SecProbe.io

CORRESP
1
filename1.htm

COMMENTS RECEIVED ON OCTOBER 12, 2005

FROM CHRISTIAN SANDOE

FIDELITY SCHOOL STREET TRUST (File Nos. 002-57167 and 811-02676)

Fidelity Intermediate Municipal Income Fund

POST-EFFECTIVE AMENDMENT NO. 70

1.	"Investment Summary" (prospectuses)

	"Principal Investment Risks"

"Issuer-Specific Changes. The value of an individual security or particular type of security can be more
volatile than the market as a whole and can perform differently from the value of the market as a whole.

	C:	The Staff would like us to address the credit quality of an issuer as a risk.

	R:	We believe the current disclosure is appropriate, as it summarizes the risks (i.e., that security
values can be more volatile or perform differently than the market as a whole) to which the fund
is subject. We do not believe "Investment Summary" is the appropriate section in which to
explain that changes in credit quality can contribute to these risks. Instead, we believe
"Investment Details" is the appropriate section to do that, and we note that current disclosure in
that section provides: "Changes in the financial condition of an issuer or counterparty, changes
in specific economic or political conditions that affect a particular type of security or issuer, and
changes in general economic or political conditions can affect a security's or instrument's credit
quality or value." We note that credit risk is an issuer specific risk, and we believe that the
current disclosure adequately brings it to the shareholder's attention. However, since the Staff
has made similar comments previously, we will consider whether a disclosure change would be
appropriate in future revisions.

2.	"Fee Table" (prospectuses)

	C:	The "Shareholder fees" and "Annual operating expenses" information should be presented as
one table with all footnotes following the table in its entirety.  The Staff believes that inserting
footnotes after the "Shareholder fees" information results in two tables instead of one.

	R:	As we have previously discussed with the Staff, we believe that the information included under
the subheadings "Shareholder fees" and "Annual operating expenses" in the "Fee Table" section
of the prospectus is presented in a manner consistent with Item 3 of Form N-1A. The footnotes
that support the information under each subheading are provided in the closest proximity
possible to that information to facilitate shareholder understanding of the information presented.
We note that General Instruction C.1(a) to Form N-1A states that a fund should use document
design techniques that promote effective communication, and we believe this format most
effectively communicates the information presented.

3.	"Investment Details" (prospectuses)

"Principal Investment Strategies"

"In addition to the principal investment strategies discussed above, FMR may invest the fund's assets in
lower-quality debt securities, and may use various techniques, such as buying and selling futures contracts,
swaps, and exchange traded funds, to increase or decrease the fund's exposure to changing security prices,
interest rates, or other factors that affect security values.  FMR may invest the fund's assets in municipal
debt securities by investing in other funds. If FMR's strategies do not work as intended, the fund may not
achieve its objective."

	C:	The Staff suggests that these are not principal strategies and they should be deleted from this
section and possibly moved into a newly created section.

	R:	We believe that the phrase "[i]n addition to the principal investment strategies discussed above"
added to the disclosure pursuant to the Staff's previous comments, adequately conveys that the
strategies that follow are not currently considered principal.  In addition, General Instruction
C.(3)(b) permits a fund to include in its prospectus (except in the Item 2 and Item 3 sections of
the prospectus) information that is not otherwise required, provided the information is not
incomplete, inaccurate, or misleading, and the disclosure does not obscure or impede
understanding of the information that is required to be included.  We feel the disclosure provides
shareholders with additional significant information about the fund's strategies and propose to
retain it in this section.

4.	"Valuing Shares" (prospectuses)

	C:	The Staff would like us to describe the effects of fair value pricing.

	R:	We call the Staff's attention to the disclosure currently presented in the last paragraph of the
"Valuing Shares" section. We note that the Instruction to Item 6(a)(1) of Form N-1A states that a
fund must provide a brief explanation of the circumstances under which it will use fair value
pricing and the effects of fair value pricing.  We believe that our current disclosure on fair value
pricing is responsive to this disclosure requirement.

5.	"Management Contract" (SAI)

"The portion of the portfolio manager's bonus that is linked to the fund's pre-tax investment performance is
measured against the Lehman Brothers 1-17 Year Municipal Bond Index. The portfolio manager's bonus is
based on several components calculated separately over his tenure over a measurement period that
eventually encompasses a period of up to three years. The primary components of the portfolio manager's
bonus are based on (i) the pre-tax investment performance of the portfolio manager's fund(s) and account(s)
relative to a benchmark index assigned to each fund or account, and (ii) the investment performance of
other FMR municipal bond funds and accounts."

	C:	The Staff believes disclosure should i) explain the link between the portfolio manager's bonus
compensation and other funds he manages and other funds within the same group as the fund he
manages, and ii) the time periods to which the bonus compensation is based.

	R:	In response to the Staff's comments, we have revised the disclosure as follows (underlined
added, [bracketed] deleted):

"The portfolio manager's base salary is determined by level of responsibility and tenure at FMR or its
affiliates. [The portion of the portfolio manager's bonus that is linked to the fund's pre-tax investment
performance is measured against the Lehman Brothers 1-17 Year Municipal Bond Index.] The portfolio
manager's bonus is based on several components. Each component is calculated separately [over his tenure]
over a measurement period, [that] initially contemporaneous with his tenure on the fund(s) and account(s)
he manages, but which eventually encompasses a rolling period of up to three years. The primary
components of the portfolio manager's bonus are based on (i) the pre-tax investment performance of the
portfolio manager's fund(s) and account(s) relative to a benchmark index assigned to each fund or account,
which investment performance is weighted according to the time period during which the portfolio manager
has managed the fund(s) and account(s) and the average asset size of those fund(s) and account(s) during
that period, and (ii) the investment performance of other FMR municipal bond funds and accounts. The
portion of the portfolio manager's bonus that is linked to the fund's pre-tax investment performance is
measured against the Lehman Brothers 1-17 Year Municipal Bond Index. A subjective component of the
portfolio manager's bonus is based on the portfolio manager's overall contribution to management of FMR.
The portfolio manager also is compensated under equity-based compensation plans linked to increases or
decreases in the net asset value of the stock of FMR Corp., FMR's parent company. FMR Corp. is a diverse
financial services company engaged in various activities that include fund management, brokerage,
retirement and employer administrative services."

6.	Tandy (prospectus and SAI)

	C:	The Staff would like us to affirm the following three statements:

		1) The fund is responsible for the adequacy and accuracy of the disclosure in the filings.

		2) Staff comments or changes to disclosure in response to Staff comments in the filings
reviewed by the Staff do not foreclose the Commission from taking any action with respect to
the filing.

		3) The fund may not assert Staff comments as a defense in any proceeding initiated by the
Commission or any other person under the Federal Securities Laws.

	R:	We affirm the aforementioned statements.