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                          March 26, 2021

       Neal Shah
       CFO
       NIOCORP DEVELOPMENTS LTD
       7000 South Yosemite Street Suite 115
       Centennial, Colorado 80112

                                                        Re: NIOCORP
DEVELOPMENTS LTD
                                                            Registration
Statement on Form S-3
                                                            Filed March 19,
2021
                                                            File No. 333-254511

       Dear Mr. Shah:

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. 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.

                                                        Please contact Timothy
Collins at 202-551-3176 with any questions.




                          Sincerely,


                          Division of Corporation Finance

                          Office of Energy & Transportation
       cc:                                              Andrew Thomas