June 5, 2008

Ms. Sheila Stout
Staff Accountant
Securities and Exchange Commission
Division of Investment Management, Office of Disclosure
Mailstop 0505
Washington, DC  20549

This correspondence is being submitted via Edgar.

Dear Ms. Stout;

We thank you for your additional comments which you relayed to us in our
telephone conversation on the annual financial statements for the fiscal
years ending January 31, 2007 through December 31, 2007 of the Evergreen
Funds that are part of the following Trusts:
       Evergreen Money Market Trust
       Evergreen Asset Allocation Trust
       Evergreen Equity Trust
       Evergreen Fixed Income Trust
       Evergreen International Trust
       Evergreen Municipal Trust
       Evergreen Select Equity Trust
       Evergreen Select Fixed Income Trust
       Evergreen Select Money Market Trust
       Evergreen Variable Annuity Trust
       Evergreen Global Dividend Opportunity Fund
       Evergreen Multi-Sector Income Fund
       Evergreen Utilities and High Income Fund
       Evergreen International Balanced Income Fund
       Evergreen Income Advantage Fund

With respect to your comments, we submit the following responses.
Additionally, Evergreen Investments acknowledges that the fund is responsible
for the adequacy and accuracy of the disclosure in the filings; 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; and the fund may not assert staff comments as a
defense in any proceeding initiated by the Commission or any person under
the federal securities laws of the United States.

* * * *

SEC FILINGS
SEC Comment:
The Staff noted within certain NSAR-B filings that the accounting letter
within the filing didn't include the signature of the audit firm.

Evergreen Response:
The accounting letter has been revised to include the name of the audit
firm.  Any filing that was omitting this information is in the process
of being re-filed with the SEC.


SEC Comment:
The Staff noted there was an NT filing made for Evergreen International
Balanced Income Fund indicating the semiannual report would not be filed
by its deadline, however the actual semiannual report was filed on the
same date.

Evergreen Response:
Evergreen filed NT-NCSR on 1/10/2006 alerting the SEC of the inability
to meet its filing deadline of 1/9/2006.  Subsequently, on 1/10/2006
the actual N-CSRS was filed with the SEC.  The filing of the NT-NCSR was
required for this fund as it was known that the filing would be late.

SEC Comment:
The Staff noted the Code of Ethics was not dated within some of the N-CSR
filings during the period.

Evergreen Response:
The Code of Ethics document will be dated within all filings going forward.

SEC Comment:
The Staff noted the N-CSR filing for the Money Market Trust includes a
filing number on its cover sheet that doesn't agree with the filing number
under which it was filed.

Evergreen Response:
Evergreen is submitting filings for this Trust under its current filing
number of 811-08555. Subsequent to these filings being accepted by EDGAR,
the filing number is apparently being converted to the Trust's former
filing number of 811-05300. We have notified the Staff of this issue.

SEC Comment:
The Staff noted the 4/30/2007 N-Q filing for Evergreen Treasury Money Market
Fund includes a certification that is not dated.

Evergreen Response:
The N-Q is being re-filed and will include current dates on the certifications.
Original copies of the certifications with the date they were originally
reviewed, June 29, 2007, are maintained on hand.

SEC Comment:
The Staff noted for Evergreen Pennsylvania Municipal Bond Fund, item 4 of
the N-CSR filing includes audit fee information for the incorrect time period.
Information for 2006 and 2005 are included; however, it should include 2006
and 2007.

Evergreen Response:
This has been revised and is in the process of being re-filed.

* * * *

FINANCIAL HIGHLIGHTS

SEC Comment:
The Staff inquired of any Fund with a distribution of capital, to confirm
that shareholders were notified of such at the time of the distribution.

Evergreen Response:
Returns of Capital are determined, in accordance with tax code, at the end
of a fund's fiscal year. As such, the annual shareholder report serves as
a communication of this distribution.

Similarly, Rule 19a-1, under the 1940 act, requires the payment of any
dividend, or a distribution in the nature of a dividend payment, to be
accompanied by a written statement ("Section 19(a) Notice") which adequately
discloses the source(s) of the payment if it is made from any source other
than accumulated undistributed net income.  Evergreen distributed the
appropriate 19(a) Notices as required.



SEC Comment:
The Staff inquired in regards to the Asset Allocation Trust, why the expense
ratio was zero.

Evergreen Response:
Evergreen Investment Services, Inc. has reimbursed all Trust expenses.  The
only expenses attributable to the Trust are from custodian and accounting
fees and professional fees, both of which represent 0.00% of average net
assets even before the reimbursement.

