February 27, 2025

Daniel Hurstak
Chief Financial Officer
Unitil Corporation
6 Liberty Lane West
Hampton, New Hampshire 03842-1720

       Re: Unitil Corporation
           Form 10-K for the Fiscal Year ended December 31, 2024
           Filed February 10, 2025
           File No. 001-08858
Dear Daniel Hurstak:

       We have reviewed your filing and have the following comments.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Year ended December 31, 2024
Financial Statements
Note 5 - Equity, page 61

1.     We note that you report using a weighted-average number of common shares
to
       calculate basic EPS of 16,098,000, although you report 16,116,724
outstanding
       common shares at the beginning of the period and 16,192,345 at the end
of the period,
       with no intervening decreases in the number of outstanding common
shares.

       We also understand that outstanding awards under your Stock Plan include
time
       restricted shares and performance restricted shares that entitle holders
to dividends in
       advance of vesting, and restricted stock units that entitle holders to
dividend
       equivalents to be paid upon separation from service.

       Please explain to us how these instruments were considered in your
calculations of the
       weighted average number of outstanding shares and EPS measures, to
include details
       of your assessment and application of guidance pertaining to the
two-class method in
       FASB ASC 260-10-45-59A through 45-68B for participating securities.
 February 27, 2025
Page 2


       Please submit the underlying calculations along with your reply,
including
       explanations where necessary to reconcile with the activity in vested
and unvested
       shares related to your Stock Plan at the end of each period covered by
your report.

       Please include any disclosure revisions that you propose to clarify your
views on these
       matters and handling of these instruments in your EPS calculations.

2.     We note that you have limited information about share activity both in
the statement
       on page 44 and among the disclosures in Note 5. Please revise your
statement or
       expand your disclosures to identify all of the changes in the number of
outstanding
       common shares for each period to comply with FASB ASC 505-10-50-2.

       With regard to your disclosure stating that you maintain a stock-based
compensation
       plan, please clarify whether you are referring to a plan that is
incremental to the three
       components of the Stock Plan, and address the requirements in FASB ASC
718-10-
       50-1 through 50-2A with respect to any additional plan.


        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

        Please contact Robert Babula at 202-551-3339 or Mark Wojciechowski at
202-551-
3759 if you have questions regarding comments on the financial statements and
related
matters.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Energy &
Transportation