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CORRESP
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  1900 K Street, NW

Washington, DC 20006-1110

+1 202 261 3300 Main

+1 202 261 3333 Fax

www.dechert.com

  ADAM T. TEUFEL

adam.teufel@dechert.com

+1 202 261 3464 Direct

+1 202 261 3164 Fax

April 2, 2025

VIA EDGAR CORRESPONDENCE

Deborah O’Neal

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, NE

Washington, D.C. 20549-4644

 Re: ALPS ETF Trust (the “Registrant” or “Trust”) (SEC File Nos. 333-148826 and 811-22175)

Dear Ms. O’Neal:

We are writing in response to
comments you provided telephonically to Kyle Whiteman and me on March 13, 2025 with respect to the Registrant’s Post-Effective Amendment
No. 337, filed on January 24, 2025, relating to ALPS Electrification Infrastructure ETF (the “Fund”), a new series of the
Registrant. On behalf of the Registrant, we have reproduced your comments below and provided the Registrant’s responses immediately
thereafter. Capitalized terms have the meanings attributed to such terms in Post-Effective Amendment No. 337.

1. Comment: Please provide the
Staff with the Fund’s completed fee table and expense example five business days prior to effectiveness of the Fund’s registration
statement.

 Response: The completed Annual Fund Operating Expenses table and Expense Example for the Fund are attached as Appendix
I.

2. Comment: The Staff notes that the Underlying
Index, which is comprised of the common stock of companies assigned to one of thirteen GICS sub-industries, includes the following sub-industries,
among others: (xi) coal & consumable fuels; and (xiii) oil & gas storage and transportation. Please explain supplementally why
these two sub-industries are included in the Underlying Index, which is designed to measure the performance of companies that are positioned
to benefit from “electrification”.

 Response: Subsequent to Post-Effective Amendment
No. 337, the Underlying Index methodology has been revised such that it will be comprised of the common stock of companies assigned to
one of seventeen ICE Uniform Entity Sector Classification (“ICE”) sub-industries. The disclosure referenced by the Staff’s
comment will be replaced with the following paragraph and corresponding changes will be made throughout the Prospectus and Statement of
Additional Information:

“The Underlying Index is comprised
of the common stock of companies assigned to one of seventeen ICE sub-industries. The seventeen ICE sub-industries are: (i) electricity
generation - renewable; (ii) electricity generation - non-renewable; (iii) multi-utilities; (iv) integrated electricity; (v) electricity
distribution & transmission; (vi) electronic components; (vii) electronic equipment & instruments; (viii) electrical components
& power equipment; (ix) battery technology; (x) construction engineering & services; (xi) construction; (xii) copper; (xiii) diversified
base metals; (xiv) thermal coal; (xv) uranium; (xvi) oil & gas pipelines & storage; and (xvii) oil & gas freight.”

The Underlying Index was constructed to gain exposure to the entire supply
chain that may benefit from investment in electrification. Thermal coal and uranium are upstream sub-industries, both of which benefit
from increased demand for electricity generation. In the case of uranium, new small-scale reactor technology may also spur increased demand
for the fuel. Oil & gas pipelines & storage and oil & gas freight are midstream sub-industries that include oil & gas
pipeline and storage operators. These sub-industries may see growing demand as electrification drives more distributed generation, needing
more connecting infrastructure.

3. Comment: Please consider
whether “Canadian Investment Risk,” which is disclosed as a principal risk of the Fund, should be updated in light of recently
announced tariffs relating to trade between the United States and Canada.

 Response: The Registrant will revise the disclosure as follows:

“Canadian Investment
Risk. The Fund may be subject to risks relating to its investment in Canadian securities. Investments in securities of Canadian issuers
involve risks and special considerations not typically associated with investments in the U.S. securities markets. The Canadian economy
is very dependent on the demand for, and supply and price of, natural resources. There is a risk that any changes in natural resources
sectors could have an adverse impact on the Canadian economy. Additionally, the Canadian economy is heavily dependent on relationships
with certain key trading partners including the United States, which recently imposed tariffs on Canadian imports, countries
in the European Union and China. Because the United States is Canada’s largest trading partner and foreign investor, the Canadian
economy is dependent on and may be significantly affected by the U.S. economy. Reduction in spending on Canadian products and services,
the imposition of additional tariffs by the United States, or changes in the U.S. economy may adversely impact the Canadian economy.
The expanding economic and financial integration of the United States, Canada, and Mexico through the North American Free Trade Agreement
(“NAFTA”), or its successor, the United States-Mexico-Canada Agreement (“USMCA”), has made, and will likely continue
to make, the Canadian economy and securities market more sensitive to North American trade patterns. In addition, certain sectors of Canada’s
economy may be subject to foreign ownership limitations. This may negatively impact the Fund’s ability to invest in Canadian issuers
and to track the Underlying Index. Because the Fund will invest in securities denominated in foreign currencies and the
income received by the Fund will generally be in foreign currency, changes in currency exchange rates may negatively impact the Fund’s
return. Each of these factors can make investments in the Fund more volatile and potentially less liquid than other types of investments.”

* * *

Should you have any questions, please
feel free to contact me at (202) 261-3464.

    Sincerely,

    /s/ Adam T. Teufel

    Adam T. Teufel

 cc: Brendan Hamill, ALPS ETF Trust

Appendix I

FEES AND EXPENSES OF THE FUND

This table describes the fees and expenses that you may pay if you buy,
hold and sell shares of the Fund (“Shares”). You may pay other fees, such as brokerage commissions and other fees to financial
intermediaries, which are not reflected in the table and example below.

Annual Fund Operating Expenses (expenses that you pay each year as a
percentage of the value of your investment):

    Management Fees
    0.50%

    Other Expenses1
    0.00%

    Total Annual Fund Operating Expenses
    0.50%

 1 Other Expenses are estimated for the current fiscal year.

Example

The following example is intended to help you compare the cost of investing
in the Fund with the costs of investing in other funds. The example assumes that you invest $10,000 in the Fund for the time periods indicated
and then hold or redeem all of your Shares at the end of those periods. The example also assumes that your investment has a 5% return
each year and that the Fund’s operating expenses remain the same each year.

    One

    Year

    Three

    Years

    Although your actual costs may be higher or lower, based on these assumptions your costs would be:
    $51
    $160