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        787 Seventh Avenue

        New York, NY 10019-6099

        Tel: 212 728 8000

        Fax: 212 728 8111

        April 15, 2020

        VIA EDGAR

        Securities and Exchange Commission

        100 F Street, N.E.

        Washington, DC 20549

        Re: The Gabelli Utility Trust

        (Securities Act File No. 333-236449, Investment Company Act File No. 811-09243) Response to Staff Comments

        Ladies and Gentlemen:

        On behalf of The Gabelli Utility Trust (the "Fund"), please find responses to telephonic comments provided by David Orlic of the staff ("Staff") of the Securities and Exchange Commission ("SEC" or "Commission") on March 16, 2020, to the undersigned of our firm regarding the registration statement on Form N-2 ("Registration Statement") filed by the Fund on February 14, 2020.

        For the convenience of the Staff, the comments are set out below. We have discussed the Staff's comments with representatives of the Fund and the Fund's investment adviser. The Fund's responses to the Staff's comments are set out immediately under the comment. The Fund anticipates filing these changes in a pre-effective amendment (the "Amendment") to the Registration Statement, pending any additional comments from the Staff. Unless otherwise indicated, defined terms used herein have the meanings set forth in the Registration Statement and page numbers are those of the Registration Statement.

        General

        (1)Comment: To the extent applicable to the Registration Statement and not otherwise addressed by the Staff's comments to the Registration Statement below, please respond to the Staff's comments to the registration statement on Form N-2 filed by The Gabelli Global Utility & Income Trust ("GLU") on July 19, 2018, as reflected in the comment response letter filed by Skadden, Arps, Slate, Meagher & Flom LLP ("Skadden") on September 14, 2018 (https://www.sec.gov/Archives/edgar/data/1282957/000119312518274083/filename1.htm) (the "First GLU Comment Response Letter"). Please note that further changes reflected in a subsequent comment

        NEW YORK WASHINGTON HOUSTON PALO ALTO SAN FRANCISCO CHICAGO PARIS LONDON FRANKFURT BRUSSELS MILAN ROME

        Securities and Exchange Commission

        April 15, 2020

        response letter filed by Skadden on October 2, 2018

        (https://www.sec.gov/Archives/edgar/data/1282957/000119312518290753/filename1.htm) (the "Second GLU Comment Response Letter") may be relevant to the Fund's responses.

        Response: The Fund submits that Comments Nos. 2, 3, 4, 8, 9, 14, 18, 19, 20, 21 in the First GLU Comment Response Letter are not applicable to the Registration Statement. Also, Comments Nos. 6, 7 and 22 in the First GLU Comment Response Letter were separately provided to the Fund and are addressed in Comments Nos. 22, 23 and 29 below.

        The Fund has copied below the remaining comments from the First GLU Comment Response Letter, with certain revisions as needed in the context of the Registration Statement, and provided its responses:

        General

        GLU Comment 1: Please state in your response letter whether FINRA will or has reviewed the proposed underwriting terms and arrangements of the transactions described in the Registration Statement.

        Response: FINRA has not reviewed, and is not expected to review, the proposed underwriting terms and arrangements of the transactions described in the Registration Statement. The Fund relies on the exemption in FINRA Rule 5110(b)(7)(A), which does not require an issuer to file with FINRA the registration statement and underwriting agreement, among other documents, relating to an offering of the issuer's securities if the issuer has unsecured, non-convertible, investment-grade preferred shares outstanding.

        GLU Comment 5: Please revise the cover of the Prospectus and Prospectus Supplement to cross-reference the risk factors addressing leverage.

        Response: The requested change will be made in the Amendment.

        Prospectus Supplement for Subscription Rights to Acquire Common Shares

        GLU Comment 10: Please explain to us the role the Rights Agent plays in selling unexercised Rights.

        Response: The Rights Agent will sell Rights on behalf of Rights holders in the circumstances described in the Prospectus Supplement for the Rights offering. In this capacity, the Rights Agent is acting as agent for Rights holders and is not conducting a secondary offering of additional Rights to the public.

        GLU Comment 11: Please clarify the relevance of the methods of transfer of Rights included in the sixth paragraph under the heading "Method of Transferring Rights."

