EXHIBIT 7

   
                 [PROTECTIVE LIFE INSURANCE COMPANY LETTERHEAD]
    
 
   
                   STATEMENT OF OPINION REGARDING ASPECTS OF
           PROTECTIVE LIFE INSURANCE COMPANY FILING OF AN INDIVIDUAL
           FLEXIBLE PREMIUM VARIABLE AND FIXED LIFE INSURANCE POLICY
                     (FILE NUMBERS 333-52215 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 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.
                                          Actuary and 2nd Vice President
                                          Protective Life Insurance Company
 
   
July 8, 1998