* * * *

SCHEDULE OF INVESTMENTS

SEC Comment:
The Staff noted the disclosure of collateral for repurchase agreements does
not include sufficient detail describing the securities representing collateral.

Evergreen Response:
For some of the repurchase agreements entered into and those invested through
the security lending program, numerous pieces of collateral can be received
for each agreement.  In order to provide a meaningful description of the
collateral without detailing every piece of the collateral, Evergreen will
begin to list the collateral pieces by general issue type and provide a range
of coupon rates and maturity dates in addition to the market value of all the
collateral pieces.



SEC Comment:
The Staff inquired in regards to a long-term bond (Gulf Breeze) held in the
portfolio of Evergreen Strategic Municipal Bond Fund whether the value of
par was accurate.

Evergreen Response:
Evergreen verified the price of $100 from an external independent approved
pricing vendor as of the reporting date.


SEC Comment:
The Staff inquired in regards to Evergreen Institutional Mortgage Portfolio.
The principal investment strategy for the fund is to invest at least 80% in
mortgage and mortgage-backed securities, but the Schedule Of Investments
reflects 27% in short term investments. How does the fund comply with its
strategy at year end?

Evergreen Response:
The 27% represents an investment in an overnight cash vehicle.  This is not
considered part of the fund's investment strategy and thus should not be
considered when determining whether 80% of the fund is invested in mortgage
or mortgage-backed securities.  Ignoring such, the Institutional Mortgage
Portfolio has more than 80% of its securities invested in mortgage and
mortgage backed securities.

SEC Comment:
The Staff inquired in regards to Evergreen California Municipal Money Market
Fund. The principal investment strategy for the Fund is to invest 80% in
California bonds; however, it is not at year end.  Are there any other
states below 80%?

Evergreen Response:
The shareholder reports identify securities by the issuing state.  Certain
of the securities held by the California Municipal Money Market Fund, that
are not issued by a governing state, are considered exempt from federal
income tax and to the extent possible California personal income tax.  Such
investments would be disclosed as Non-State Specific in the shareholder
report.  For the year ended January 31, 2007 the Fund was not in a
violation of the 80% investment strategy.


We have also reviewed other State Specific Funds with a similar investment
strategy and have confirmed that there was no violation of such strategy.

SEC Comment:
The Staff inquired in regards to Evergreen Pennsylvania Municipal Bond
Fund. The Schedule of Investments includes underlying securities in an
inverse floating rate structure but does not include any inverse floaters.

Additional Inquiry
The staff further inquired as to the difference in disclosure between
Evergreen Pennsylvania Municipal Bond Fund and Evergreen North Carolina
Municipal Bond Fund as it relates to inverse floaters

Evergreen Response:
Investments in inverse floaters are treated as financing transactions
in accordance with SFAS 140. Based on this treatment, the security held
by the fund is the long-term bond underlying the floating rate structure
and not the inverse floater itself.

Additional Evergreen Response:
The North Carolina Municipal Bond Fund contains a disclosure that relates
to a inverse floating rate security purchased on the secondary market.
The Evergreen Pennsylvania Municipal Bond Fund did not purchase such
securities on the secondary market and therefore would not have this
disclosure included in the report.
* * *


STATEMENT OF ASSETS AND LIABILITIES
SEC Comment:
The Staff inquired whether all restricted cash was being separately
disclosed as such.

Evergreen Response:
The Evergreen funds identify any restricted cash separately on the
Statement of Assets and Liabilities.  Any large positions of cash
during the review, not identified as restricted cash, represented
un-invested, non-restricted cash at the end of period.

* * * *


STATEMENT OF OPERTIONS
SEC Comment:
The Staff inquired in regards to Evergreen High Yield Bond Fund. On
the Statement of Operations, there is income from affiliated
investments but on the Statement of Assets and Liabilities, there is
no reference to affiliated investments.

Additional Inquiry
The staff clarified the inquiry pertained to the Select High Yield
Bond Fund.

Evergreen Response:
Evergreen notes that the Fund held an investment in the Evergreen
Institutional Money Market Fund in the amount of $17,213,277 and as
such disclosed the position in the Statement of Assets and
Liabilities as an investment in affiliate.

Additional Evergreen Response
The Fund held investments in the Evergreen Institutional Money Market
Fund during the period but not at year end.

* * * *

NOTES TO FINANCIAL STATEMTENTS
SEC Comment:
The Staff inquired whether any contractual waivers were subject to a
recapture agreement. If so, disclosure of the terms should be made
within the notes.

