May 24, 2005


via facsimile and U.S. mail

Mr. Lewis E. Walde
Chief Financial Officer
Hecla Mining Company
6500 N. Mineral Drive, Suite 200
Coeur d`Alene, Idaho 83815



	Re:	Hecla Mining Company
		Form 10-K, Filed March 16, 2005
		Response letter dated April 27, 2005
		Form 10-Q, Filed May 10, 2005
		File No. 001-08491

Dear Mr. Walde:

      We have reviewed the above filings and response letter and
have
the following comments.  Our review has been limited to the areas
commented on below.  Where indicated, we think you should revise
your
documents in response to these comments.  If you disagree, we will
consider your explanation as to why our comment is inapplicable or
a
revision is unnecessary.  Please be as detailed as necessary in
your
explanation.  In some of our comments, we may ask you to provide
us
with supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

10-K for the year ended December 31, 2004

Management`s Discussion and Analysis, page 52

General

1. 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.

2. 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 be
continue
to be appropriate in the future.  Refer to Item 303(a)(3)(ii) of
Regulation S-K for guidance.

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

3. 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.

4. Tell us and clarify within your disclosure whether the non-GAAP
measure, Total Cash Costs, is a liquidity or a performance
measure.

		Critical Accounting Policies, page 73

			Revenue Recognition

5. We note your intention to change your accounting policy
footnote
to accurately describe your current use of the forward rate for
provisionally priced contracts at the Greens Creek unit and for
the
Lucky Friday unit, beginning January 1, 2005.  Please submit a
sample
of your intended disclosure.  Note that we believe a description
of
how provisionally priced sales contracts are accounted for is
beneficial to the reader and should include a description of how
the
embedded derivative is separated from the host contract and
accounted
for as a derivative instrument pursuant to SFAS 133.

Note 1:  Summary of Significant Accounting Policies, page F-8

	L. Revenue Recognition and Accounts Receivable, page F-13

6. We note from your response to prior comment 5 that you will
expand
your revenue recognition policy to indicate that your by-product
sales are also recorded as revenues.  Please expand this policy
footnote to identify the operating units that generate by-product
revenue.
10-Q for the quarter ended March 31, 2005

Controls and Procedures, page 45

7. We note your disclosure that based on your evaluation of the
design and operation of your disclosure controls and procedures,
your
Chief Executive Officer and Chief Financial Officer concluded that
your disclosure controls and procedures "were effective as of
March
31, 2005, in ensuring that material information required to be
disclosed in this report has been properly recorded, processed,
summarized and reported within the required time periods."  Revise
to
clarify, if true, that your officers concluded that your
disclosure
controls and procedures are also effective to ensure that
information
required to be disclosed in the reports that you file or submit
under
the Exchange Act is accumulated and communicated to your
management,
including your chief executive officer and chief financial
officer,
to allow timely decisions regarding required disclosure.  See
Exchange Act Rule 13a-15(e).

Closing Comments

      As appropriate, please amend your filings and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
your amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested supplemental information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendments and
responses to our comments.

      You may contact Jennifer Goeken at (202) 551-3721, or in her
absence, Jill Davis at (202) 551-3683, if you have questions
regarding comments on the financial statements and related
matters.
Please contact me at (202) 551-3740 with any other questions.
Direct
all correspondence to the following ZIP code:  20549-0405.

							Sincerely,



							H. Roger Schwall
							Assistant Director


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Hecla Mining Company
May 24, 2005
page 1




UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

         DIVISION OF
CORPORATION FINANCE