July 17, 2000
VIA EDGAR
Securities and Exchange Commission
450 Fifth Street, NW
Washington, D.C. 20549
Re: Representation of Counsel for SAFECO Life Insurance Company ("SAFECO
Life") and its SAFECO Separate Account C ("Separate
Account") Initial 33 Act Registration, Form N-4
File Nos. _________and 811-8052
Commissioners:
SAFECO and its Separate Account believe that the filing of this initial
registration is consistent with the purposes and requirements for filing under
Rule 485(a) under the Securities Act of 1933 ("1933 Act"). This representation
is based on the fact that this initial registration is consistent with the
purposes and requirements described in the adopting release for the changes to
Rule 485 (IC-Rel. 20486).
Based on the above, the filing of this registration is made pursuant to Rule
485(a) of the 1933 Act to become automatically effective as soon as is
practicable. The undersigned has prepared and reviewed this initial
registration, and it is his opinion that this registration does not contain
disclosures which would render it ineligible to become effective pursuant to
paragraph (a) of Rule 485.
Sincerely,
/s/ William E. Crawford
William E. Crawford
Counsel
