SecProbe.io

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                                [SHIP LOGO] VANGUARD/R/

                                                    July 12, 2005

Christian Sandoe, Esq.
Division of Investment Management
U.S. Securities and Exchange Commission            via electronic filing
450 Fifth Street,
N.W., Fifth Floor
Washington, D.C. 20549

                       Re:  VANGUARD WELLESLEY INCOME FUND
                                   FILE NO. 811-01766

Dear Mr. Sandoe:

         The following responds to your comments of July 8, 2005 on the
post-effective amendment of the Vanguard Wellesley Income Fund (the
"Registrant") registration statement on Form N-1A. You commented on PEA number
57 that was filed on May 23, 2005 pursuant to Rule 485(a). Note that each
prospectus page reference is to the Investor Shares versions of the prospectus.

COMMENT 1:  VANGUARD WELLESLEY INCOME FUND (PROSPECTUS PAGE 1)
--------------------------------------------------------------

Comment:          The "Fund Profile" contains the following description of the
                  Fund's primary investment strategies: "The Fund invests
                  approximately 60% to 65% of its assets in investment-grade
                  corporate, U.S. Treasury, and government agency bonds, as well
                  as mortgage-backed securities. The remaining 35% to 40% of
                  Fund assets are invested in common stocks of companies that
                  have a history of above-average dividends or expectations of
                  increasing dividends." It is not clear what the strategy is
                  and how the portfolio manager invests the Fund's assets.

Response:         We believe that with the following (underlined) change, the
                  "Fund Profile" appropriately summarizes the Fund's primary
                  investment strategies as required by Item 2(a) of Form N-1A:
                  "The Fund invests approximately 60% to 65% of its assets in
                  investment-grade corporate, U.S. Treasury, and government
                  agency bonds, as well as mortgage-backed securities that the
                                                                      --------
                  advisor believes will generate a high and sustained level of
                  ------------------------------------------------------------
                  current income. The remaining 35% to 40% of Fund assets are
                  --------------
                  invested in common stocks of companies that have a history of
                  above-average dividends or expectations of increasing
                  dividends."

COMMENT 2A: VANGUARD WELLESLEY INCOME FUND (PROSPECTUS PAGE 1)
--------------------------------------------------------------

Comment:        Disclose the following in the "Fund Profile"  section on page 1
                of the prospectus: (a) dollar-weighted average maturity or
                average duration of the Fund as of a recent date; and (b) the
                market  capitalization of the Fund as of a recent date.

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Christian Sandoe, Esq.
July 12, 2005
Page 2

Response:         Although dollar-weighted average maturity, duration, and
                  market-capitalization are all important economic
                  characteristics of the Fund, they are not part of the Fund's
                  primary investment strategies and are not, therefore, subject
                  to disclosure in the "Fund Profile" pursuant to Item 2 of Form
                  N-1A.
                           Because they are important characteristics, we
                  already disclose the Fund's average duration as of a recent
                  date (see page 8 of the prospectus). We will add the following
                  disclosure concerning market capitalization to the Security
                  Selection section of the prospectus: "Stocks of publicly
                  traded companies and funds that invest in stocks are often
                  classified according to market value, or market
                  capitalization. These classifications typically include
                  small-cap, mid-cap, and large-cap. It's important to
                  understand that, for both companies and stock funds, market
                  capitalization ranges change over time. Also, interpretations
                  of size vary, and there are no `official' definitions of
                  small-, mid-, and large-cap, even among Vanguard fund
                  advisors. The asset-weighted median market capitalization of
                  the Fund as of x, 2005, was $x billion."

COMMENT 2B: VANGUARD WELLESLEY INCOME FUND (PROSPECTUS PAGE 6)
--------------------------------------------------------------

Comment:          The following statement appears in the discussion of interest
                  rate risk on page 6 of the prospectus: "Interest rate risk for
                  the Fund should be moderate because the average duration of
                  the Fund's bond portfolio is intermediate-term ... ."
                  "Intermediate-term" is term used to describe bond maturity,
                  and not duration.

