SecProbe.io

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Mail Stop 0510
April 20, 2005

By U.S. mail and facsimile to (949)609-0594

Mr. Michael Davies
Chief Financial Officer, Reclamation Consulting and Applications,
Inc.
23832 Rockfield Blvd., Suite 275
Lake Forest, CA 92630

Re:	Reclamation Consulting and Applications, Inc.
      Form 10-KSB for the fiscal year ended June 30, 2004
      File No. 0-29881

Dear Mr. Davies:

We have reviewed your response to our letter dated March 2, 2005
and
have the following comments.  We ask that you respond by May 4,
2005.

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.

10-KSB for the Period Ended June 30, 2004

General

1. Where a comment below requests additional disclosures or other
revisions to be made, please show us in your supplemental response
what the revisions will look like.  These revisions should be
included in your future filings.

Liquidity and Capital Resources

2. We note your response to prior comment 8 and appreciate the
additional information you have provided.  Please further explain
your relationship with Canvasback Company Limited and the $650,000
operating line of credit that you secured prior to issuing your
2004
Annual Form 10-KSB.  Please disclose more information about this
financing source in your future filings.

Note 5-Property and Equipment

3. We reviewed your response to prior comment 11 and appreciate
the
additional information you have provided.  Please provide us
additional information regarding your Form 8-K filed on November
15,
2004 stating you would be purchasing from North American Systems,
Inc
a 100% ownership interest in the equipment, machinery, operations
systems and manuals located in West Valley, Utah.  Please tell us
how
the sale of these assets pursuant to the agreement of August 1,
2003
and the purchase of these assets pursuant to the agreement of
November 8, 2004 (if consummated) have been accounted for.

Note 14-Litigation

4. We note your response to prior comment 14 and appreciate the
additional information provided.  Please also tell us the amount
of
money paid by the Company in order to have these shares returned
to
Treasury and settle the lawsuit and how that transaction is
reflected
in your statement of operations and statement of stockholders`
deficit.

Controls and Procedures

5. We reviewed your response to prior comment 16 and note your
disclosure that your "President and Chief Executive Officer and
Chief
Financial Officer concluded that the Company`s disclosure controls
and procedures are effective in providing reasonable assurance
that
information required to be disclosed by the Company in reports
that
it files under the Exchange Act is properly recorded, processed,
summarized and reporting within the time period specified in the
Commission`s rules and procedures."  Revise to clarify, if true,
that
your officers concluded that your disclosure controls and
procedures
are also effective to ensure that information, required to be
disclosed in the reports that you file or submit under the
Exchange
Act, is accumulated and communicated to your management, including
your chief executive officer and chief financial officer, to allow
timely decisions regarding required disclosure.  Refer to Exchange
Act Rule 13a-15.  Alternatively, your officers may conclude that
the
Company`s disclosure controls and procedures are "effective"
without
defining disclosure controls and procedures.

Item 14-Principal Accountant Fees and Services

6. We note your response to prior comment 18 and appreciate the
additional information you have provided.  Please separately
disclose
the fees billed for professional services rendered by the
principal
accountant for each year indicated.  Also, separately state fees
which are not audit related and for those fees describe the
services
performed by the principal accountant.

Certifications-Exhibit 31.1 and 31.2

7. Please amend the certifications you included in your June 30,
2004
Form 10-KSB, September 30, 2004 Form 10-QSB and your December 31,
2004 Form 10-QSB to conform the language to Item 601 (31) of
Regulation S-B.

Please respond to these comments within 10 business days, or tell
us
when you will provide us with a response.  Please provide us with
a
supplemental response letter that keys your responses to our
comments
and provides any requested supplemental information.  Detailed
letters greatly facilitate our review.  Please file your
supplemental
response on EDGAR as a correspondence file.  Please understand
that
we may have additional comments after reviewing your 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.  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 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.

If you have any questions regarding these comments, please direct
them to Mindy Hooker, Staff Accountant, at (202) 824-5459 or to
the
undersigned at (202) 824-5373.

Sincerely,

John Cash
Accounting Branch Chief
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Reclamation Consulting and Applications, Inc.
Form 10-KSB
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510

         DIVISION OF
CORPORATION FINANCE

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