Mail Stop 7010

							December 6, 2005

via U.S. mail and Facsimile

Gordon Davies
President
Reclamation Consulting and Applications, Inc.
23832 Rockfield Boulevard, Suite 275
Lake Forest, California 92630

	Re:	Reclamation Consulting and Applications, Inc.
Form SB-2/A filed November 23, 2005
File No. 333-126916
PRE R 14A filed November 23, 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 supplemental 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.

Form SB-2/A filed November 23, 2005

Certain Relationships and Related Transactions, page 33

1. We note your response to prior comment seven.  As some of the
parties identified are not discussed elsewhere in the prospectus,
please revise this section to include a discussion of each related
party`s relationship with the issuer.  See Item 404 of Regulation
S-
B.

Plan of Distribution, page 39

2. We note your response to prior comment ten.  We directed you to
telephone interpretation 3S of the March 1999 supplement to
provide
an example, by analogy, for when you should file a prospectus
supplement.  Please note that the analysis for when a prospectus
supplement should be filed to disclose resales by the selling
shareholders would be similar regardless of the form type used to
register the resale. Therefore, revise this section to disclose
that
upon the conversion of the notes or exercise of the warrants and
subsequent resale of the underlying shares by the selling
shareholders, you will file a prospectus supplement as necessary
to
update the disclosure of the number of shares that each selling
shareholder intends to sell and reflecting prior resales.  In this
regard, we note that your plan of distribution currently
contemplates
filing a prospectus supplement only when a selling shareholder
notifies you of a material arrangement with a broker-dealer.

PRE R 14A filed November 23, 2005

3. Please revise your disclosures, as appropriate, to refer to the
proxy statement rather than "this registration statement being
declared effective".  For example, see the language added to the
Secured Convertible Notes section and the section added discussing
your obligation to pay liquidated damages.  It appears that these
sections have been copied directly from the registration
statement.
If you wish to refer to having the registration statement declared
effective, you should revise your discussions to clearly convey
that
the registration statement is a document separate from the proxy
statement that is being sent to shareholders regarding the
proposed
increase in authorized shares.

4. Given that you have included a discussion of related parties
and
transactions, please revise to include the information requested
by
comment one above.


Closing Comments

      As appropriate, please amend your registration statement in
response to these comments.  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 supplemental 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 filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed 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.

	Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

?	should the Commission or the staff, acting pursuant to
delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
?	the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and
?	the company may not assert staff comments and the declaration
of
effectiveness 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 connection with our review of
your
filing or in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      Please direct questions on disclosure issues to Tamara
Brightwell, Staff Attorney, at (202) 551-3751 or, in her absence,
to
me at (202) 551-3760.


	Sincerely,



	Pamela A. Long
	Assistant Director


cc: 	Andrea Cataneo, Esq.
	Sichenzia Ross Friedman Ference LLP
	1065 Avenue of the Americas, 21st Floor
	New York, New York 10018
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Gordon Davies
Reclamation Consulting and Applications, Inc.
December 6, 2005
Page 1



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

         DIVISION OF
CORPORATION FINANCE