EXHIBIT 7

                 [PROTECTIVE LIFE INSURANCE COMPANY LETTERHEAD]

                   STATEMENT OF OPINION REGARDING ASPECTS OF
          PROTECTIVE LIFE INSURANCE COMPANY FILING OF A LAST SURVIVOR
           FLEXIBLE PREMIUM VARIABLE AND FIXED LIFE INSURANCE POLICY
                     (FILE NUMBERS 333-31944 AND 811-7337)

In my capacity as Actuary for Protective Life Insurance Company, I have provided
actuarial advice concerning (a) the Registration Statement describing the offer
and sale of the above captioned flexible premium variable life insurance
policies ("Policies") and (b) policy forms for the Policies.

It is my professional opinion that:

    (1) The illustrations of policy values, surrender values, death benefits and
       accumulated premiums in the prospectus contained in the Registration
       Statement are based on the assumptions stated in the illustrations, and
       are consistent with the provisions of the Policies. The rate structure of
       the policies have not been designed so as to make the relationship
       between premiums and benefits, as shown in the illustrations, appear to
       be more favorable to prospective non-smoker purchasers of Policies at age
       45 than to prospective purchasers of Policies, for males or females,
       smokers or non-smokers, at other issue ages.

    (2) The information contained in the examples set forth in Appendix A of the
       prospectus covering death benefit calculations is based on the
       assumptions stated in the examples, and is consistent with the provisions
       of the Policies.

I hereby consent to the filing of this opinion as an exhibit to Pre-Effective
Amendment No. 1 to the Registration Statement and to the use of my name under
the heading "Experts" in the prospectus.


                                             
                                                /s/ STEPHEN PEEPLES
                                                -------------------------------------------
                                                Stephen Peeples, F.S.A., M.A.A.A.
                                                Protective Life Insurance Company Actuary
                                                and 2nd Vice President


May 24, 2000