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Skadden, Arps, Slate, Meagher & Flom llp

	FOUR TIMES SQUARE NEW YORK 10036-6522 ________ TEL: (212) 735-3000 FAX: (212) 735-2000 www.skadden.com August 5, 2014	FIRM/AFFILIATE OFFICES ----------- BOSTON CHICAGO HOUSTON LOS ANGELES PALO ALTO WASHINGTON, D.C. WILMINGTON ----------- BEIJING BRUSSELS FRANKFURT HONG KONG LONDON MOSCOW MUNICH PARIS SÃO PAULO SHANGHAI SINGAPORE SYDNEY TOKYO TORONTO VIENNA

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

RE: BlackRock Resources & Commodities Strategy Trust (811-22501) N-14 Filing

Ladies and Gentlemen:

On behalf of BlackRock Resources & Commodities Strategy Trust (the "Fund"), we are enclosing herewith for filing pursuant to the Securities Act of 1933, as amended (the "Securities Act"), and the General Rules and Regulations of the Securities and Exchange Commission (the "Commission") thereunder, and the Investment Company Act of 1940, as amended, and the General Rules and Regulations of the Commission thereunder, one electronically signed Registration Statement on Form N-14 (the "Registration Statement").

The Registration Statement is being filed in connection with the reorganizations of BlackRock Real Asset Equity Trust (811-21931) and BlackRock EcoSolutions Investment Trust (811-22082) with BlackRock Resources & Commodities Strategy Trust (811-22501).

A fee of $128.80 to cover the registration fee under the Securities Act has been paid.

If you have any questions or require any further information with respect to this Registration Statement, please call me at (212) 735-3637 or Tom DeCapo at (617) 573-4814.

	Best regards,

	/s/ George Ching

	George Ching