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[Ramco-Gershenson Properties Trust letterhead]

May 20, 2005

Via EDGAR

Securities and Exchange Commission

Division of Corporation Finance

450 Fifth Street, N.W.

Washington, D.C. 20549

Attention: Thomas Flinn

    Re:

    Ramco-Gershenson Properties Trust

Form 8-K filed May 11, 2005

File No. 1-10093

Dear Mr. Flinn:

     This letter is being sent to you by Ramco-Gershenson Properties Trust (the “Company”) in
response to your letter dated May 18, 2005 regarding your comments on the above referenced Form
8-K. The Company is filing today via EDGAR this letter in response to your comments. The
Company’s specific responses to your comments are as follows:

    1.
    Please supplementally explain how the audit committee concluded that Grant
Thornton met the independence requirements of Rules 2-01(b) and (c) of Regulation S-X.
In addition, please supplementally explain the nature and extent of the services that
Grant Thornton provided to the company regarding the documentation and testing of
internal controls. Your response should address, but not be limited to, the following:

    •
    The dates that Grant Thornton started and completed its services

    •
    The specific services that Grant Thornton provided and which
internal controls that Grant Thornton documented and tested

    •
    Whether Grant Thornton performed any services related to the
material weakness identified by the company which led to the
restatement of the company’s financial statements, and if so, the
details regarding any such services performed

    •
    Whether Grant Thornton performed any services related to the
remediation of any internal control deficiency or weakness, and if so,
the nature and timing of the remediation efforts Grant Thornton
provided

Securities and Exchange Commission

May 20, 2005

Page 2

    •
    Whether Grant Thornton provided any services or had any involvement
(direct or indirect) in reporting to the Audit Committee regarding
internal controls, and if so, the dates of Grant’s services or
involvement

     In connection with its engagement of Grant Thornton LLP (“Grant Thornton”) as the independent
registered public accounting firm for 2005, the Audit Committee of the Company’s Board of Directors
concluded that Grant Thornton met the independence requirements of Rules 2-01(b) and (c) of
Regulation S-X. The Audit Committee concluded that the services provided by Grant Thornton to the
Company in 2004 did not affect Grant Thornton’s independence with respect to 2005 and that the
results of the services provided by Grant Thornton during 2004 will not be subject to audit
procedures during the audit of the Company’s 2005 financial statements.

     During 2004, Grant Thornton assisted the Company with the documentation and testing of
internal controls. The Audit Committee engaged Grant Thornton to provide such services on June
28, 2004. Grant Thornton provided such services from the date of engagement though November 2004.
At the end of its engagement, Grant Thornton assisted with the transition of testing of internal
controls to the Company’s internal personnel. Such transition was completed by December 17, 2004,
when Grant Thornton’s engagement ended. The Company’s internal personnel then completed testing of
internal controls for the fourth quarter of 2004, and the Company has continued to modify both its
systems of internal control over financial reporting and the documentation and testing of these
controls.

     The services provided by Grant Thornton consisted of assisting management in finalizing its
documentation of internal controls and developing and executing an independent testing plan to
assess the operational effectiveness of internal control over financial reporting. The cycles
where Grant Thornton assisted in documenting and testing controls were:

    •
    revenues,

    •
    expenditures,

    •
    payroll,

    •
    fixed assets,

    •
    treasury,

    •
    equity and

    •
    financial reporting.

Securities and Exchange Commission

May 20, 2005

Page 3

     During the documentation phase of their engagement, Grant Thornton identified both design
deficiencies and operational deficiencies which were reported to the Audit Committee. These
deficiencies, which consisted mainly of the documentation of the operation of controls, were
remediated by management. Grant Thornton did not provide any additional services related to the
remediation of control deficiencies other than additional testing of the remediation measures
implemented by management. None of the deficiencies identified by Grant Thornton related to the
material weakness identified by management which resulted in a restatement of the Company’s
financial statements for the years ended December 31, 2003 and 2002 and the first, second and third
quarters of 2004. Such material weakness was identified during the close of the Company’s fourth
quarter 2004 financial statements and the preparation of the Company’s Annual Report on Form 10-K,
which took place during early 2005, following the conclusion of Grant Thornton’s engagement.

     Grant Thornton initially met with the Audit Committee on June 10, 2004. During the course of
its engagement, Grant Thornton provided periodic reports to the Audit Committee regarding the
progress of its work. Grant Thornton provided such reports to the Audit Committee at meetings held
on July 21, 2004, September 1, 2004, October 28, 2004 and December 1, 2004.

    2.
    Please supplementally explain the nature of each of the accounting matters you
discussed with Grant Thornton, although none applied to any specific transaction.

     During the course of its engagement to document and test internal controls over financial
reporting, Grant Thornton discussed accounting matters with the Company in the general context of
discussing the necessary controls over financial reporting processes to identify and implement the
appropriate GAAP for certain types of transactions and ensuring the related documentation and
disclosure requirements would be met. The more substantial of these discussions included:

    •
    SFAS 66 — Sales of Real Estate, relating to the Company’s processes and
controls for evaluating real estate transactions as to when to record a sale
and what elements of a transaction are necessary to constitute a sale under the
requirements set forth in SFAS 66 and related literature;

    •
    SFAS 133 — Accounting for Derivative Instruments, primarily relating to
interest rate swaps, particularly as to the Company’s processes and controls
related to appropriate documentation and support required for hedge accounting
by the standard;

Securities and Exchange Commission

May 20, 2005

Page 4

    •
    SFAS 141 — Business Combinations, primarily relating to the processes and
controls required to ensure that the allocation of purchase price to assets
acquired is appropriate;

    •
    SFAS 144 – Accounting for the Impairment or Disposal of Long-Lived Assets,
primarily relating to the Company’s processes and controls for recognizing and
measuring impairment of long-lived assets and recognition of gain or loss on
sales of long-lived assets; and

    •
    FIN 46(R) — Consolidation of Variable Interest Entities, primarily relating
to the Company’s processes and controls over the assessment and accounting for
existing and potential future off-balance sheet joint ventures.

     None of such discussions related to any specific transactions, but the discussions did involve
examples of transactions that the Company has or may enter into from time to time. As noted above,
the nature of the discussions was primarily related to ensuring that the Company’s interpretations
and related processes and controls were sufficient to capture, record and document the applicable
transactions to the extent they impacted the financial reporting process.

     As requested in your letter, the Company acknowledges that:

    •
    The Company is responsible for the adequacy and accuracy of the disclosure
in its filings with the Securities and Exchange Commission (the “Commission”);

    •
    Staff comments or changes to disclosure in response to staff comments in the
filings reviewed by the staff do not foreclose the Commission from taking any
action with respect to the filing; and

    •
    The Company may not assert staff comments as a defense in any proceeding
initiated by the Commission or any person under the federal securities laws of
the United States.

Securities and Exchange Commission

May 20, 2005

Page 5

     If you have any questions or comments regarding this letter, please contact me at (248)
592-6200.

    Very truly yours,

         /s/ Richard J. Smith

    Richard J. Smith

    Chief Financial Officer