SecProbe.io

CORRESP
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January 27, 2020

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attn: Anu Dubey

 Re: Aberdeen Standard Global Infrastructure Public Private
Income Fund

    File Nos. 333-234722 and 811-23490

Dear Ms. Dubey:

On behalf of Aberdeen Standard Global Infrastructure
Public Private Income Fund (the “Fund” or the “Registrant”), we are writing to respond to the comments
that the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) provided in writing
to Katherine Corey on December 11, 2019, relating to the Fund’s initial registration statement on Form N-2 (the
 “Registration Statement”) with respect to the proposed offering of shares by the Fund (the “Shares”), which
was filed on November 15, 2019.

For your convenience, the Staff’s
written comments have been copied below. The Registrant’s responses are set out immediately under each of the Staff’s
comments. Capitalized terms used in this letter and not otherwise defined herein shall have the meanings specified in the Registration
Statement.

PROSPECUS

Cover page

 1. The second sentence under “Investment Objective”
states that the Fund’s investment objective is to seek to provide a high level of total return with an emphasis on current
distributions. Because the Fund’s name includes the word “income” and as “distributions” can include
items that are not income (e.g., returns of capital), please revise the investment objective to emphasize the achievement
of current income. See Frequently Asked Questions about Rule 35d-1, Question 9.

Response: The Registrant will revise its investment
objective to read as follows:

“to seek to provide a high level of total return
with an emphasis on current income”.

 2. The second sentence under “Investment Strategies”
states that, under normal conditions, at least 80% of the Fund’s net assets (plus the amount of any borrowings for investment
purposes) will be invested in U.S. and non-U.S. infrastructure-related issuers. Please revise this 80% investment policy to also
reflect the type of investments suggested by the words “Public” and “Private” in the Fund’s name.
See Rule 35d-1(a)(2)(i) under the Investment Company Act of 1940 (“1940 Act”). Also, please explain
to us how it is appropriate to include the word “Private” in the Fund’s name at launch when, as disclosed on
page 7, the Fund expects to fully invest the net proceeds of the offering in an initial portfolio of primarily publicly listed
investments within one month after the closing but will only reinvest some portion of this initial portfolio into Private Infrastructure
Opportunities over a period of 24 months after the closing of the offering.

Response: The Fund respectfully submits that
the terms “public” and “private” in its name does not refer to a specific type of investment or investments
(e.g., stock, bond, equity, debt, small-cap, etc.), but rather to the method through which various investments are offered.
Accordingly, the Fund does not believe that the terms “public” and “private” in its name implicate Rule 35d-1
under the 1940 Act.

The Fund also believes that it is appropriate to
include the term “private” in its name at Fund launch, as the Fund’s investment strategy will seek to invest
in private investments under normal circumstances. The Fund will, however, add disclosure to its investment strategy noting that
appropriate investments in Private Infrastructure Opportunities may not be immediately available after Fund launch. Please see
the response to comment 3 below for more detail.

 3. The second bullet point in the third to last paragraph
under “Investment Strategies” describes “Private/Direct Infrastructure Investments”. The last sentence
of this bullet point states that the Fund currently intends to invest up to 25% of its total assets in Private Infrastructure
Opportunities. Inasmuch as the Fund’s name includes the words “Public” and “Private”, please disclose
the minimum amount of the Fund’s assets that will be invested, under normal circumstances, in each of public infrastructure
investments and Private Infrastructure Opportunities. We may have more comments after reviewing your response.

Response: The Registrant intends, under normal
circumstances, to invest at least 60% of its assets, and typically 75%, in public infrastructure investments and at least 10%-25%
of its assets in private/direct infrastructure investments. If, due to market conditions, private/direct infrastructure investments
are scarce, or if necessary for liquidity purposes, the Fund may depart from its policy to invest a minimum of 10% of its assets
invested in private/direct infrastructure investments. To clarify, the Registrant will modify the disclosure in bullet points 1
and 2 under “Investment Strategies” to read as follows:

 · Public Infrastructure Investments. The Fund will, under normal
circumstances, invest at least 60%, and generally expects to invest approximately 75%, of its total assets in listed equity securities
of infrastructure-related issuers. Equity securities in which the Fund intends to invest include primarily common stocks,
preferred stocks and depositary receipts. The Fund may invest in securities of issuers of any market
capitalization.

      2

 · Private/Direct Infrastructure Investments. The Fund will make direct investments in infrastructure
assets through private transactions, which may include investments alongside other funds or accounts advised by the Adviser or
its affiliates in certain infrastructure assets (“Co-Investment Opportunities”). A “private transaction”
means an investment in infrastructure assets directly or through the purchase of securities issued by a sponsor vehicle, including
equity securities, warrants, bank or other indebtedness, conversion privileges and other rights, in a transaction that is exempt
from registration under the Securities Act of 1933, as amended (the “Securities Act”). The Fund may also be offered
an opportunity to invest in certain infrastructure assets in a private transaction on a stand-alone basis alongside other investors
(“Stand-Alone Opportunities”, and together with “Co-Investment Opportunities, “Private Infrastructure Opportunities”).
Unless and until the Fund receives an exemptive order from the Securities and Exchange Commission to co-invest in negotiated Co-Investment
Opportunities (which cannot be assured), the Fund will only invest in Co-Investment Opportunities where the transaction is permitted
under existing regulatory guidance, such as transactions in which price is the only negotiated term. Under normal circumstances,
the Fund will invest at least 10%, and currently intends to generally invest closer to 25%, of its total assets, measured at the
time of investment, in Private Infrastructure Opportunities. As a result of the relatively limited availability of Private Infrastructure
Opportunities, the Fund may have a lower percentage of its total assets invested in Private Infrastructure Opportunities during
the initial 24 months following inception. In addition, as the Fund disposes of individual Private Infrastructure Opportunities,
the Fund will look to redeploy its capital into new Private Infrastructure Opportunities, which may be scarce. As the Fund approaches
the end of its 15-year term (see “Term” below), the Fund may refrain from making new Private Infrastructure Opportunities,
if necessary, for liquidity purposes, and increase its allocation to public infrastructure investments. During such periods, the
Fund may have a lower percentage of its total assets invested in Private Infrastructure Opportunities.

 4. The first sentence of the third paragraph under “Term”
states that the amount paid to participating common shareholders upon completion of an Eligible Tender Offer will be based upon
the Fund’s net asset value at such time. The third sentence of this paragraph states that, given the nature of certain of
the Fund’s investments, the amount actually paid upon completion of an Eligible Tender Offer may be less than the Fund’s
net asset value per share on the expiration date of the Eligible Tender Offer. As this disclosure indicates that the Fund contemplates
that it may not be able to pay an amount equal to the Fund’s net asset value on the expiration date of the Eligible Tender
Offer, please explain to us how the Fund will comply with the requirement to disclose the “type and amount of consideration
offered to security holders [emphasis added]”. See Item 1004(a)(1)(ii) of Regulation M-A under the Securities
Exchange Act of 1934 (“1934 Act”) and Item 4 of Schedule TO under the 1934 Act. Please also explain to us how the
Fund will pay the consideration for the tendered shares “promptly”, as required by Rule 13e-4(f)(5) under
the 1934 Act (which requires the issuer making the tender offer to pay the consideration offered promptly after the termination
of the tender offer).

Response: The
Fund acknowledges the aforementioned requirements, and notes that on page 5, the disclosure provides that “[a]n Eligible
Tender Offer would be made, and common shareholders would be notified thereof, in accordance with the Fund’s Declaration
of Trust, the 1940 Act, the Securities  Exchange Act of 1934, as amended (the “Exchange Act”), and the applicable
tender offer rules thereunder (including Rule 13e-4 and Regulation 14E under the Exchange Act).” The Fund will
clarify the disclosure referenced in the Staff’s comment to state that tendering shareholders will receive an amount equal
to net asset value for their shares in an Eligible Tender Offer, though given the nature of certain of the Fund’s investments,
the Fund’s net asset value may be impacted by the sale of such investments.

      3

 5. The first sentence under “Leverage” states
that the issuance of debt securities, among other things, represents the leveraging of the Fund’s common shares. Please
confirm that the fee table will reflect the issuance costs of debt securities. Alternatively, please disclose that the Fund has
no current intent to issue debt securities (i.e., that the Fund will not issue debt securities within one year of the effective
date of its registration statement).

Response: The Registrant will add the following
language to this section: “The Fund has no current intent to issue debt securities.”

 6. The second sentence of the last paragraph under “Important
Note” indicates that a shareholder can inform the fund or the financial intermediary that he or she wishes to continue receiving
paper copies of shareholder reports “by following the instructions included with this disclosure”. Please clarify
to which instructions this phrase refers.

