<DOCUMENT>
<TYPE>EX-99.77B ACCT LTTR
<SEQUENCE>2
<FILENAME>brrcst77b.txt
<TEXT>
REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Board of Trustees and Shareholders of BlackRock
Resources and Commodities Strategy Trust:

In planning and performing our audit of the consolidated
financial statements of BlackRock Resources and Commodities
Strategy Trust (the "Trust") as of and for the year ended
October 31, 2012, in accordance with the standards of the
Public Company Accounting Oversight Board (United States), we
considered the Trust's internal control over financial
reporting, including controls over safeguarding securities, as
a basis for designing our auditing procedures for the purpose
of expressing our opinion on the consolidated financial
statements and to comply with the requirements of Form N-SAR,
but not for the purpose of expressing an opinion on the
effectiveness of the Trust's internal control over financial
reporting. Accordingly, we express no such opinion.
The management of the Trust is responsible for establishing
and maintaining effective internal control over financial
reporting.  In fulfilling this responsibility, estimates and
judgments by management are required to assess the expected
benefits and related costs of controls.  A company's internal
control over financial reporting is a process designed to
provide reasonable assurance regarding the reliability of
financial reporting and the preparation of the consolidated
financial statements for external purposes in accordance with
generally accepted accounting principles.  A company's
internal control over financial reporting includes those
policies and procedures that (1) pertain to the maintenance of
records that, in reasonable detail, accurately and fairly
reflect the transactions and dispositions of the assets of the
company; (2) provide reasonable assurance that transactions
are recorded as necessary to permit preparation of the
consolidated financial statements in accordance with generally
accepted accounting principles, and that receipts and
expenditures of the company are being made only in accordance
with authorizations of management and directors of the
company; and (3) provide reasonable assurance regarding
prevention or timely detection of unauthorized acquisition,
use, or disposition of a company's assets that could have a
material effect on the consolidated financial statements.
Because of its inherent limitations, internal control over
financial reporting may not prevent or detect misstatements.
Also, projections of any evaluation of effectiveness to future
periods are subject to the risk that controls may become
inadequate because of changes in conditions or that the degree
of compliance with the policies or procedures may deteriorate.
A deficiency in internal control over financial reporting
exists when the design or operation of a control does not
allow management or employees, in the normal course of
performing their assigned functions, to prevent or detect
misstatements on a timely basis.  A material weakness is a
deficiency, or a combination of deficiencies, in internal
control over financial reporting, such that there is a
reasonable possibility that a material misstatement of the
company's annual or interim consolidated financial statements
will not be prevented or detected on a timely basis.
Our consideration of the Trust's internal control over
financial reporting was for the limited purpose described in
the first paragraph and would not necessarily disclose all
deficiencies in internal control that might be material
weaknesses under standards established by the Public Company
Accounting Oversight Board (United States).  However, we noted
no deficiencies in the Trust's internal control over financial
reporting and its operation, including controls for
safeguarding securities that we consider to be a material
weakness, as defined above, as of October 31, 2012.
This report is intended solely for the information and use of
management and the Board of Trustees of BlackRock Resources
and Commodities Strategy Trust and the Securities and Exchange
Commission and is not intended to be and should not be used by
anyone other than these specified parties.

/s/ Deloitte & Touche LLP

Philadelphia, Pennsylvania
December 21, 2012


</TEXT>
</DOCUMENT>
