Exhibit 11

KIRKPATRICK & LOCKHART LLP
1800 Massachusetts Avenue, N.W.
2nd Floor
Washington, D.C. 20036-1800
Telephone (202) 778-9000
Facsimile (202) 778-9100
www.kl.com

October 27, 1999

Fidelity Select Portfolios
82 Devonshire Street
Boston, Massachusetts 02109

Ladies and Gentlemen:

 You have requested our opinion regarding certain matters in
connection with the issuance of shares of Fidelity Select Gold
Portfolio ("Gold Portfolio"), a series of Fidelity Select Portfolios
(the "Trust"), pursuant to a Registration Statement to be filed by the
Trust on Form N-14 ("Registration Statement") under the Securities Act
of 1933 ("1933 Act") in connection with the proposed acquisition by
Gold Portfolio of all of the assets of Fidelity Select Precious Metals
and Minerals Portfolio ("Precious Metals and Minerals Portfolio"),
also a series of the Trust, and the assumption by Gold Portfolio of
the liabilities of Precious Metals and Minerals Portfolio solely in
exchange for Gold Portfolio shares.

 In connection with our services as counsel for the Trust, we have
examined, among other things, originals or copies of such documents,
certificates and corporate and other records as we deemed necessary or
appropriate for purposes of this opinion.  We have assumed the
genuineness of all signatures, the authenticity of all documents
submitted to us, the conformity to original documents of all documents
presented to us as copies thereof and the authenticity of the original
documents from which any such copies were made, which assumptions we
have not independently verified.  As to various matters of fact
material to this opinion, we have relied upon statements and
certificates of officers of the Trust.  Based upon this examination,
we are of the opinion that the shares to be issued pursuant to the
Registration Statement, when issued upon the terms provided in the
Registration Statement, subject to compliance with the 1933 Act, the
Investment Company Act of 1940, and applicable state law regulating
the offer and sale of securities, will be legally issued, fully paid,
and non-assessable.

 The Trust is an entity of the type commonly known as a "Massachusetts
business trust."  Under Massachusetts law, shareholders of a business
trust may be held personally liable for the obligations of the Trust.
The Trust's Declaration of Trust provides that the Trustees shall have
no power to bind any shareholder personally or to call upon any
shareholder for the payment of any sum of money or assessment
whatsoever other than such as the shareholder may at any time
personally agree to pay by way of subscription for any shares or
otherwise.  The Declaration of Trust also requires that every note,
bond, contract or other undertaking issued by or on behalf of the
Trust or the Trustees relating to the Trust shall include a recitation
limiting the obligation represented thereby to the Trust and its
assets (although the omission of such recitation shall not operate to
bind any shareholder).  The Declaration of Trust provides that: (i) in
case any shareholder or any former shareholder of any Series of the
Trust shall be held personally liable solely by reason of his being or
having been a shareholder and not because of his acts or omissions or
for some other reason, the shareholder or former shareholder shall be
entitled out of the assets belonging to the applicable Series to be
held harmless from and indemnified against all loss and expense
arising from such liability; and (ii) a Series shall, upon request by
the shareholder, assume the defense of any claim made against any
shareholder for any act or obligation of that Series and satisfy any
judgment thereon.

 We hereby consent to your filing a copy of this opinion as an exhibit
to the Registration Statement.

       Yours truly,

       /s/ Kirkpatrick & Lockhart LLP
           Kirkpatrick & Lockhart LLP