EXHIBIT 10(a)
LETTER OF CONSENT
<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 Post-Effective Amendment No. 1 to the
Registration Statement on Form N-4 (File No. 333-95611) filed by PHL Variable
Accumulation Account with the Securities and Exchange Commission under the
Securities Act of 1933.
I also represent that Post-Effective Amendment No. 1 to the above referenced
Registration Statement does not appear to contain disclosures which would render
it ineligible to become effective pursuant to paragraph (b) of Rule 485 under
the 1933 Act, as amended.
Very truly yours,
/s/ Edwin L. Kerr
---------------------------------------
Edwin L. Kerr, Counsel
PHL Variable Insurance Company
Dated November 20, 2000
