PHOENIX HOME LIFE VARIABLE ACCUMULATION ACCOUNT
N-4/A, EX-99.10(A), 2001-01-12
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                                 EXHIBIT 10(a)

                               WRITTEN CONSENT OF
                               EDWIN L. KERR, ESQ.
<PAGE>




To Whom It May Concern:


    I hereby consent to the reference to my name under the caption "Legal
Matters" in the Prospectus contained in Pre-Effective Amendment No. 1 to the
Registration Statement on Form N-4 (File No. 333-47862) filed by Phoenix Home
Life Mutual Insurance Company for the Phoenix Home Life Variable Accumulation
Account with the Securities and Exchange Commission under the Securities Act of
1933.




Very truly yours,


/s/ Edwin L. Kerr
---------------------------------------
Edwin L. Kerr, Counsel
Phoenix Home Life Mutual Insurance Company









Dated January 12, 2001



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