CANADA LIFE OF AMERICA LETTERHEAD


March 4, 1999


Securities and Exchange Commission
Division of Investment Management
450 Fifth Street, N.W.
Washington, D.C. 20549

RE:  Canada Life of America Variable Annuity Account 1
     File Number:  333-71217
     CIK Number: 0000851066

Ladies and Gentlemen:

On behalf of Canada Life of America Variable Annuity Account 1, Canada Life 
Insurance Company of America (the "Company") hereby applies pursuant to Rule 477
under the Securities Act of 1933 for withdrawal of the registration statements 
filed on January 26, 1999 (File Number: 333-71217) (the "Registration 
Statements"). The Separate Accounts are registered as unit investment trusts 
under the Investment Company Act of 1940.

The Company's filing agent, R.R. Donnelley Financial inadvertently filed the
Registration Statements under the wrong CIK and CCC codes. Canada Life of
America Variable Annuity Account 1 (CIK: 0000851066) filed incorrectly under
codes for Canada Life of America Variable Annuity Account 2 (CIK:0000895360).
At the request of the Securities and Exchange Commission Division of Investment
Management, the Company is filing the Registration Withdrawal Requests for both
Registration Statements (File Number: 333-71217).

On the basis of all the foregoing, the Company submits that withdrawal of the
Registration Statements is consistent with the public interest and the
protection of investors.

Sincerely,

/s/ Elisabeth M. Grano
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Canada Life Insurance Company of America