PROTECTIVE LIFE INSURANCE CO
AW, 1999-03-15
LIFE INSURANCE
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STEVE M. CALLAWAY
 Senior Associate Counsel

Writer's Direct Number: (205) 868-3804
Facsimile Number: (205) 868-3597
Toll-Free Number: (800) 627-0220
E-mail: [email protected]



                                                 February 22, 1999

VIA FACSIMILE

Securities and Exchange Commission
Office of Edgar Information and Analysis
450 Fifth Street, NW
Washington, DC 20549

         RE:      ACCESSION NUMBER: 0000950168-99-000352
                  Post-Effective Amendment No. 1 to
                  Registration Statement No. 333-50055 on Form S-1

Dear Commissioners:

         On February 12,  1999,  Protective  Life  Insurance  Company  filed the
above-captioned   Registration   Statement   using   the   wrong   CIK  and  CCC
identification  numbers.  Due to this error,  please withdraw  Accession Number:
0000950168-99-000352. On February 16, 1999, the subject Post-Effective Amendment
was filed using the correct CIK and CCC  identification  numbers.  The Accession
Number for the correct filing is 0000950168-99-000426.

         Thank you for your  assistance  in this  matter and please  address any
questions or comments about this filing to the undersigned at (800) 627-0220.

                                                     Very truly yours,

                                                       /s/ Steve M. Callaway

                                                     Steve M. Callaway







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