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        April 15, 2020

        Response: The Fund will caption the first four paragraphs of the referenced section as "Sales on the [•]" and the remaining paragraphs of the referenced section as "Other Transfers." The Fund notes that the subject matter of these disclosures is fairly typical and this method of distinguishing the various methods of transfer is consistent with other recent rights offerings. See, e.g., RMR Real Estate Income Fund, Definitive Prospectus filed August 18, 2017, at S-17-18; Tortoise MLP Fund, Inc., Definitive Prospectus filed June 19, 2018, at S-15-16.

        GLU Comment 12: Please confirm whether the fees paid to the Rights Agent and to the Administrative Agent, respectively, will be included in the estimated offering expenses.

        Response: The Fund confirms that such fees will be included in the estimated offering expenses in the Prospectus Supplement for any future rights offering.

        GLU Comment 13: The third paragraph under the heading "Payment for Shares" contains the following disclosure:

        If a holder of Rights who acquires Common Shares pursuant to the Rights offering does not make payment of all amounts due, the Fund reserves the right to take any or all of the following actions:

        (i) find other purchasers for such subscribed-for and unpaid- for Common Shares; (ii) apply any payment actually received by it toward the purchase of the greatest whole number of Common Shares which could be acquired by such holder upon exercise of the Rights or any over-subscription privilege; (iii) sell all or a portion of the Common Shares purchased by the holder, in the open market, and apply the proceeds to the amounts owed; and

        (iv)exercise any and all other rights or remedies to which it may be entitled, including, without limitation, the right to set off against payments actually received by it with respect to such subscribed Common Shares and to enforce the relevant guarantee of payment.

        Comment 13(a): Please explain why prongs (i), (iii) and (iv) are necessary.

        Response: As indicated in Comment and Response No. 27 below, the Fund will delete prong (iii) in the Amendment. The Fund has informed us that prongs (i) and (iv) are necessary because Common Shares may be issued before a Rights holder's payment clears. For example, a Rights holder may provide a check on the Expiration Date, and that check may not have cleared at the time the Common Shares are issued. The disclosure under prongs (i) and

        (iv)of the referenced paragraph addresses the Fund's remedies in the situation where all or a portion of a Rights holder's payment does not clear, and where the Fund would not be able to simply reduce the amount of Common Shares to be issued to the Rights holder to cure the insufficient payment. Please see

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        April 15, 2020

        Comment and Response No. 27 below for certain revisions to prongs (i) and (iv) that will be made in the Amendment.

        The Fund believes that these remedies are common in closed-end fund rights offerings and does not believe they raise any particularly novel issues. See, e.g., RMR Real Estate Income Fund, Definitive Prospectus filed August 18, 2017, at S-24-25; Tortoise MLP Fund, Inc., Definitive Prospectus filed June 19, 2018, at S-20.

        Comment 13(b): Please explain the Fund's rationale for possibly selling subscribed-for and unpaid-for Common Shares to investors other than Rights holders.

        Response: Please see Comment and Response No. 27 below describing how the Fund will revise this disclosure in the Amendment.

        Comment 13(c): Please provide us with a supplementary analysis of how prong (iii) is consistent with the Securities Act.

        Response: Please see Comment and Response No. 27 below indicating that the Fund will delete prong (iii) in the Amendment.

        Comment 13(d): Please explain what prong (iv) is intended to mean.

        Response: The Subscription Certificate is a contractual obligation pursuant to which an exercising Rights holder agrees to purchase Common Shares at the Subscription Price. Prong (iv) means that the Fund may enforce that contract by, for example, pursuing its rights (including through litigation) against the defaulting exercising Rights holder for any unpaid amounts or other damages. The Fund believes that the language in prong (iv) is consistent with that used in other closed-end fund rights offerings and that it is not necessary to modify it. See, e.g., RMR Real Estate Income Fund, Definitive Prospectus filed August 18, 2017, at S-24-25; Tortoise MLP Fund, Inc., Definitive Prospectus filed June 19, 2018, at S-20.

        Nevertheless, to add additional clarity to the last clause, the Fund will revise prong (iv) as described in Comment and Response No. 27.

        GLU Comment 15: The disclosure under the heading "Foreign Restrictions" is as

        follows: "Subscription Certificates will only be mailed to Record Date Shareholders whose addresses are within the United States (other than an APO or FPO address). Please explain the basis on which the Fund believes that it may exclude foreign shareholders from participation in the Rights offering.

