 must include annual cash flow
forecasts based on an annual production schedule for the life of the mining project to
comply with Item 601(b)(96)(iii)(B)(19) of Regulation S-K.
4.We note that in response to prior comment 5, regarding information disclosed about
market studies providing justification for demand or sales over the life of the mine,
pursuant to Item 601(b)(96)(iii)(B)(16) of Regulation S-K, you indicate that you will
supplement the financial modeling information associated with your long term business
plan, with a standalone cash flow model "...based solely upon the processing and sales of
mineral reserves converted to lithium hydroxide," which we understand is representing
your expectation that ore production will occur over approximately eleven years.

However, with regard to Item 601(b)(96)(iii)(B)(19) of Regulation S-K, you refer to
Figures 12-1 and 19-1 (possibly intending reference to Tables 12-1 and 19-1 on pages 121
and 200) of the technical report summary as having "collectively satisfied the substantive
requirements" pertaining to the economic analysis, although you indicate that
additional cash flow details will be provided for some line items in Section 19 and that

 FirstName LastNameMichael White
 Comapany NamePiedmont Lithium Inc.
 February 10, 2023 Page 3
 FirstName LastName
Michael White
Piedmont Lithium Inc.
February 10, 2023
Page 3
reserve information in Section 12 "will be re-cast/overlaid with additional cash flow
information on the basis of processing mineral reserves only...."

We understand from the technical assumptions disclosed on page 202 of the technical
report summary that details of the economic analysis provided in Section 19 are based on
a model that assumes not only production and processing of your mineral reserves into
lithium hydroxide monohydrate over a period of eleven years, but also processing
spodumene concentrate purchased from third parties for an additional twenty years.

Given the objective of the technical report summary, as outlined in Item 601(b)(96)(i) of
Regulation S-K, to support disclosures of mineral resources and mineral reserves, by
identifying and summarizing the underlying scientific and technical information and
conclusions, it is unclear how inclusion of cash flows incremental to those derived from
processing your mineral reserves would be consistent with this objective.

We believe that content throughout the technical report summary should generally be
aligned with this objective.  For example, the economic analysis in Section 19 should
include annual cash flow forecasts based on an annual production schedule for the life of
the mining project, along with measures of economic viability such as net present value
(NPV), internal rate of return (IRR), and payback period of capital.

Please explain to us, with input from the qualified persons, why economics associated
with processing spodumene concentrate acquired from third parties for twenty years
beyond the life of your mine would be appropriately regarded as support for your
disclosures of mineral resources and mineral reserves, in your view; and tell us the extent
to which the mining project would be economic or uneconomic if recovery of the
concentrator and chemical plant costs were dependent upon the mining project alone.

If you believe that you are able to show how financial modeling associated with your long
term business plan has utility in supporting your mineral resources and reserves in the
technical report summary, please submit the entire corresponding annual discounted cash
flow forecasts for our review, and we will further consider your position.
            You may contact John Coleman at 202-551-3610 or Gus Rodriguez at 202-551-3752 if
you have questions regarding comments.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation