Skadden, Arps, Slate Meagher & Flom LLP
                               Four Times Square
                              New York, NY 10036


                                                     September 17, 2004


Securities and Exchange Commission
Judiciary Plaza
450 Fifth Street, N.W.
Washington, D.C.  20549
Attention:  Laura Hatch

Re:      Gabelli Utility Trust (the "Trust")
         (File Nos: 333-118701 and 811-09243)
         ------------------------------------

Ladies and Gentlemen:

         On August 31, 2004, a registration statement on Form N-2 (the
"Registration Statement") was transmitted electronically for filing on behalf
of the Trust pursuant to (1) the Securities Act of 1933, as amended, (2) the
Investment Company Act of 1940, as amended, (3) the General Instructions to
Form N-2, and (4) Rules 101 and 102 under Regulation S-T. The Registration
Statement was filed for the purpose of registering common shares of beneficial
interest of the Trust in connection with a proposed issuance of transferable
rights for common shares of beneficial interest to the Trust's shareholders.

         The disclosures in the Registration Statement are substantially
identical to those included in a registration statement with respect to a
previous issuance of transferable rights by the Trust (File Nos. 333-105467 and
811-09243), filed on May 22, 2003, as subsequently amended (the "Prior
Registration Statement"), with the following exceptions:

         o        The Registration Statement contemplates an issuance of four
                  transferable rights for each common share whereas under the
                  Prior Registration Statement three transferable rights were
                  issued for each common share;

         o        Additional disclosure has been added to the Registration
                  Statement clarifying that rights acquired in the secondary
                  market may not participate in the over-subscription
                  privilege. See "Prospectus Summary-Over-subscription
                  Privilege", "Prospectus Summary-Sale of Rights", "The
                  Offer-Terms of the Offer" and "The Offer-Over-subscription
                  Privilege";

         o        The Registration Statement has added disclosure regarding the
                  Trust's proxy voting procedures in accordance with the
                  revised requirements of Form N-2; and

         o        Other non-material updating changes.

         The Prior Share Registration Statement was previously reviewed by the
staff of the Securities and Exchange Commission (the "staff") in connection
with the Trust's previous issuance of rights for its common shares. In
accordance with Investment Company Release No. 13768, the Trust hereby requests
selective review of the Registration Statement limited to those portions not
previously reviewed by the staff during its review of the Prior Registration
Statement.

         We will file a request for acceleration of the effectiveness of this
registration statement when comments are resolved. If you have any questions,
please contact the undersigned at (212) 735-3556.

                                                     Very truly yours,

                                                     /s/Edward Meehan

                                                     Edward Meehan