        Response: Foreign shareholders are not excluded from participation in an offering of Rights. Any foreign shareholder may exercise or sell (in a transferable

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        Rights offering) any Rights to which they are entitled. The Fund is simply not undertaking in the Registration Statement to register the offering of Rights in any non- U.S. jurisdiction. In the event a shareholder is unable to exercise their Rights due to local laws, the Fund has established a mechanism that seeks to allow shareholders located in foreign jurisdictions to realize the value of the Rights. These points are disclosed to shareholders under the heading "Foreign Restrictions," which further provides: "Because the offering of the Rights will not be registered in any jurisdiction other than the United States, the Rights Agent will attempt to sell all of the Rights issued to shareholders of record outside of these jurisdictions and remit the net proceeds, if any, to such shareholders of record. If the Rights can be sold, sales of these Rights will be deemed to have been effected at the weighted average price received by the Rights Agent on the day the Rights are sold, less any applicable brokerage commissions, taxes and other expenses."

        Prospectus Supplement for Subscription Rights to Acquire Preferred Shares

        GLU Comment 16: In the first paragraph under the heading "Description of the Series [ ] Preferred Shares," please delete the second sentence or revise it to reflect that the disclosure in this section is intended to be a summary of the material provisions of the Statement of Preferences.

        Response: The Fund will revise the referenced sentence as follows: "This is intended to be a summary of the material provisions of the Fund's Statement of Preferences for the Series [ ] Preferred Shares (the "Statement"). Since this disclosure is only a summary, you should refer to the Statement for a complete description of the obligations of the Fund and your rights."

        GLU Comment 17: Please revise the first sentence under "Voting Rights" to remove the suggestion that there are voting rights omitted from the disclosure.

        Response: The Fund respectfully submits that the referenced sentence is expected to appear in the Statement of Preferences applicable to a series of preferred shares being offered under the Registration Statement. The Fund will therefore preface this sentence with, "The Statement provides that, except as . . ."

        GLU Comment 23: Please provide the Staff with a form of the legal opinion required by Item 25(2)(l) of Form N-2 prior to requesting effectiveness.

        Response: The Fund has attached a draft of the legal opinion as Appendix A to this letter.

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        Securities and Exchange Commission

        April 15, 2020

        Prospectus

        Prospectus Summary

        (2)Comment: Please confirm that the Fund is distributing capital gains only once a year in accordance with Section 19(b) of the Investment Company Act of 1940, as amended (the "1940 Act").

        Response: The Fund has received an order from the Commission exempting the Fund from Section 19(b) and Rule 19b-1 under the 1940 Act that permits the Fund to make periodic distributions of long-term capital gains, as often as monthly, on the Fund's common shares and as often as distributions are specified in the terms of any preferred shares outstanding. See Investment Company Act Release Nos. 25070 (July 20, 2001) (notice) and 25110 (Aug. 15, 2001) (order).

        (3)Comment: In the subsection entitled "Dividends and Distributions—Common Share Distributions" on page 3, please add disclosure that return of capital will reduce the Fund's net asset value ("NAV"), which could negatively affect the price a shareholder receives upon sale of its shares.

        Response: The Fund will add the following disclosure to the aforementioned subsection:

        The amount treated as a tax free return of capital will reduce the NAV of the Fund's shares and a shareholder's adjusted tax basis in the common shares or preferred shares, as applicable, which may negatively affect the price a shareholder receives upon the sale of its shares and may increase the shareholder's potential taxable gain or may reduce the potential taxable loss on the sale of the shares.

        (4)Comment: In the subsection entitled "Use of Proceeds" on page 4, please disclose the types of changes in market conditions that could extend the use of proceeds period to six months.

        Response: The Fund will add the following disclosure to the "Use of Proceeds" sections in the Prospectus Summary, Prospectus, and Prospectus Supplements: "This could occur because the Investment Adviser follows a value-oriented investment strategy; therefore, market conditions could result in the Investment Adviser delaying the investment of proceeds if it believes the margin of risk in making additional investments is not favorable in light of its value-oriented investment strategy. See 'Investment Objectives and Policies—Investment Methodology of the Fund.'"

        (5)Comment: In the subsection entitled "Risk Factors and Special Considerations," please revise the risk factor for "Industry Concentration Risk" on page 4 to state that the Fund is concentrated (i.e., invests 25% or more of its total assets) in the Utility Industry, rather than stating that the Fund invests a "significant portion of its assets" in the Utility Industry.

        Response: The Fund will revise the first sentence of the risk factor for "Industry Concentration Risk" as follows:

        The Fund invests a significant portion is concentrated (i.e., invests 25% or more of its total assets) in foreign and domestic companies in

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