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

================================================================================

December 14, 2005

VIA EDGAR AND FEDERAL EXPRESS

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.
                  Registration Statement on Form SB-2
                  File No. 333-126916
                  Registration Statement filed November 23, 2005
                  Preliminary Proxy Statement on Schedule 14A
                  File No. 000-29881
                  Preliminary Proxy Statement filed November 23, 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 December 6, 2005 (the "Comment
Letter") relating to the Registration  Statement on Form SB-2 (the "Registration
Statement")  and the  Preliminary  Proxy  Statement  (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.  3 to the  Company's  Registration
Statement and Amendment No. 3 to the Company's Proxy Statement.

                       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.

Securities and Exchange Commission
December 14, 2005
Page 2 of 3

     Response
     --------

     We have revised our disclosure to state,  "All of the above related parties
     are current  shareholders of our company.  With the exception of Kurt Baum,
     who currently holds approximately 13.4%, none of the above shareholders own
     5% or more of our currently issued shares of common stock. In addition, Mr.
     Fred Davies is the father of Gordan  Davies and Michael  Davies,  our Chief
     Executive Officer and Chief Financial Officer,  respectively,  who are also
     our directors." We believe that our disclosure  satisfies the  requirements
     of 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.

     Response
     --------

     We have  revised  our  disclosure  to state,  "As  necessary,  we will file
     prospectus  supplements to update the  disclosure  concerning the number of
     shares that each selling  stockholder intends to sell and/or has sold, when
     such number of shares,  either individually or in the aggregate,  reaches a
     material level."

                        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
     liquidate 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.

Securities and Exchange Commission
December 14, 2005
Page 3 of 3

     Response
     --------

     We  have  revised  our   disclosure  to  remove  all  references  to  "this
     registration  statement." The revised  language  clearly refers to a resale
     registration  statement  registering the shares of common stock  underlying
     the secured convertible notes and warrants.

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

     Response
     --------

     As we did in our  response  to  comment  one  above,  we have  revised  our
     disclosure  to  state,  "All  of the  above  related  parties  are  current
     shareholders of our company. With the exception of Kurt Baum, who currently
     holds approximately 13.4%, none of the above shareholders own 5% or more of
     our currently  issued shares of common stock. In addition,  Mr. Fred Davies
     is the father of Gordan  Davies and  Michael  Davies,  our Chief  Executive
     Officer  and  Chief  Financial  Officer,  respectively,  who are  also  our
     directors." We believe that our disclosure  satisfies the  requirements  of
     Item 404 of Regulation S-B.

     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