<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>a38716.txt
<DESCRIPTION>CORRESPONDENCE
<TEXT>


<PAGE>


            [Letterhead of Cohen & Steers Select Utility Fund, Inc.]




                                               November 8, 2004


OVERNIGHT DELIVERY AND EDGAR
----------------------------

Securities & Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

Attention: Mr. Keith O'Connell

Re:  Cohen & Steers Select Utility Fund, Inc.
     Registration Statement on Form N-2
     Filed on November 8, 2004
     File Nos.: 333-119279 and 811-21485

Dear Mr. O'Connell:

     Pursuant to Rule 461 of the General Rules and Regulations under the
Securities Act of 1933, as amended, Cohen & Steers Select Utility Fund, Inc.
(the "Fund") hereby requests that the effective date of the Registration
Statement on Form N-2 (File Nos.: 333-119279 and 811-21485) (the "Registration
Statement") be accelerated so that it will be declared effective as soon as
practicable on Wednesday, November 10, 2004.

     We have also been advised that the National Association of Securities
Dealers, Inc. has no objection to the underwriting arrangements.

     In addition, as you requested in a telephone conversation held on November
4, 2004 with Jon R. Gray of Simpson Thacher & Bartlett LLP, the Fund hereby
acknowledges that:

     o  in declaring the Registration Statement effective, neither the
        Securities and Exchange Commission (the "Commission") nor the staff of
        the Commission (the "Staff") forecloses itself from taking any action
        with respect to the Registration Statement;

     o  the action of the Commission or the Staff in declaring the filing
        effective does not relieve the Fund from its full responsibility for the
        adequacy and accuracy of the disclosure in the Registration Statement;
        and

     o  the Fund may not assert Staff comments as a defense in any proceeding
        initiated by the Commission or any person under the federal securities
        laws of the United States.


                                      Very truly yours,

                                      COHEN & STEERS SELECT
                                      UTILITY FUND, INC.


                                      By:  /s/ Lawrence B. Stoller
                                         ------------------------------
                                         Name: Lawrence B. Stoller




<PAGE>


                        [Letterhead of Merrill Lynch]

                                            Global Markets & Investment Banking

                                            4 World Financial Center - 5th Floor
                                            New York, New York 10080

                                            212-449-6500


                                                                November 8, 2004



Mr. Keith O'Connell
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

Re:  Cohen & Steers Select Utility Fund, Inc. (the "Fund")
     Form N-2 Registration Statement No. 333-119279
     Investment Company Act File No. 811-21485

Dear Mr. O'Connell:

     Pursuant to Rule 460 of the General Rules and Regulations under the
Securities Act of 1933, as amended (the "Securities Act"), we on behalf of the
several underwriters, wish to advise you that the amended Registration
Statement, Form N-2 as filed on November 8, 2004, and Preliminary Prospectus
dated November 8, 2004, will be electronically distributed during the period
November 8, 2004 through pricing on November 10, 2004 as follows: approximately
350 copies of the Preliminary Prospectus and a limited number of Registration
Statements will be sent to underwriters, dealers and institutions.

     In accordance with Rule 461 of the General Rules and Regulations under the
Securities Act, the undersigned, on behalf of the underwriters of the offering
of up to 2,680 preferred shares of beneficial interest of the Fund, Series T28,
hereby joins in the request of the Fund for acceleration of the effective date
of the above-named Registration Statement so that it becomes effective on
November 10, 2004, or as soon as possible thereafter.

                                      Very truly yours,

                                      MERRILL LYNCH & CO.
                                      MERRILL LYNCH, PIERCE, FENNER & SMITH
                                                  INCORPORATED

                                      On behalf of the several Underwriters

                                      By: MERRILL LYNCH, PIERCE, FENNER & SMITH
                                                      INCORPORATED


                                      /s/ Richard A. Diaz
                                      -------------------------
                                      Name: Richard A. Diaz
                                      Authorized Signatory



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