Evergreen Response:
There is no recapture agreement in effect for any waivers.

SEC Comment:
The Staff suggested disclosing the percent of securities fair valued
by the Board of Trustees within the Notes to Financial Statements.

Evergreen Response:
Evergreen notes that all fair valued positions are clearly marked on
the SOI and generally, the amounts per fund are not material.

SEC Comment:
The Staff noted tri-party repurchase agreements are referenced in the
Notes to Financial Statements; however, the third party is not
included in the disclosure describing the repos.

Evergreen Response:
The tri-party repurchase agreements which are entered into by the funds
are typically with a counterparty and a third party custodian which
administers the collateral.  As the third party to the transaction is
the custodian and not counterparty to the agreement, they are not
disclosed in the description of the repurchase agreement.

SEC Comment:
The Staff inquired in regards to Evergreen New York Municipal Money
Market Fund and California Municipal Money Market Fund. Each fund has a
principal investment strategy including Tender Option Bonds but there is
no disclosure of Tender Option Bonds at period end. Other funds have
disclosure regarding Credit Default Swaps within the Notes to Financial
Statements but no Credit Default Swaps at period end. Why do some funds
have this disclosure and others do not?

Evergreen Response:
The significant accounting policy note in the shareholder reports
describes transaction types the funds have engaged in over the last 2
reporting cycles identified in the Statement of Changes.  These
transaction types may or may not be held at period end. If a fund did
not actively trade in a specific transaction type, it is not discussed
in the notes.


SEC Comment:
The Staff suggested that regarding distribution fees, Evergreen consider
disclosing the approved amount as well as the limited amount rather than
just the limited amount. This comment was also given during the review
of an N-14.

Evergreen Response:
We already have a section in the prospectus disclosing approved amounts
so we will begin including this disclosure in the shareholder reports as well.

SEC Comment:
The Staff noted in regards to Evergreen California Municipal Money Market
Fund, the MDFP includes a footnote stating that 12b-1 fees for Class S are
being waived; however, there is no mention of the waiver in the Notes to
Financial Statements.

Additional Inquiry
The staff further inquired as to the nature of the waiver in place for
Class S.

Evergreen Response:
Within the Notes to Financial Statements for this fund's shareholder report,
there is a note stating the amount waived for Class S.

Additional Evergreen Response:
Note 3 of the Notes to Financial Statements of the January 31, 2007 annual
report includes disclosure that states during the year ended January 31,
2007, EIMC voluntarily reimbursed Distribution Plan expenses (see Note 4)
relating to Class S shares in the amount of $91,251.

SEC Comment:
The Staff noted in regards to Evergreen Balanced Fund and Evergreen
Diversified Bond Fund, the Notes to Financial Statements indicate there is a
contractual waiver but the prospectus indicates there is a voluntary waiver.

Evergreen Response:
On 4/15/2007 for Evergreen Balanced Fund and on 5/20/2007 for Evergreen
Diversified Bond Fund, the contractual waivers expired and were not renewed.

* * * *




PROSPECTUS
SEC Comment:
The Staff noted for Evergreen Strategic Growth Fund, Evergreen Special Equity
Fund and Evergreen Short Intermediate Bond Fund, the portfolio turnover
exceeded 100% for consecutive years. There is no risk disclosure related to
high turnover in the funds' prospectuses. If high turnover is part of the
fund's investment strategy, there should be risk disclosure included in the
Fund's prospectus.

Additional Inquiry
The staff further inquired as to how Evergreen determines when the risk of
high turnover is part of the investment strategy.  Is there a point at which
this disclosure would be considered to be moved into the principal risks
disclosures?


Evergreen Response:
Each fund's prospectus currently includes disclosure relating to Portfolio
Turnover in the section entitled: "Other Fund Practices" (Please see page 53
of the Evergreen Domestic Equity Funds I prospectus dated February 1, 2008
in connection with Evergreen Strategic Growth Fund and Evergreen Special
Equity Fund and page 31 of the Evergreen Short and Intermediate Term Bond
Funds prospectus dated November 1, 2007 in connection with Evergreen Short
Intermediate Bond Fund.)  In the disclosure, each fund notes that
consideration of portfolio turnover is not a part of the fund's investment
strategy.  The risks associated with high turnover are discussed in the
disclosure.

Additional Evergreen Response:
If contemplation of portfolio turnover is not part of a fund's strategy then
there is not a point at which consideration would be given to move the
disclosure pertaining to the risk of high portfolio turnover into the
principal risk disclosures.

