EXHIBIT 2

                 [PROTECTIVE LIFE INSURANCE COMPANY LETTERHEAD]

Nancy Kane
Senior Associate Counsel

                                  May 24, 2000

Protective Life Insurance Company
2801 Highway 280 South
Birmingham, Alabama 35223

Gentlemen:

    With respect to the registration statement on Form S-6 to be filed by
Protective Life Insurance Company (the "Company") and Protective Variable Life
Separate Account (the "Account") with the Securities and Exchange Commission for
the purpose of registering under the Securities Act of 1933, as amended,
flexible premium fixed and variable life insurance policies (the "Policies"), I
have examined such documents and such law as I considered necessary and
appropriate, and on the basis of such examination, it is my opinion that:

    1.  The Company is a corporation duly organized and validly existing as a
       stock life insurance company under the laws of the State of Tennessee and
       is duly authorized by the Department of Commerce and Insurance of the
       State of Tennessee to issue the Policies.

    2.  The Account is a duly authorized and existing separate account
       established pursuant to the provisions of Section 56-3-501 of the
       Tennessee Code.

    3.  To the extent so provided under the Policies, that portion of the assets
       of the Account equal to the reserves and other contract liabilities with
       respect to the Account will not be chargeable with liabilities arising
       out of any other business that the Company may conduct.

    4.  The Policies, when issued as contemplated by the Form S-6 registration
       statement, will constitute legal, validly issued and binding obligations
       of the Company.

    I hereby consent to the filing of this opinion as an exhibit to the
Form S-6 registration statement for the Policies and the Account.

                                          Sincerely,
                                          /s/ Nancy Kane
                                          --------------------------------------
                                          Nancy Kane, Esq.