Response:         We believe that it is appropriate to characterize the Fund's
                  duration as intermediate-term. Furthermore, we have included
                  additional disclosure in the prospectus that defines
                  "duration" and states exactly what the Fund's average duration
                  was as of a specific date.

COMMENT 3:  VANGUARD WELLESLEY INCOME FUND (PROSPECTUS PAGE 7)
--------------------------------------------------------------
Comment:          The introduction to the "Security Selection" of the prospectus
                  contains the following statement: "The Fund is run according
                  to traditional methods of active investment management. To
                  achieve the Fund's investment objective--income and moderate
                  capital appreciation--the advisor follows specific strategies
                  for bond and stock selection." Describe the "specific
                  strategies" used by the advisor.

Response:         We have deleted the sentence that uses the phrase "specific
                  strategies," and have replaced it with the following:
                  "Securities are bought and sold based on the advisor's
                  judgments about companies and their financial prospects, and
                  about bond issuers and the general level of interest rates."
                  In addition to the foregoing statement, the prospectus
                  contains other disclosure about the advisor's investment
                  strategies.

COMMENT 4:  VANGUARD WELLESLEY INCOME FUND (PROSPECTUS PAGE 8)
--------------------------------------------------------------
Comment:          Define the term duration and give an example of how changes in
                  interest rates influence duration.

Response:         We already disclose the following definition and example in
                  the prospectus's glossary. "DURATION: A measure of the
                  sensitivity of bond--and bond fund--prices to interest rate
                  movements. For example, if a bond has a duration of two years,
                  its price would fall by approximately 2% when interest rates
                  rose by 1%. On the other hand, the bond's price would rise by
                  approximately 2% when interest rates fell by 1%."

<PAGE>
Christian Sandoe, Esq.
July 12, 2005
Page 3

COMMENT 5:  VANGUARD WELLESLEY INCOME FUND (PROSPECTUS PAGE 8)
--------------------------------------------------------------------------------
Comment:          In the "Plain Talk About Types of Bonds," several types of
                  bonds offered by corporations, governments, and other entities
                  are discussed. As discussed in Paul Roye's October 17, 2003
                  letter to the Investment Company Institute, clarify that not
                  all bond issuers are government-sponsored entities and that
                  their bonds may not be guaranteed or insured by the U.S.
                  government.

Response:         We will add the underlined text to the "Plain Talk About Types
                  of Bonds" as follows: "Bonds are issued (sold) by many
                  sources: Corporations issue corporate bonds; the federal
                  government issues U.S. Treasury bonds; agencies of the federal
                  government issue agency bonds; and mortgage holders issue
                  "mortgage-backed" pass-through certificates. Each issuer is
                  responsible for paying back the bond's initial value as well
                  as for making periodic interest payments. Many bonds issued by
                                                            --------------------
                  government agencies and entities are neither guaranteed nor
                  -----------------------------------------------------------
                  insured by the U.S. government."
                  -------------------------------

COMMENT 6:  VANGUARD WELLESLEY INCOME FUND (PROSPECTUS PAGE 9-10)
-----------------------------------------------------------------
Comment:          The following disclosure appears on pages 9-10 of the
                  prospectus: "The Fund's stocks are chosen primarily for their
                  dividend-producing capabilities, but must also have the
                  potential for moderate long-term capital appreciation. The
                  advisor looks for stocks of companies that either offer
                  significant dividends now or expect to increase their
                  dividends in the future. This income orientation leads the
                  Fund to invest in stocks with higher than market-average
                  dividend yields. As a result, the Fund's equity holdings are
                  expected to have more of a value orientation than a growth
                  orientation. Securities are sold when an investment has
                  achieved its intended purpose, or because it is no longer
                  considered attractive." Clarify what it means when an
                  investment has "achieved its intended purpose" or "is no
                  longer considered attractive."

