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    Chicago

    New York

    Washington, DC

    London

    San Francisco

    Los Angeles

    Singapore

    Dallas

    Miami

    October 18, 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, D.C. 20549

    Attn:
    Ms. Eileen Smiley

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

    Registration Statement on Form N-1A

    File No. 333-281744

To the Commission:

On behalf of the Registrant, this letter is in
response to the comments provided by the staff of the U.S. Securities and Exchange Commission (the “Commission”) to Vedder
Price P.C. on September 20, 2024 with respect to the Registration Statement on Form N-1A filed on August 23, 2024 (the “Registration
Statement”) for Tortoise Power and Energy Infrastructure Fund (the “Fund”), a series of the Registrant. 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 missing information in the Prospectus and Statement of Additional Information and to file exhibits in Part C of the Registration
Statement.

PROSPECTUS

Cover Page

 1. Comment: Please complete all blank fields.

Response:
The Registrant confirms that it will complete all blank fields before requesting effectiveness of the Registration Statement.

    222
    North LaSalle Street  |  Chicago, Illinois 60601  |  T +1 312 609 7500  |  F
    +1 312 609 5005

    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.

U.S. Securities and Exchange Commission

October 18, 2024

Page 2

Fund Summary, page
1

Fees and Expenses of the
Fund, page 1

 2. Comment: Please bold the second sentence in the narrative before the fee table as required
by Item 3 of Form N-1A.

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

 3. Comment: Please disclose in a footnote to the Fund’s fee table that “Other Expenses”
are based on estimated amounts for the current fiscal year as required by Instruction 6(a) to Form N-1A.

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

Example, page 1

 4. Comment: Please only include expenses for years 1 and 3 as this is a new fund.

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

Principal Investment Strategies,
pages 1-10

 5. Comment: The disclosure found in Pages 1-10, appears to be a description of the Fund’s
principal investment strategies. Form N-1A requires a summary in plain English of the principal investment strategies of the Fund and
should be a summary of the information provided in Item 9. The disclosure does not conform to this requirement. Inclusion of excessive
detail and disclosure that is not a principal investment strategy of the Fund has the effect of obscuring important information about
the Fund’s principal investment strategies. Please revise the Item 4 description of principal investment strategies to conform to
the requirements of Form N-1A and provide a concise summary in plain English of the principal investment strategies the Fund will utilize
to seek to meet its investment objective and move disclosure unrelated to principal strategies and excessive detail to Item 9 or the Statement
of Additional Information, as appropriate. Examples include, but are not limited to, the following:

(a)
The third full paragraph on Page 2, contains a discussion of the qualification requirements under Subchapter M of the Internal Revenue
Code. This is not a principal strategy and should be covered in response to Item 7 of Form N-1A.

(b)
The section entitled “Power and Energy Infrastructure Fixed Income Securities” on Page 3 contains a lengthy description of
different features of certain fixed income securities and in some cases risks of certain fixed income securities. Please move excessive
detail to Item 9 or an appropriate place in the registration statement (risk section of Item 4 or 9 or the SAI as appropriate) so as not
to obscure important information about the Fund’s principal strategies.

(c)
The first full paragraph of the section entitled “Power and Energy Infrastructure Equity Securities” on Page 4-6, states that
the Fund intends primarily to invest in MLP common units and common stock and then goes on to refer to a lengthy list of other equity
securities and details about each of those types of equity securities, including some risk disclosure (adverse events, etc.) about equity
securities. Item 4 should list only the securities that the Fund will invest in as a principal strategy with the other detailed descriptions
of the instruments and the risks in an appropriate part of the registration statement, including the Summary Risk Section of Item 4 or
in Item 9 or the SAI, as appropriate.

U.S. Securities and Exchange Commission

October 18, 2024

Page 3

(d)
Item 4 requires disclosure of principal strategies and not negative strategies. The disclosure that the Fund will not engage in short
sales in the second full paragraph on Page 2 is not a principal strategy and can be included in Item 9 or the SAI as a non-fundamental
investment policy.

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

 6. Comment: The second full paragraph on Page 1 states that the Fund invests primarily in power
and energy infrastructure companies. The first full paragraph on Page 2 details the Fund’s 80% policy. Please reconcile this disclosure
with the Fund’s 80% policy

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

 7. Comment: Please define how the Fund interprets the phrase “stable and defensive characteristics”
and “throughout economic cycles” in the second sentence of the last full paragraph on Page 1.

Response:
The Registrant views companies that provide consistent dividends and stable earnings regardless of the state of the overall stock market
as companies providing stable and defensive characteristics throughout economic cycles. The Registrant has revised the disclosure accordingly.

 8. Comment: Please disclose how the Fund defines “low volatility and minimization of
downside risk” in the first sentence of the first paragraph on Page 2.

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

 9. Comment: Please disclose how the Fund defines “assets systems” in the last sentence
of the first paragraph on Page 2.

Response:
The Registrant has revised the disclosure to refer to “long-lived assets” in place of “asset systems.”

 10. Comment: The second sentence of the first paragraph on Page 2 states that the Fund invests
80% of its total assets, including borrowings, in securities of energy and infrastructure companies. This paragraph also defines power
infrastructure and energy infrastructure companies but does not include the criteria that the Fund will use to identify how a particular
company is economically tied to power infrastructure or energy infrastructure. Please disclose the criteria the Fund will use to determine
whether a company is a power infrastructure or energy infrastructure company for purposes of its 80% policy.

