BUTZEL LONG, a professional corporation
                               380 Madison Avenue,
                               New York, NY 10017

                               Tel: (212) 818-1110
                               FAX: (212) 818-0494
                            e-mail: jones@butzel.com



                                       January 29, 2010


BY EDGAR

Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549

               Re:  Tax-Free Trust of Oregon (a portfolio of
                    The Cascades Trust)
                    File Nos. 33-4382 and 811-4626

Dear Sirs:

     On behalf of Tax-Free Trust of Oregon (the "Trust"), the only series of the
Cascades Trust, we are filing today with the Commission, pursuant to Rule 485(b)
under the Securities Act of 1933 (the "1933 Act") and pursuant to the Investment
Company Act of 1940 (the "1940 Act"), the following documents:

         In accordance with Rule 472(b) under the 1933 Act and Rule 8b-11 under
         the 1940 Act, the text on Form N-1A of Post-Effective Amendment No. 35
         to the Registration Statement of the Trust under the 1933 Act and
         Amendment No. 36 to the Registration Statement of the Trust under the
         1940 Act, marked to show changes.

         This filing does not contain disclosures that would make it ineligible
to be filed under Rule 485(b).

         The staff is advised that this filing supersedes a filing under Rule
485(a) for this Trust, which will not become effective.

         We received staff comments with respect to that filing, all of which
are addressed in this filing.

         Pursuant to Rule 485(b) it is proposed that this amendment will become
effective on February 1, 2010.

                                            Very truly yours,


                                            /s/ Robert I. Jones
                                            Robert I. Jones