SecProbe.io

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                    Skadden, Arps, Slate, Meagher & Flom LLP
                              333 West Wacker Drive
                             Chicago, Illinois 60606

                                                                  August 9, 2005

Mr. Larry Greene
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C.  20549

                             Re:  Van Kampen Pennsylvania Value Municipal
                             Income Trust -- Registration Statement on Form N-14
                             (the "Registration Statement")
                             (File Nos. 333-126292 and 811-07398)

Dear Mr. Greene:

                  Thank you for your telephonic comments regarding the
Registration Statement on Form N-14 for Van Kampen Pennsylvania Value Municipal
Income Trust (the "Acquiring Fund" or the "Registrant") filed with the
Securities and Exchange Commission (the "Commission") on June 30, 2005 in
connection with the proposed reorganizations (the "Reorganizations") of Van
Kampen Advantage Pennsylvania Municipal Income Trust, Van Kampen Pennsylvania
Quality Municipal Trust and Van Kampen Trust for Investment Grade Pennsylvania
Municipals (the "Target Funds") into the Acquiring Fund. On behalf of the
Acquiring Fund, we have summarized your comments to the best of our
understanding, below which we have provided our response to those comments. We
have not included comments which we resolved in the course of our conference
call with you. Where changes were necessary in response to your comments, they
are reflected in Pre-Effective Amendment No. 1 to the Acquiring Fund's
Registration Statement on Form N-14, which will be filed on or about August 9,
2005. The Target Fund and the Acquiring Fund are referred to herein collectively
as the "Funds."

COMMENTS TO THE JOINT PROXY STATEMENT/PROSPECTUS

COMMENT 1.        UNDER "QUESTIONS & ANSWERS," IN THE RESPONSE TO THE SECOND
                  QUESTION, REVISE THE DISCLOSURE TO MORE FULLY EXPLAIN THE
                  REASONS FOR THE PROPOSED REORGANIZATIONS.

Response 1.       The Funds respectfully submit that they have adequately
                  conveyed the reasons for the proposed Reorganizations. The
                  Funds respond to that question as follows:

                           The Board of Trustees of each Fund has determined
                           that each Reorganization will benefit common
                           shareholders of the respective Target Fund and the
                           Acquiring Fund. The Target Funds and the Acquiring
                           Fund are similar. Each Fund seeks to provide common
                           shareholders with a high level of current income
                           exempt from federal and Pennsylvania income tax, and
                           where possible under local law, local income and
                           personal property taxes, consistent with preservation
                           of capital, by investing substantially all of its
                           assets in Pennsylvania municipal securities rated
                           investment grade at the time of investment.
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                           Each Fund is managed by the same investment advisory
                           personnel. After the Reorganizations, it is
                           anticipated that common shareholders of each Fund
                           will experience a reduced annual operating expense
                           ratio, as certain fixed administrative costs will be
                           spread across the combined fund's larger asset base.

                  This disclosure notes that the Funds pursue substantially
                  similar investment objectives and strategies and are managed
                  by the same investment advisory personnel. These facts serve
                  as important background for the primary reason for the
                  Reorganizations -- the anticipated reduced annual operating
                  expense ratio for common shareholders of each Fund. Given that
                  the Funds pursue substantially similar investment objectives
                  and strategies and are managed by the same investment advisory
                  personnel, common shareholders of each Fund should find the
                  anticipated reduced annual operating expense ratio as a
                  compelling reason to support the Reorganizations of their
                  Fund.

COMMENT 2.        UNDER THE "FEE, EXPENSE AND DISTRIBUTIONS ON PREFERRED SHARES
                  TABLE FOR COMMON SHAREHOLDERS OF THE FUNDS," THE FUNDS MAY
                  DELETE ALL REFERENCES TO ANY FEE DESCRIPTIONS FOR WHICH NO
                  CLASS OF SHARES PAYS SUCH FEES.

Response 2.       The Funds acknowledge the comment and opt to continue to show
                  these captions.

COMMENT 3.        UNDER "PROPOSAL 1 -- COMPARISON OF THE FUNDS -- OTHER
                  INVESTMENT PRACTICES AND POLICIES -- STRATEGIC TRANSACTIONS,"
                  PROVIDE ADDITIONAL DISCLOSURE REGARDING EACH FUND'S COMPLIANCE
                  WITH APPLICABLE REGULATORY REQUIREMENTS WHEN IMPLEMENTING
                  STRATEGIC TRANSACTIONS.

