Mail Stop 7010

      November 2, 2005

Michael Davies
Chief Financial Officer
Reclamation Consulting and Applications, Inc.
23832 Rockfield Boulevard, Suite 275
Lake Forest, California 92630


      Re:	Reclamation Consulting and Applications, Inc.
		PRE R 14A filed October 21, 2005
      File No. 000-29881

Dear Mr. Davies:

		We have limited our review of your filing to those
issues
we have addressed in our comments.  Where indicated, we think you
should revise your document 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 information so we may better understand
your
disclosure.  After reviewing this information, we may 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 filing.
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.

PRE R 14A filed October 21, 2005

Proposal 2, page 7
1. Given that you are proposing to increase the number of
authorized
shares of common stock, some of which will be used to satisfy your
obligations under the Securities Purchase Agreement, you should
include the disclosure required by Item 11 of Schedule 14A as to
the
secured convertible notes.  See Note A of Schedule 14A.  In this
regard, we note your disclosure on pages eight and nine.  Please
confirm that you have provided all the information with respect to
the convertible notes required by Item 11(b) of Schedule 14A,
particularly with regard to Item 202 of Regulation S-B, or revise
to
include such information.
Additionally, Item 11(e) requires that you furnish the information
required by Item 13(a) of Schedule 14A, including financial
statements.  Please revise.  If you believe that you may
incorporate
this information by reference pursuant to Item 13(b), please
revise
the section "Annual Report on Form 10-KSB" on page 20 accordingly.
2. We note your response to prior comment three.  On page nine,
please clarify that some of the convertible notes and
corresponding
warrants have already been sold.  State the estimated number of
common shares that are issuable upon conversion of the notes and
the
exercise of the warrants that have already been sold.  In
addition,
revise the language regarding your obligation to sell convertible
notes and warrants "in the near future" to clarify, if true, that
you
have an obligation to sell convertible notes and warrants to the
investors under the securities purchase agreement five days after
the
registration statement is declared effective.  State the estimated
number of common shares that will be issuable under the
convertible
notes and warrants sold after the registration statement is
declared
effective.
3. We note the statement that secured convertible notes
outstanding
may be converted into an estimated 37,142,858 shares of common
stock
and that you have an obligation to sell secured convertible notes
that may be converted into an estimated 20,000,000 shares of
common
stock.  Please clarify whether the 37,142,858 shares underlying
secured convertible notes include the shares underlying the notes
issued pursuant to the securities purchase agreement.  Clarify
whether the estimated 20,000,000 additional shares to be issued
underlie the secured convertible notes to be sold after the
registration statement is declared effective.  In this regard, see
comment two above.

Closing Comment

		As appropriate, please amend your filing 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 the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.
	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

		In addition, please be advised that the Division of
Enforcement has access to all information you provide to the staff
of
the Division of Corporation Finance in our review of your filing
or
in response to our comments on your filing.

	Please contact Tamara Brightwell, Staff Attorney, at (202)
551-
3751, or in her absence, me at (202) 551-3760 with any questions.


      Sincerely,




      Pamela A. Long
      Assistant Director



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Mr. Michael Davies
Reclamation Consulting and Applications, Inc.
November 2, 2005
page 1



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE