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CORRESP
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    Chicago

    New York

    Washington, DC

    London

    San Francisco

    Los Angeles

    Singapore

    Dallas

    Miami

    October 16, 2024
    vedderprice.com

    Deborah Bielicke Eades

    Shareholder

    +1 312 609 7661

    deades@vedderprice.com

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street NE

Washington, DC 20549

 Attn: Ms. Eileen Smiley

 Re: Tortoise Capital Series Trust (the “Registrant”)

Registration Statement on Form N-14

File No. 333-281752

To the Commission:

On behalf of the Registrant, this letter is in
response to the comments provided telephonically by the staff of the U.S. Securities and Exchange Commission (the “Commission”)
to Vedder Price P.C. on September 5, 2023 and September 23, 2024 with respect to the Registrant’s Registration Statement on
Form N-14 filed on August 23, 2024 (the “Registration Statement”) relating to the issuance of shares of beneficial
interest of Tortoise Power and Energy Infrastructure Fund (the “Acquiring Fund”), a series of the Registrant, in connection
with the proposed mergers of Tortoise Pipeline & Energy Fund, Inc. (“TTP” or a “Target Fund”), Tortoise Energy
Independence Fund, Inc. (“NDP” or a “Target Fund”) and Tortoise Power and Energy Infrastructure Fund, Inc. (“TPZ”
or a “Target Fund”) with and into a wholly-owned subsidiary of the Acquiring Fund. The Acquiring Fund and each Target Fund
are each referred to herein as a “Fund” and collectively as the “Funds.” Any capitalized terms used but not defined
herein have the same meanings as given to them in the Registration Statement. Any page references refer to the initial Registration Statement.
Set forth below are the staff’s comments and the Registrant’s responses. The Registrant is filing Pre-Effective Amendment
No. 1 to the Registration Statement concurrently herewith to address the comments of the staff, to complete all missing information
and remove all brackets in the Joint Proxy Statement/Prospectus and Statement of Additional Information, to correct and complete all cross
references in the document, and to file exhibits in Part C of the Registration Statement.

Disclosure Comments

 1. Comment: Please revise the disclosure relative to the Registrant and the Acquiring Fund
to reflect changes made to the Registrant’s Registration Statement on Form N-1A (File No. 333-281744) in response to staff
comments on that filing.

Response:
The Registrant confirms that Pre-Effective Amendment No. 1 to the Registration Statement includes applicable conforming changes.

222 North LaSalle Street | Chicago, Illinois 60601
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Vedder Price P.C. is affiliated with
Vedder Price LLP, which operates in England and Wales, Vedder Price (CA), LLP, which operates in California, Vedder Price Pte. Ltd., which
operates in Singapore, and Vedder Price (FL) LLP, which operates in Florida.

October 16, 2024

Page 2

 2. Comment: Please confirm that the forms of proxy cards will be filed as an exhibit to Pre-Effective
Amendment No. 1.

Response:
The Registrant confirms that the forms of proxy cards will be filed as Exhibit 18 to Pre-Effective Amendment No. 1 to the Registration
Statement.

 3. Comment: In the Q&A, the response to the question “Why am I receiving the enclosed
Joint Proxy Statement/Prospectus?” refers to the Merger of each Target Fund with and into a wholly-owned subsidiary of the Acquiring
Fund, but later the Joint Proxy Statement/Prospectus refers to a second-step merger in which the wholly-owned subsidiary merges with and
into the Acquiring Fund. Please revise the disclosure in the Q&A to explain the chronology of the two-step merger process or add a
cross-reference to the more detailed discussion in the Joint Proxy Statement/Prospectus.

Response:
The Registrant has revised the disclosure in response to the staff’s comment.

 4. Comment: Please revise the disclosure in the Joint Proxy Statement/Prospectus to clarify
whether the Mergers were approved unanimously by the Target Fund Boards or by a majority of the members of the Target Fund Boards.

Response:
The Registrant has revised the disclosure throughout to state that the Mergers were unanimously approved by the Boards on August 5, 2024.

 5. Comment: In the Q&A, the response to the question “Why does each Target Fund Board
recommend the Merger of its Target Fund?” indicates that stockholders of each Target Fund may benefit from the Merger through, among
other things, “[t]he potential for a high level of current income resulting from lower expenses while reducing the volatility associated
with the use of leverage from preferred stock and borrowings.” However, elsewhere in the Joint Proxy Statement/Prospectus, the disclosure
indicates that the Acquiring Fund may utilize leverage to the extent permitted by the 1940 Act. Please revise the disclosure in the Q&A
and elsewhere to more clearly describe the differences in the use of preferred stock, notes and borrowings (‘structural leverage”)
between the Acquiring Fund and the Target Funds in the Q&A and in the body of the Joint Proxy Statement/Prospectus.