SEC Comment:
The Staff noted for Evergreen Strategic Growth Fund, 40% of the fund is
invested in Information Technology and for Evergreen Municipal Money Market
Fund, 40% of the fund is invested in Housing but there is no disclosure in
the prospectus indicating a principal investment strategy or risk to
concentrate investments. Item 4 of N1a requires such disclosure if the fund
has a policy to concentrate.

Evergreen Response:
As stated in each fund's current Statement of Additional Information, the
funds are managed under a fundamental policy that states that the fund will
not concentrate its investments in the securities of issuers primarily
engaged in any particular industry (other than securities that are issued or
guaranteed by the U.S. government or its agencies or instrumentalities).
(Please see the "Evergreen Domestic Equity Funds I" Statement of Additional
Information dated February 1, 2008 in connection with Evergreen Strategic
Growth Fund and the "Evergreen Money Market Funds" Statement of Additional
Information dated June 1, 2007 as supplemented November 1, 2007 in
connection with Evergreen Municipal Money Market Fund.)   In the regards
to Evergreen Strategic Growth Fund, the category entitled "Information
Technology" in the fund's most recent shareholder report denotes a sector
not an industry classification.  Within the "Information Technology" sector
 as noted in the report are various industries such as "Communications
Equipment" and "Software" none of which represents greater than 25% of the
 fund's portfolio.  In regards to Evergreen Municipal Money Market Fund,
the portion of the fund invested in "Housing" includes government securities
which are specifically excluded from the concentration policy for the fund.



SEC Comment:
The Staff noted for Evergreen Ultra Short Opportunity Fund, there is no
disclosure regarding the acceptable average maturity level of the fund's
investments within the prospectus. The table at the end of the Schedule of
Investments indicates a significant portion of securities in the > 3 year
range, which seems long for an ultra short fund. What is the acceptable
average maturity range for this fund?

Additional Inquiry
The staff further inquired as to the acceptable maturity range for the Fund.
Past filings indicate the range of 1 year maturities to approximately 10% of
the Fund.  Additionally, are these ranges considered to be under normal
market conditions?

Evergreen Response:
As disclosed in the fund's current prospectus dated November 1, 2007, the
fund's portfolio of securities is managed based an average portfolio
duration. Please see page 9 of the fund's prospectus which includes the
following statement: "Under normal market conditions, the fund intends to
maintain an average portfolio duration of approximately one year or less."

 Additional Evergreen Response:
As noted in the prospectus, the fund is managed to an average duration and
not to effective maturity which is what the table in the shareholder reports
disclose.  Effective maturity can be used as a proxy for duration; however,
duration is a measure of the approximate sensitivity of a bond's value to
interest rate changes.  Duration decreases as a bond gets closer to its
maturity date, as the security is less volatile because risk of call, and
principal and interest default is less.


OTHER
SEC Comment:
The Staff noted for Evergreen Pennsylvania Municipal Bond Fund and Evergreen
Balanced Fund, there is disclosure within the first few pages of the N-CSR
that the strategy had changed. How were shareholders notified? What are the
details of the change? Why was there no A filing if part of the principal
investment strategy changed?

Additional Inquiry
The staff asked for indication as to the date the sticker related to the
strategy change was filed.  The staff also inquired as to the driving reason
for the strategy change (was it to align with other funds)?

Evergreen Response:
Within the 3/31/2007 annual report for Evergreen Pennsylvania Municipal Bond
Fund, there was a shareholder notification text box that included the details
of the change related to investments in derivatives to be effective on
7/1/2007. The 3/31/2007 annual report for Evergreen Balanced Fund also
included a shareholder notification text box that included the details of the
 strategy change effective 6/1/2007. This change was also included in a
sticker to the prospectus for both funds.

Additional Evergreen Response:
The Supplement to the Prospectus, which identified the strategy change, was
filed on 12/18/2006. The SEC Accession number was 0000907244-06-000712.
The driving reason behind the strategy change was that Evergreen wanted to
provide the funds broader flexibility for use of certain derivatives,
including credit default swaps
* * * *






If you have any further questions regarding the responses contained herein,
please contact me at 617.210.3588.

Sincerely,



Kasey Phillips
Senior Vice President, Evergreen Investment Services, Inc.
Treasurer, Evergreen Funds


Jeremy DePalma
Senior Vice President, Evergreen Investment Services, Inc.
Treasurer, Evergreen Funds


cc:  The Audit Committee of the Evergreen Funds
	Steve Bowen, Partner  KPMG
	Steve Callahan, Partner  KPMG







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