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VIA EDGAR

John Ganley, Esq.

Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Re: BlackRock Resources & Commodities Strategy Trust (the “Trust”)

Dear Mr. Ganley:

On behalf of BlackRock Resources & Commodities Strategy Trust (the “Trust”), transmitted herewith for filing with the Securities and Exchange Commission (the “Commission”) under the Securities Act of 1933 and the Investment Company Act of 1940 is the Trust’s Pre-Effective Amendment No. 2 to the Registration Statement on Form N-2 (Nos. 333-170939 and 811-22501) (the “Registration Statement”).

We have received your oral comments on February 22, 2011 with respect to the Trust’s Pre-Effective Amendment No. 1 to the Registration Statement on Form N-2 filed on February 11, 2011. We expect to provide supplemental responses to your oral comments with the Trust’s next pre-effective amendment filing in approximately one week.

If you have any questions or comments or require any additional information in connection with the above, please telephone me at (212) 735-3406 or George Ching at (212) 735-3637.

	Very truly yours,

	/s/ Michael K. Hoffman
	Michael K. Hoffman

cc: George Ching