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

U.S. Securities and Exchange Commission

October 18, 2024

Page 4

 11. Comment: Please consider re-organizing the principal investment strategy disclosure to generally
describe the types of securities that the Fund will invest in and then group discussion of similar investments/strategies, investment
vehicles, investments, and/or limitations together. For example, the first sentence of the second full paragraph on Page 2 states that
the Fund will invest a minimum of 50% of its total assets in fixed income securities and then contains other investment limitations that
could potentially apply to fixed income or other investments. As another example, as drafted, the permissive list of investments in foreign
issuers could be interpreted as applying only to fixed income investments of the Fund because it is contained in the paragraph describing
the Fund’s investments in fixed income securities.

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

 12. Comment: In the second full paragraph on Page 2, disclose how the Fund will invest the remaining
50% of its assets (i.e., in equity securities or derivatives etc.) and then how the remaining investment limitations apply to both types
of investments.

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

 13. Comment: The second full paragraph on Page 2 states that the Fund may invest 10% of its
assets in non-US issuers. If the Fund may invest, as a principal strategy in emerging markets issuers, please add disclosure to that effect
and risk disclosure about the additional risks of investing in emerging markets.

Response:
The Registrant confirms that investments in securities of emerging markets issuers is not a principal strategy of the Fund.

 14. Comment: The first sentence of the fourth full paragraph on Page 2 states that “[a]lthough
inconsistent with its investment objectives, under adverse market or economic conditions or pending investment of offering or leverage
proceeds” the Fund can make certain defensive investments and describes those investments and certain risks associated with such
investments.

(a)
In compliance with Form N-1A, if these investments will be a principal strategy, please provide a concise summary in plain English if
the Fund will use temporary defensive investments, and under what circumstances with additional detail and risk disclosure in an appropriate
place in the registration statement.

Response:
The Registrant confirms that these investments are not a principal strategy of the Fund.

(b)
Please also supplementally explain if and how the Fund intends to obtain leverage. If so, please disclose accordingly if it is part of
the principal investment strategy, or otherwise revise the disclosure referring to leverage if this was inadvertently included.

Response:
For the information of the staff, the Fund does not intend to use leverage in the implementation of its principal investment strategies.

U.S. Securities and Exchange Commission

October 18, 2024

Page 5

 15. Comment: The first full paragraph on Page 3 states that the Fund may invest up to 25% of
its assets in MLPs.

(a)
Please disclose in an appropriate place in the registration statement, as applicable, that if an MLP in which the Fund invests amends
its partnership tax return, shareholders may receive a corrected 1099 from the Fund, which could, in turn, require shareholders to amend
their own federal, state, or local tax returns.

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

(b)
If the Fund invests in equity interests of MLPs, please confirm if those investments include general partnership interests in the MLP

Response:
The Registrant confirms that the Fund will not invest in general partnership interests in MLPs.

(c)
Please confirm that current income tax expenses and/or deferred income tax expenses will be reflected in the fee table.

Response:
The Registrant confirms that current income tax expenses and/or deferred income tax expenses, if any, will be reflected in the fee table.

 16. Comment: Please explain supplementally to the staff whether the Fund intends to invest through
any entity that: (1) is primarily controlled by the Fund; and (2) primarily engages in investment activities in securities or other assets.
If so, we may have additional comments.

Response:
For the information of the staff, the Fund has no intention to invest through such entities.

 17. Comment: The first sentence of the section entitled “Investment Grade Securities”
refers to the “Adviser.” Please disclose the name of the Adviser the first time the term is used as a defined term.

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

 18. Comment: The section entitled “Power and Energy Infrastructure Equity Securities”
on Page 4 states that equity securities could consist of MLP common units or common stock. MLP interests are also discussed on Page 3
related to the Fund’s investments in fixed income securities. Consistent with Comment 11, please consider re-organizing the principal
investment strategy disclosure to group discussion of similar investments/vehicles/strategies together to provide a more concise summary
of the Fund’s principal investment strategies.

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

 19. Comment: Please supplementally explain if the Fund will invest more than 15% of its assets
in hedge funds or private equity issuers that rely on the exclusions in either Section 3(c)(1) or Section 3(c)(7) of the Investment Company
Act of 1940. Also, please supplementally explain if the Fund will invest in the securities of unlisted closed end funds or business development
companies.

Response:
For the information of the staff, the Fund has no intention to invest in such securities.

U.S. Securities and Exchange Commission

October 18, 2024

Page 6

 20. Comment: The section entitled “Covered Call Options Strategy” on Page 6 describes
the Fund’s covered call options strategy and states that the Fund currently intends to only write calls on securities it holds in
its portfolio. Please supplementally explain if the Fund will only write call options on securities that it owns, or if the Fund will
use a synthetic options strategy. We may have additional comments.

Response:
For the information of the staff, in connection with its covered call options strategy, the Fund intends to write options only on securities
it owns and has no intention to use a synthetic options strategy.

Principal Risks,
pages 7-12

 21. Comment: Form N-1A requires a summary of the principal risks with more detailed disclosure
of the risks in Item 9. There does not appear to any differentiation between the risks disclosed in Item 4 and the risk disclosed in Item
9. Please revise to provide a summary of the more detailed risk disclosure in Item 9.

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

 22. Comment: Please order the principal risks of this Fund in order of importance. For example,
concentration risk is disclosed at the end of the summary risk disclosure on Pages 10 and 11. See ADI 2019-08 – Improving Principal
Risks Disclosure.

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

 23. Comment: There is summary risk disclosure entitled “Diversification Risk” on
Page 9. However, the principal strategies do not disclose that the Fund is non-diversified. Please disclose that the Fund is non-diversified
in the discussion of principal investment strategies to align the principal risks with the principal investment strategies.

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

 24. Comment: On Page 12 of the Statement of Additional Information, you state that the Fund
can concentrate in a group of industries. Page 10 of the “Principal Risks” section contains sector concentration risk disclosur