Mail Stop 7010

						August 23, 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 filed July 27, 2005
File No. 333-126916

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 filed July 27, 2005

June 2005 Securities Purchase Agreement, page 5

1. We note the Securities Purchase Agreement provides for the sale
of
convertible notes in principal amount of $2,000,000 and the sale
of
warrants to purchase 8,000,000 shares of common stock to the
investors pursuant to the Securities Purchase Agreement.  Revise
here, and throughout the prospectus as necessary, to disclose the
principal amount of convertible notes and denomination of the
notes,
as well as the number of warrants being sold to the investors.  In
addition, disclose the consideration paid or to be paid for the
warrants.  In this regard, we note your disclosure on page 29 in
the
Convertible Securities section with regard to the issuance of the
securities and payment for the securities.

Risk Factors, page 6
There Are a Large Number of Shares Underlying our Secured
Convertible
Notes..., page 7

2. Tell us supplementally, and revise your disclosures to clarify,
what you mean when you state that you have an "obligation to sell
secured convertible notes that may be converted into an estimated
13,684,211 shares ... and issue warrants to purchase 5,200,000
shares
of common stock in the near future."  In this regard, we assume
that
your obligation to sell secured convertible notes and issue
warrants
is pursuant to the Securities Purchase Agreement and that the sale
will be completed within five days of this registration statement
becoming effective.  Please also update this disclosure and
disclosure throughout the prospectus to reflect the amount of
notes
and warrants you have issued.  We understood that an additional
$600,000 of notes and warrants, whose underlying shares are being
registered for resale, were to have been issued shortly after the
registration statement was filed.

3. It is unclear what you mean by the statement "All of the
shares,
including all of the shares issuable upon conversion of the
secured
convertible notes and upon exercise of our warrants, may be sold
without restriction."  It appears that the convertible notes and
warrants have been issued pursuant to an exemption from
registration
under the Securities Act and therefore the underlying common stock
would be subject to certain resale restrictions.  Please revise to
clarify, if true, that these shares can be resold pursuant the
prospectus that forms part of this registration statement once the
registration statement is effective.

The Continuously Adjustable Conversion Price..., page 8

4. Please revise this risk factor to discuss the fact that this
downward pressure could encourage short sales by selling security
holders or others.  Please explain short selling and its likely
impact on the market price of your common stock.

Description of Securities, page 29
Warrants, page 29

5. We note that you have issued 2,800,000 warrants to purchase
shares
of common stock and are obligation to issue 5,200,000 additional
warrants.  Please revise to clarify when you are required to issue
the additional warrants and disclose any compensation to be
received
for the warrants.
6. Revise this section to state, if true, that you are registering
the resale of the common stock underlying the warrants discussed
in
the prospectus rather than registering the sale of the common
stock.

Selling Stockholders, page 33

7. Describe here the material transactions and relationships
between
Reclamation Consulting and Application and each of the selling
shareholders during the past three years.  See Item 507 of
Regulation
S-B.  Please describe the transactions in which you issued the
shares
to be resold and the warrants in materially complete terms,
including
the basic terms of all the issuance transactions, including the
dates
the transactions took place, the material terms of the
transactions,
the parties who participated in the transactions and the number of
shares and warrants received by them.  We note that you describe
the
transaction in which you entered into the Securities Purchase
Agreement with the four accredited investors, however, it does not
appear that you have discussed the transactions in which you
issued
the other common shares registered for resale.

8. Revise the selling shareholder table to include a line that
shows
the total number of shares to be offered in this prospectus.

Plan of Distribution, page 31

9. Please tell us whether any of the selling shareholders are a
broker-dealer or an affiliate of broker-dealer.  If any selling
shareholder is a registered broker-dealer, it should be named as
an
underwriter.  If the selling shareholder is an affiliate of a
registered broker-dealer, expand the prospectus to indicate
whether
it acquired the securities to be resold in the ordinary course of
business.  Also indicate whether at the time of the acquisition it
had any agreements, understandings or arrangements with any other
persons, either directly or indirectly, to dispose of the
securities.

10. Please expand your disclosure in the first full paragraph
after
the bullets on page 31 to describe in greater detail Rule 144
under
the Securities Act as it pertains to resales of your common stock.

11. Please revise this section to state that if an underwriter or
broker-dealer is used in the resale of the shares, you will file a
post-effective amendment to disclose the name of the underwriter
and
discuss the material terms of any agreement.

Exhibit 4.1

12. We note the condition set forth in section 7.h. that the buyer
shall have received an opinion of the company`s counsel "in form,
scope and substance reasonably satisfactory to the Buyer" dated as
of
the closing date as a condition precedent to the buyers` purchase
of
the notes and warrants.  We also note the opinion of company`s
counsel must be in substantially the same form as Exhibit D
"attached
hereto", however, it does not appear that the exhibit has been
attached.  Please supplementally provide us with a copy of Exhibit
D.
We may have further comments upon review of the exhibit.

13. Please file a copy of the Securities Purchase Agreement whose
signature pages include the amounts of notes, warrants and
purchase
price each purchaser agreed to buy.

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 this action 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.
August 23, 2005
Page 1



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

         DIVISION OF
CORPORATION FINANCE