Response 3.       Each Fund may engage in certain strategic transactions,
                  such as put and call options, financial futures contracts and
                  interest rate transactions such as swaps, caps, floors or
                  collars. The Funds disclose that they "compl[y] with
                  applicable regulatory requirements when implementing these
                  strategies, techniques and instruments." This general
                  disclosure provides the Funds with flexibility to adjust to
                  changes in applicable law, rules, regulations or exemptive
                  relief. The Funds acknowledge the Staff's comment but do not
                  believe that additional disclosure is necessary.

COMMENT 4.        UNDER "PROPOSAL 1 -- INFORMATION ABOUT THE REORGANIZATIONS
                  -- MATERIAL U.S. FEDERAL INCOME TAX CONSEQUENCES OF THE
                  REORGANIZATIONS," PROVIDE DISCLOSURE REGARDING CAPITAL LOSS
                  CARRYFORWARDS, IF APPLICABLE.

Response 4.       The Funds respectfully submit that the rule applicable to
                  capital loss carryforwards is not material with respect to the
                  Reorganizations and therefore no such disclosure is necessary.

COMMENT 5.        UNDER "OTHER INFORMATION -- SHAREHOLDER PROPOSALS," PROVIDE
                  THE DISCLOSURE REQUIRED BY RULE 14A-8(e) OF REGULATION 14A.

Response 5.       The Funds have added the requested disclosure.

COMMENTS TO THE STATEMENT OF ADDITIONAL INFORMATION (SAI)

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COMMENT 6.        UNDER "TRUSTEES AND OFFICERS -- BOARD COMMITTEES," INDICATE
                  WHETHER THE MEMBERS OF THE BOARD'S BROKERAGE AND SERVICES
                  COMMITTEE ARE INTERESTED TRUSTEES.

Response 6.       The first paragraph of that section reads as follows:

                           "The Board of Trustees has three standing committees
                           (an audit committee, a brokerage and services
                           committee and a governance committee). Each committee
                           is comprised solely of 'Independent Trustees,' which
                           is defined for purposes herein as trustees who: (1)
                           are not 'interested persons' of the Fund as defined
                           by the 1940 Act and (2) are 'independent' of the Fund
                           as defined by the New York Stock Exchange, American
                           Stock Exchange and Chicago Stock Exchange listing
                           standards."

                  Thus, the Funds do not believe that additional disclosure is
                  necessary.

COMMENT 7.        IN THE FIFTH PARAGRAPH UNDER "INVESTMENT ADVISORY
                  AGREEMENT," DISCUSS THE FACTORS INVOLVED IN DETERMINING THE
                  APPROVAL OF THE INVESTMENT ADVISORY AGREEMENT.

Response 7.       The Funds respectfully submit that they have satisfied the
                  existing disclosure requirements regarding approval of
                  advisory contracts required under Form N-14. Form N-14 (Items
                  12(b) and 13(b)) requires the Funds to furnish in the SAI the
                  information called for under Item 18.13 of Form N-2.
                  Investment Company Act Release No. 26486 (June 23, 2004) (the
                  "Release") removes Item 18.13 of Form N-2 effective January
                  31, 2006 and adds new disclosure regarding approval of
                  advisory contracts to shareholder reports.

                  The Funds respectfully submit that they are not yet obligated
                  to provide this new disclosure in their shareholder reports.
                  The Release adds subsection (e) to Item 24.6 of Form N-2,
                  which applies only "[i]f the Registrant's board of directors
                  approved any investment advisory contract during the
                  Registrant's most recent fiscal half-year." Each Fund's most
                  recent fiscal half-year ended April 30, 2005, which preceded
                  the May 25-26, 2005 Board meeting at which the investment
                  advisory contract for each Fund was renewed. Since the Board
                  had not approved the investment advisory contracts pursuant to
                  the revised disclosure rules prior to April 30, 2005, the
                  Funds were not required to provide the new disclosure in their
                  most recent shareholder reports. Although the Release states
                  that "[p]rior to January 31, 2006, a fund may omit disclosure
                  in its SAI with respect to any board approval of an investment
                  advisory contract if it has previously provided the required
                  disclosure with respect to that board approval in a
                  shareholder report," since none of the Funds has yet been
                  obligated to provide the new disclosure in its shareholder
                  reports, the Funds have provided the disclosure currently
                  required by Item 18.13 of Form N-2.

