EXHIBIT 10(a)
WRITTEN CONSENT OF
EDWIN L. KERR, ESQ
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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. 11 to the
Registration Statement on Form N-4 (File No. 33-87376) filed by PHL Variable
Accumulation Account with the Securities and Exchange Commission under the
Securities Act of 1933.
Very truly yours,
/s/ Edwin L. Kerr
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Edwin L. Kerr, Counsel
PHL Variable Insurance Company
Dated November 20, 2000