Response: The Registrant will delete the following
language: “by following the instructions included with this disclosure”.

Prospectus Summary — Investment Strategies and Policies
(pages 2 - 4)

 7. On page 3, the last two sentences in the bulleted
item “Private/Direct Infrastructure Investments” indicate that the Fund may invest up to 25% of its total assets,
measured at the time of investment, in Private Infrastructure Opportunities and certain Private Infrastructure Opportunities may
be issued by sponsor vehicles structured as funds that would be investment companies but for the provisions of Sections 3(c)(1) and
3(c)(7) of the 1940 Act. Please tell us what types of funds these sponsor vehicles include (e.g., private equity funds,
hedge funds). Please explain to us why it is appropriate for the Fund to be able to invest up to 25% of its total assets in Private
Infrastructure Opportunities that are not typically available to retail investors. See Concept Release on Harmonization of
Securities Offering Exemptions, Investment Company Act Release No. 33512 (June 18, 2019) at pages 186-187.
Please also tell us how many funds that would be investment companies but for Sections 3(c)(1) or 3(c)(7) of the 1940
Act that the Fund would typically invest in and whether there is a minimum number of such funds in which the Fund would invest.
We may have more comments after reviewing your response.

Response: As disclosed in the Prospectus,
certain Private Infrastructure Opportunities may be issued by sponsor vehicles structured as funds that would be investment companies
but for the provisions of Section 3(c)(1) and 3(c)(7) of the 1940 Act (“unregistered funds”). Most,
if not all, of such unregistered funds in which the Fund will invest will hold a single investment. These single private infrastructure
investments are generally made available to the Fund, and other investors, through an unregistered fund, rather than directly,
for administrative and/or tax purposes. Such funds do not have the same characteristics as funds commonly known as “hedge
funds” or “private equity funds” (for example, they hold a single asset and, therefore, are not managed like
a portfolio of investments and do not employ leverage or alternative or risky investment strategies, and generally do not charge
a management or performance fee/carried interest).

      4

The Fund does not currently intend to invest in unregistered
funds that are “hedge funds” or “private equity funds” as part of its principal investment strategy and
will revise the above-referenced disclosure to state that it will limit its investments in unregistered funds that are commonly
known as “hedge funds” or “private equity funds” to no more than 15% of its total assets.

 8. On page 3, the third paragraph states that the Fund
may use derivative instruments. Please disclose that the Fund will value derivatives based on market value or fair value for purposes
of the Fund’s 80% investment policy. See Rule 35d-1(a)(2)(i) under the 1940 Act.

Response: The Registrant will add the following
sentence to the above-referenced paragraph: “The Fund will value derivatives based on market value or fair value for purposes
of its 80% investment policy.”

Prospectus Summary — Term (pages 4 - 7)

 9. The second sentence on page 5 states that it is
anticipated that shareholders who properly tender common shares in the Eligible Tender Offer will receive a purchase price equal
to the net asset value per share as of a date following the expiration date of the Eligible Tender Offer and prior to the payment
date. Please disclose with greater specificity the date as of which the Fund’s net assets would be valued for purposes of
determining the purchase price shareholders will receive in an Eligible Tender Offer.

Response: The date on which the Fund’s
net assets would be valued for purposes of determining the purchase price shareholders will receive in an Eligible Tender Offer
is dependent on the date of the Eligible Tender Offer, which may occur at some point 15 to 16.5 years from the date of the launch
of the Fund, which date cannot be predicted with any further specificity at this time. The Registrant confirms, however, that the
valuation date will comply with tender offer rules.

 10. The last full sentence on page 6 states that the
Fund may transfer unsold investments to a liquidating trust. Please disclose whether such liquidating trust would continue to
be a registered investment company under the 1940 Act. We may have more comments after reviewing your response.

Response: The liquidating trust will be a
separate entity from the Fund and, in reliance on Section 7 of the 1940 Act, will not be a registered investment company under
the 1940 Act. The Fund will transfer any illiquid portfolio investments that remain unsold on the Termination Date to a liquidating
trust and distribute interests in such liquidating trust to common shareholders as part of its final distribution. The sole purpose
of the liquidating trust would be to hold illiquid investments of the Fund that were unable to be sold and to dispose of such investments.
As such investments are sold over time by the liquidating trust, the liquidating trust would dist