Response:         We have deleted the following sentence: "Securities are sold
                  when an investment has achieved its intended purpose, or
                  because it is no longer considered attractive."

COMMENT 7:  VANGUARD WELLESLEY INCOME FUND (PROSPECTUS PAGE12)
----------------------------------------------------------------
Comment:          The Fund's broad policies with respect to frequent trading and
                  market-timing are disclosed on page 7 of the prospectus under
                  the heading "Frequent Trading or Market-Timing." However,
                  specific policies applicable to discrete types of investors
                  are disclosed in various sections throughout the "Investing
                  with Vanguard" section. All of the Fund's policies concerning
                  frequent trading and market-timing should be disclosed
                  together under the heading "Frequent Trading or
                  Market-Timing."

Response:         We believe that the Fund's policies against frequent trading
                  and market-timing are properly disclosed in the prospectus
                  pursuant to Item 6(e)(4) of Form N-1A.  Item 6(e)(4) does not
                  require that the specific policies applicable to each type of
                  shareholder be disclosed together in the prospectus.  As such,
                  we believe that it is appropriate to have the general
                  discussion of the Fund's policies against frequent trading and
                  market-timing under the heading "Frequent Trading or Market-
                  Timing" with a reference to the "Investing with Vanguard"
                  section where specific policies applicable to different types
                  of shareholders and transactions are disclosed.
                       We believe that removing the disclosure from the
                  "Investing with Vanguard" section and combining the disclosure
                  into a single "Frequent Trading and Market-Timing" section
                  would make the discussion of transaction policies incomplete
                  in the "Investing

<page>
Christian Sandoe, Esq.
July 12, 2005
Page 4

                  with Vanguard" section. Repeating the specific policies in
                  both the "Investing with Vanguard" section under the "Frequent
                  Trading and Market-Timing" section would unnecessarily clutter
                  the prospectus with duplicative disclosure.

COMMENT 8:  VANGUARD WELLESLEY INCOME FUND (PROSPECTUS PAGE 13)
---------------------------------------------------------------
Comment:          In the discussion of the Fund's investment advisor,
                  there are two portfolio managers listed. Indicate the separate
                  roles of each portfolio manager.

Response:         We will clarify that Earl E. McEvoy is the portfolio manager
                  responsible for the equity portion of the Fund, and that John
                  R. Ryan manages the fixed income portion of the Fund.

COMMENT 9:  VANGUARD WELLESLEY INCOME FUND (STATEMENT OF ADDITIONAL INFORMATION)
--------------------------------------------------------------------------------
Comment:         Where is the new SAI disclosure concerning portfolio manager
                 compensation and holdings?

Response:   We have not yet included the new disclosure concerning portfolio
            managers pursuant to Item 15 of Form N-1A because it is not yet
            required.  The adopting release for the portfolio manager disclosure
            rule (SEC release 33-8458) states, in part, that. "The effective
            date of the amendments is October 1, 2004. All initial registration
            statements on Forms N-1A, N-2, and N-3, and all post-effective
            amendments that are annual updates to effective registration
            statements on these forms, filed on or after February 28, 2005, must
            include the disclosure required by the amendments."
                  Although, this particular filing is a post-effective amendment
            filed after February 28, 2005, it is not an annual update.  We will
            include the disclosure when we file the annual update of the Fund's
            registration statement.

                                     * * * * *

As required by the SEC staff, each series of the Registrant acknowledges that:

- It is responsible for the adequacy and accuracy of the disclosure in the
  filing.
- Staff comments or changes in response to staff comments in the filings
  reviewed by the staff do not foreclose the Securities and Exchange Commission
  from taking any action with respect to the filing.
- It may not assert staff comments as a defense in any proceeding initiated by
  the Securities and Exchange Commission or any person under the federal
  securities laws of the United States.

Please call me at (610) 503-2320 if you have any questions.

                                                       Sincerely,

                                                  Christopher A. Wightman
                                                     Associate Counsel
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