February 27, 2025 Mark A. Smith President and Chief Executive Officer NioCorp Developments Ltd. 7000 South Yosemite Street, Suite 115 Centennial, Colorado 80112 Re: NioCorp Developments Ltd. Registration Statement on Form S-1 Filed February 19, 2025 File No. 333-285066 Dear Mark A. Smith: 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 S. Levenberg at 202-551-3707 with any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation cc: Andrew Thomas, Esq., of Jones Day