BLACKWELL Eric J. Gervais 4801 MAIN STREET DIRECT LINE FAX
SANDERS Associate SUITE 1000 (816) 983-8362 (816) 983-8080
LLP KANSAS CITY, MO 64112
EMAIL ADDRESS TELEPHONE WEBSITE ADDRESS
egervais@blackwellsanders.com (816) 983-8000 www.blackwellsanders.com
February 19, 2008
VIA EDGAR
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: Larry L. Greene, Senior Counsel
Re: Tortoise Energy Capital Corporation (the "Company")
Dear Larry:
Today the Company filed via EDGAR a shelf Registration Statement on Form
N-2 (the "Registration Statement") under the Securities Act of 1933 and the
Investment Company Act of 1940. The purpose of this filing is to register the
Company's common stock, preferred stock and debt securities for offering from
time to time by the Company or certain stockholders of the Company. The Company
intends to use the proceeds from any offering pursuant to the Registration
Statement for investment purposes, to retire all or a portion of any debt under
its unsecured credit facility, to retire or redeem other senior securities, or
for working capital purposes.
On February 12, 2008, the Company's affiliate, Tortoise Energy
Infrastructure Corporation ("TYG"), had declared effective a shelf Registration
Statement registering its common stock, preferred stock and debt securities for
offering from time to time by TYG or certain of its stockholders (the "TYG Shelf
Registration Statement"). You were the Securities and Exchange Commission staff
member who reviewed the TYG Shelf Registration Statement. The Registration
Statement contains disclosure that it is nearly identical to that contained in
the TYG Shelf Registration Statement. The only substantive differences in the
disclosure contained in the Registration Statement are attributable to the
slightly different investment policies of TYG and the Company.
Due to the similarities in the disclosure contained in the Registration
Statement and the TYG Shelf Registration Statement, we are hereby requesting
selective review of the Registration Statement. We are not aware of any novel
issues or disclosure items requiring the attention of the staff in the
Registration Statement.
February 19, 2008
Page 2
Please call the undersigned at (816) 983-8362 or Steve Carman at (816)
983-8153 with any questions you may have.
Sincerely,
/s/ Eric J. Gervais
EJG
cc: Dave Schulte, Tortoise Capital Advisors, LLC
Terry Matlack, Tortoise Capital Advisors, LLC
Diane Bono, Tortoise Capital Advisors, LLC
