Exhibit 8

                                Actuarial Consent





                                                                   July 22, 2002


Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

To the SEC Staff:

This opinion is furnished in connection with the registration of flexible
premium variable life insurance policies ("Policies") under the Securities Act
of 1933. The prospectus included in the Registration Statement on Form S-6 (SEC
File No. 333-76778) describes the Policies. The forms of Policies were prepared
under my direction, and I am familiar with the Registration Statement and
Exhibits thereto.

I certify that the fees and charges deducted under the Policies, in the
aggregate, are reasonable in relation to the services rendered the expenses to
be incurred, and the risks assumed by PHL Variable Insurance Company. In my
opinion, the illustrations of death benefits and cash values included in the
exhibits to the Registration, based on the assumptions stated in those
illustrations, are consistent with the provisions of the respective forms of the
Policies.

I hereby consent to the use of this opinion as an exhibit to the Registration
Statement.

                                        Very truly yours,


                                        /s/ Stuart Kwassman
                                        -------------------
                                        Stuart Kwassman, FSA, MAAA, CLU