SEC Division of Investment Management staff letter: BlackRock Science and Technology Trust and BlackRock Utilities, Infrastructure & Power Opportunities Trust

WILLKIE FARR &GALLAGHER up
Deputy Director and Chief Counsel
United States Securities and Exchange Commission Division of Investment Management l 00 F Street, N.E. Washington, DC 20549 Dear Mr. Cellupica:
On behalf ofeach ofBlackRock Science and Technology Trust ("BST") and BlackRock Utilities, Infrastructure & Power Opportunities Trust ("BUI" and together with BST, the "Funds" and each, a "Fund''), we seek assurance that the staff of the Division oflnvestment Management (the "Staff') will not recommend enforcement action against a Fund to the Securities and Exchange Commission (the "Commission") under Section 5(b) or Section 6(a) of the Securities Act of 1933, as amended (the "Securities Act"), if it utilizes Rule 486(b) under the Securities Act to file post-effective amendments to its registration statement in satisfaction of the undertakings contained in its registration statement under the circumstances set forth in this letter.
I. Background
Each Fund is a closed-end management investment company that is registered under the Investment Company Act of 1940, as amended (the "Investment Company Act"). Each Fund is organized as a Delaware statutory trust and is governed by a board of trustees ( each, a "Board"). Each Fund is authorized to issue common shares of beneficial interest. Each Fund's common shares of beneficial interest are registered under Section I 2(b) of the Securities Exchange Act of 1934, as amended, and are listed and traded on the New York Stock Exchange. BlackRock Advisors, LLC serves as the investment adviser to each Fund. Each Fund has a fiscal year end of December 31. Each Fund has filed and had declared effective an equity shelfregistration statement on Form N-2 pursuant to which it has registered, and may issue, common shares of beneficial interest in accordance with the terms of Rule 415(a)(l)(x) under the Securities Act and the positions of the Staff articulated in Pilgrim America Prime Rate Trust, SEC Staff No-Action Letter (May 1, 1998) ("Pilgrim Letter") and Nuveen Virginia Premium !11co111e lvfunicipal Fund, SEC Staff No-Action Letter (Oct. 6, 2006) ("Nuveen Letter"). Ntw YoRK "Y!ASH!NGTON HoeSTON PALO Aero SAN FRANC!SCO PAR.JS LONDON fRANKHJRT BRUSSHS fv1lLAN ROME