EDGAR  EXHIBIT  11


                                                                           DRAFT


                               CONSENT OF COUNSEL


     Re:     Calvert  Impact  Fund,  Inc.
             Calvert  South  Africa  Fund

Ladies  and  Gentlemen:

     As  counsel  to the Calvert Impact Fund, Inc. Calvert South Africa Fund, it
is  my  opinion  that:

(i)     Calvert  Impact  Fund, Inc. is an open-end management company registered
under  the Securities Act of 1933 and the Investment Company Act of 1940, and is
duly organized and validly existing in good standing under the laws of the State
of  Maryland;

(ii)     Calvert  South  Africa  Fund  is a series of Calvert Impact Fund, Inc.;

(iii)     The  Agreement and Plan of Reorganization and the execution and filing
of  the  Plan  have been duly authorized and approved by all requisite action by
the  Board of Directors of Calvert Impact Fund, Inc., and the Plan has been duly
executed  and  delivered by Calvert South Africa Fund and is a valid and binding
obligation  of  Calvert  Impact  Fund, Inc. and its series, Calvert South Africa
Fund;  and

(iv)     Calvert South Africa Fund shares to be issued pursuant to the Agreement
and  Plan  of  Reorganization  (the  "Plan")  have been duly authorized and upon
issuance  thereof in accordance with the Plan will be validly issued, fully paid
and  non-assessable  shares of beneficial interest of Calvert South Africa Fund.

     My  opinion  is based on an examination of documents related to the Calvert
Impact  Fund,  Inc.  Calvert  South  Africa  Fund,  including  its  Articles  of
Incorporation,  its  By-Laws,  other original or photostatic copies of corporate
records,  certificates  of  public  officials,  documents, papers, statutes, and
authorities  as  I  deemed  necessary  to  form  the  basis  of  this  opinion.


Very  truly  yours,


SULLIVAN  &  WORCESTER  LLP
[DATE]