Response:
The Registrant has revised the disclosure in response to the staff’s comment.

 6. Comment: In the Q&A, the response to the question “Why does each Target Fund Board
recommend the Merger of its Target Fund?” states that “[e]ach Target Fund Board considered that the Merger of its Target Fund
will allow stockholders of the Target Fund to continue their investment in an open-end ETF.” Please revise the disclosure as this
statement suggests the Target Funds are ETFs.

Response:
The Registrant has revised the disclosure to state that the Merger will allow stockholders to continue their investment in a similar strategy but through an ETF.

October 16, 2024

Page 3

 7. Comment: In the Q&A, the response to the question “Why does each Target Fund Board
recommend the Merger of its Target Fund” states that “[t]he Target Fund Board also noted that the Acquiring Fund will have
substantially the same investment objective and investment policies and strategies as TPZ, except that the Acquiring Fund cannot engage
in structural leverage through borrowings and preferred stock.” Please revise the disclosure to address how the Boards of the other
Target Funds considered differences between the investment objectives and policies of those Target Funds and those of the Acquiring Fund
or add a cross-reference to the discussion of this matter elsewhere in the Joint Proxy Statement/Prospectus.

Response:
The Registrant has revised the disclosure in response to the staff’s comment.

 8. Comment: In the Q&A, the response to the question “Will stockholders of the Target
Funds have to pay any fees or expenses in connection with the Mergers?” indicates the dollar amounts of Merger costs, expressed
both in the aggregate and on a per-share basis, expected to be borne by the Target Funds. Please revise the disclosure here and elsewhere
in the Joint Proxy Statement/Prospectus (e.g., under “Expenses” on page 23) to indicate how the expected costs of the
Mergers will be allocated among the Target Funds.

Response:
The Registrant has revised the disclosure in response to the staff’s comment.

 9. Comment: In the Q&A, please revise the response to the question “How will the
Mergers impact ongoing fees and expenses?” to include a cross-reference to the fee table in the Joint Proxy Statement/Prospectus.

Response:
The Registrant has revised the disclosure in response to the staff’s comment.

 10. Comment: In the Q&A, please revise the response to the question “How do the Funds’
objectives, strategies and risks compare?” to more clearly explain the differences between the investment objectives, policies and
risks of each Target Fund and those of the Acquiring Fund. Consider adding charts with a narrative description of key differences or add
one or more cross-references to relevant disclosure in the Joint Proxy Statement/Prospectus. Add a cross-reference to the Principal Risks
Comparison in the Joint Proxy Statement/Prospectus with a page reference.

Response:
The Registrant has revised the summary disclosure in the Q&A in response to the staff’s comment, and has added cross
references to the more detailed discussion in the Joint Proxy Statement/Prospectus. Registrant has added additional detail to the
chart presentation in the Joint Proxy Statement/Prospectus but does not believe that the level of detail contained in such chart is
suitable for a Q&A format.

 11. Comment: In the Q&A, the response to the question “Will the portfolios of the
Target Funds be repositioned prior to the Mergers?” provides information on expected portfolio repositioning intended to de-lever
the Target Funds and align their portfolios with the investment policies and restrictions of the Acquiring Fund. In disclosure comparing
the investment policies and restrictions of the Target Funds to those of the Acquiring Fund, please highlight any differences that require
pre-Merger portfolio repositioning.

Response:
The Registrant has more clearly described the differences between the policies of the Funds in response to the staff’s comment.

October 16, 2024

Page 4

 12. Comment: In the Q&A, please revise the response to the question “How will the
Mergers impact distributions to stockholders of the Target Funds?” to indicate how the Acquiring Fund will make distributions to
shareholders.

Response:
The Registrant has revised the disclosure in response to the staff’s comment.

 13. Comment: In the Notice of Joint Special Meeting of Stockholders, please revise the statement
of the proposal on which Target Fund stockholders will be asked to vote to indicate Target Fund stockholders will be asked to authorize
the merger of “each” Target Fund with and into a wholly-owned subsidiary of the Acquiring Fund.

Response:
The Registrant notes that the Merger of each Target Fund is an independent transaction, and that Target Fund stockholders will be asked
to vote only on the authorization of the Merger of their Target Fund. Accordingly, the Registrant respectfully declines to revise the
disclosure in response to this comment.

 14. Comment: TTP has outstanding shares of preferred stock. Please explain supplementally whether
separate approval by holders of such preferred stock is required pursuant to Section 18(a)(2)(D) of the 1940 Act. Also, please confirm
TTP preferred stockholders have a right to vote on that Target Fund’s Merger proposal given the December 13, 2024 mandatory
redemption date of TTP’s shares of preferred stock.