                  The new disclosure requirements also apply to "all proxy
                  statements filed on or after October 31, 2004," and the N-14
                  serves as a proxy statement for the Acquiring Fund with
                  respect to the issuance of additional common shares in
                  connection with the Reorganizations. However, the Funds
                  respectfully submit that they are not obligated to provide
                  this new disclosure. The Release adds new

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                  disclosure to Item 22(c)(11) of Schedule 14A; Item 22(c),
                  though, applies only "[i]f action is to be taken with respect
                  to an investment advisory contract." Accordingly, since the
                  Acquiring Fund is not taking action with respect to an
                  investment advisory contract, the new disclosure is not
                  required.

COMMENT 8.        UNDER "FUND MANAGEMENT," PROVIDE THE DISCLOSURE REQUIRED BY
                  ITEM 21.2 OF FORM N-2 WITH RESPECT TO COMPENSATION.

Response 8.       The Funds respectfully submit that they have satisfied the
                  existing disclosure requirements regarding portfolio manager
                  compensation. Item 21.2 requires disclosure of "the structure
                  of, and the method used to determine, the compensation of each
                  Portfolio Manager." The Funds' investment adviser has created
                  a structure and method for compensating portfolio managers
                  which is fully described in the SAI. To the extent that the
                  Funds disclosed any additional information regarding the
                  structure and method for compensating its portfolio managers,
                  they would risk the possibility that the value of compensation
                  would be disclosed, a result that is specifically disclaimed
                  by Item 21.2 ("[t]he value of compensation is not required to
                  be disclosed under this Item").

ACCOUNTING COMMENTS

COMMENT 9.        IN THE CAPITALIZATION TABLE UNDER "PROPOSAL 1 -- COMPARISON
                  OF THE FUNDS -- CAPITALIZATION," EXPLAIN SUPPLEMENTALLY THE
                  REASON FOR THE DECLINE IN THE NET ASSET VALUE PER COMMON SHARE
                  OF THE ACQUIRING FUND FROM THE FOURTH TO THE FIFTH COLUMN.

Response 9.       The fourth column shows the net asset value per common
                  share of the Acquiring Fund as of January 31, 2005, while the
                  fifth column shows the net asset value per common share of the
                  Acquiring Fund assuming each of the Reorganizations was
                  approved and completed as of January 31, 2005. The pro forma
                  column thus reflects (as indicated in the second footnote) a
                  non-recurring cost associated with the Reorganizations of
                  approximately $587,000, which accounts for the decline from
                  $16.48 to $16.43 in the net asset value per common share of
                  the Acquiring Fund.

COMMENT 10.       WITH RESPECT TO THE PROPOSED REORGANIZATIONS, ADDRESS ANY
                  ISSUES RAISED BY THE STAFF OF THE SECURITIES AND EXCHANGE
                  COMMISSION IN NORTH AMERICAN SECURITY TRUST (PUBL. AVAIL.
                  AUG. 5, 1994) ("NORTH AMERICAN").

Response 10.      The Funds' analysis of North American has been prepared and
                  filed as a separate correspondence.

COMMENT 11.       EXPLAIN SUPPLEMENTALLY THE BASIS FOR THE CHOICE OF JANUARY 31,
                  2005 AS THE DATE FOR THE PRO FORMA FINANCIAL STATEMENTS
                  ATTACHED AS APPENDIX L TO THE SAI.

Response 11.      Rule 11-02(c) of Regulation S-X governs the periods to be
                  presented with respect to pro forma financial information.
                  Rule 11-02(c)(1) requires that a pro forma financial
                  information be prepared "as of the end of the most recent
                  period for which a consolidated balance sheet of the
                  registrant is required by Rule 3-01."

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                  Rule 3-01(g) refers registered management investment companies
                  to Rule 3-18 in lieu of Rule 3-01. Rule 3-18(c) states:

                           If the most current balance sheet or statement of
                           assets and liabilities in a filing is as of a date
                           245 days or more prior to the date the filing is
                           expected to become effective, the financial
                           statements shall be updated with a balance sheet or
                           statement of assets and liabilities as of an interim
                           date within 245 days.

                  We expected this filing to become effective on August 9, 2005,
                  which is 282 days from October 31, 2004, the last fiscal year
                  end of each Fund. Accordingly, pursuant to Rule 3-18(c), we
                  updated the pro forma financial information "as of an interim
                  date within 245 days." The date chosen, January 31, 2005, is
                  an interim d