RECLAMATION CONSULTING AND APPLICATIONS, INC.
                      23832 ROCKFIELD BOULEVARD, SUITE 275
                          LAKE FOREST, CALIFORNIA 92630

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NOVEMBER 23, 2005

VIA EDGAR AND FEDERAL EXPRESS
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Securities and Exchange Commission
100 F Street, N.E.
Washington, DC  20549

     Attn:     Pamela A. Long, Assistant Director
               Division of Corporation Finance

               Tamara Brightwell, Esq.

     Re:       Reclamation Consulting and Applications, Inc.
               Preliminary Proxy Statement on Schedule 14A
               File No. 000-29881
               Preliminary Proxy Statement filed July 22, 2005

Ladies and Gentlemen:

     The following  responses address the comments of the reviewing Staff of the
Commission as set forth in a comment letter dated November 2, 2005 (the "Comment
Letter") relating to the Preliminary Proxy Statement on Schedule 14A (the "Proxy
Statement") of Reclamation  Consulting and  Applications,  Inc. (the "Company").
The answers set forth herein refer to each of the Staffs' comments by number.

     We are filing herewith Amendment No. 2 to the Company's Proxy Statement.

                          PRE 14A FILED OCTOBER 21,2005
                          -----------------------------

Proposal 2, page 7
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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 l4A. 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.




Securities and Exchange Commission
November 23, 2005
Page 2 of 3


     Additionally, Item 11(e) requires that you furnish the information required
     by Item  13(a) of  Schedule  14A,  including  fmancial  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.

     Response
     --------

     We have revised our  disclosure  to  incorporate  by  reference  our Annual
     Report on Form  10-KSB  for the fiscal  year  ended  June 30,  2005 and our
     Quarterly  Report on Form 10-QSB for the quarter ended  September 30, 2005.
     In  addition,  we hereby  confirm  that we have  provided  all  information
     required by Item 11 of Schedule 14A.

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 wariants "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.

     Response
     --------

     We have revised our disclosure to state:

     "As of November 23, 2005, we had  $1,300,000 in secured  convertible  notes
     outstanding issued pursant to the Securities  Purchase Agreement dated June
     23,  2005 that may be  converted  into an  estimated  33,911,570  shares of
     common stock at current market prices and outstanding  warrants to purchase
     5,200,000 shares of common stock issued pursant to the Securities  Purchase
     Agreement dated June 23, 2005. Additionally, we have an obligation pursuant
     to the Securities  Purchase Agreement dated June 23, 2005, to sell $700,000
     in secured convertible notes within two days of this regisration  statement
     being declared effective that may be converted into an estimated 18,260,076
     shares of common  stock at  current  market  prices and issue  warrants  to
     purchase 2,800,000 shares of common stock in the near future."

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




Securities and Exchange Commission
November 23, 2005
Page 3 of 3


     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.

     Response
     --------

     We have revised our  disclosure  to indicate  that the secured  convertible
     notes that are convertible into 33,911,570 (formerly  37,142,858) shares of
     common  stock were issued  pursuant to the  securities  purchase  agreement
     dated June 23, 2005.  Furthermore,  we have  clarified  our  disclosure  to
     indicate that the we have an obligation pursuant to the Securities Purchase
     Agreement  dated June 23,  2005,  to sell  $700,000 in secured  convertible
     notes within two days of the resale  regisration  statement  being declared
     effective  that may be  converted  into an estimated  18,260,076  (formerly
     20,000,000) shares of common stock at current market prices.

     We trust that the  foregoing  appropriately  addresses the issues raised by
your recent  Letter of Comment.  Thank you in advance for your prompt review and
assistance.

                                   Very  truly  yours,

                                   /s/  GORDON  DAVIES
                                   -------------------
                                   Gordon Davies
                                   President