Response:
Registrant confirms that preferred stockholders of TTP are entitled to vote on the Merger if such shares were outstanding on the record
date. Under the charter of Registrant, common and preferred stockholders vote together as a single class. As an open-end fund operating
as an ETF, the Acquiring Fund may not issue preferred shares. Accordingly, all preferred shares will be redeemed on their mandatory redemption
date or otherwise prior to the closing of the Merger. Because preferred stockholders are not participating in the Merger, Registrant does
not believe that preferred stockholders are entitled to vote as a separate class pursuant to Section 18 of the 1940 Act.

 15. Comment: The Notice of Joint Special Meeting of Stockholders, and disclosure elsewhere,
states that “[c]ommon stockholders and preferred stockholders, if any, are entitled to vote on the [Merger proposal].” Please
revise the disclosure to clarify that only TTP has outstanding shares of preferred stock.

Response:
The Registrant has revised the disclosure in response to the staff’s comment.

 16. Comment: Page 3 of the Joint Proxy Statement/Prospectus indicates that “[w]hile
the closing of one Merger is not contingent on the closing of any other Merger, the Merger of TPZ with and into the Merger Sub must be
consummated prior to the consummation of any other Merger.” Please explain supplementally what would happen if TPZ stockholders
do not approve the Merger but stockholders of the other Target Funds do.

Response:
In the event TPZ stockholders do not approve the Merger but the stockholders of the other Target Funds do, the Board of the applicable
Target Fund may take such actions as it deems in the best interests of the Fund, including by proceeding with the applicable Merger(s),
or continuing to operate the Target Fund as a standalone fund. Disclosure to this effect has been added to the Joint Proxy Statement/Prospectus.

October 16, 2024

Page 5

 17. Comment: Please revise the disclosure on pages 3 and 59 of the Joint Proxy Statement/Prospectus
to specify the percentage of shares of each Target Fund necessary to achieve quorum and to approve the Merger proposal.

Response:
The Registrant has revised the disclosure in response to the staff’s comment.

 18. Comment: Under “Board Considerations of the Proposed Mergers” on page 4
of the Joint Proxy Statement/Prospectus and under “Comparison of Fees and Expense Ratios” on page 25 of the Joint Proxy
Statement Prospectus, please revise the disclosure to explain how the Target Fund Boards considered the gross fees and expenses of the
Target Funds versus those of the Acquiring Fund. Are total and net expense ratios expected to be the same?

Response:
The Registrant has revised the disclosure in response to the staff’s comment, and confirms that, given the fixed unitary fee rate
of the Acquiring Fund, the total and net expense ratios of the Acquiring Fund will be the same.

 19. Comment: Please revise the comparison of the Funds’ investment objectives on page 7
of the Joint Proxy Statement/Prospectus to include a narrative description of material differences.

Response:
The Registrant has revised the disclosure in response to the staff’s comment.

 20. Comment: Please move the pie charts comparing the asset types and investment structures
of the Target Funds’ portfolio holdings so as not to interrupt the narrative comparison of the Funds’ principal investment
strategies.

Response:
The Registrant has revised the disclosure in response to the staff’s comment.

 21. Comment: Please revise the cross-reference appearing below the pie charts on page 8
of the Joint Proxy Statement/Prospectus, and other cross-references in the document, to include page numbers.

Response:
The Registrant has revised the disclosure in response to the staff’s comment.

 22. Comment: Please revise the disclosure in the Joint Proxy Statement/Prospectus to include
a description of material differences between the fundamental investment restrictions of the Target Funds and those of the Acquiring Fund.
Material differences should be disclosed in the Joint Proxy Statement/Prospectus, not in the Statement of Additional Information.

Response:
The Registrant has revised the disclosure in the Joint Proxy Statement/Prospectus.

October 16, 2024

Page 6

 23. Comment: Under “Risks of the Funds” on page 8 of the Joint Proxy Statement/Prospectus,
please add a chart that compares the principal risks of investing in the Target Funds and the principal risks of investing in the Acquiring
Fund and explains material differences.

Response:
The Registrant has revised the disclosure in response to the staff’s comment.

 24. Comment: Under “Description of Shares” on page 8 of the Joint Proxy Statement/Prospectus,
please explain or provide a cross-reference to disclosure of material differences between the voting rights of stockholders of the Target
Funds and the voting rights of shareholders of the Registrant. Please specifically note that the Registrant has NAV-based voting while
the Target Funds do not.

Response:
The Registrant has revised the disclosure in response to the staff’s comment. Registrant notes that the final Declaration of Trust
approved by the Board does not include dollar-based voting rights.

 25. Comment: Please revise the disclosure to advise the Commission staff as