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: steve_callaway@protective.com 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