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Lindsay Thorpe, Counsel

Protective Life Insurance Company

Writer’s Direct Number: (205) 898-7409

Facsimile Number: (205) 268-3597

Toll-Free Number: (800) 627-0220

E-mail: lindsay.thorpe@protective.com

August 16, 2024

Via EDGAR and E-mail

Ms. Alison White

Senior Counsel

Disclosure Review Office 2

Division of Investment Management

U.S. Securities and Exchange Commission

100 F. Street, N.E.

Washington, D.C. 20549

    Re:
    Protective Life Insurance Company

    Protective Variable Annuity Separate Account 811-08108

    Post-Effective Amendment No. 11 to the Registration Statement
    on Form N-4

    File Nos. 333-237747 & 811-08108

Ms. White:

On behalf of Protective Life
Insurance Company (the “Company”) and on behalf of Protective Variable Annuity Separate Account (the “Account”),
we have filed this letter as correspondence via EDGAR to the above referenced Post-Effective Amendment No. 11 to the Form N-4
Registration Statement (the “Amendment”) for certain flexible premium deferred variable and fixed annuity contracts (the
 “Contracts”). This letter provides the Company’s responses to comments received from the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) on August 7, 2024.

For the Staff’s convenience,
each Staff comment is set forth in full below, followed by the Company’s response. Where page numbers are referenced, they
are consistent with the marked to show copy provided to the Staff.

PROSPECTUS (Protective Investors Benefit Advisory
Variable Annuity 333-237747)

 1. Staff
                                            Comment: Please disclose all material financial intermediary variations, in the Prospectus.

Response:
We will add a new appendix to the prospectus that disclosures all material financial intermediary variations (if any) consistent
with the Staff’s comment, subject to

2801
US-280 • Birmingham, AL 35223   |   (205) 268-1000   |   protective.com

Ms. White

August 16,2024

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any subsequent Commission or Staff
guidance that otherwise applies to us, when we file the post-effective amendment for annual updates, effective May 1, 2025.

 2. Staff
                                            Comment: DEATH BENEFIT – Important Considerations for Choosing a Death Benefit
                                            (p. 39). Please confirm supplementally that the only material differences between the maximum
                                            value death benefits are the frequency of calculations and the current fees.

Response:
We supplementally confirm that the maximum value death benefit riders do not differ in the form and function beyond the frequence of
calculation and the fee.

 3. Staff
                                            Comment: Rate Sheet Prospectus Supplement Information (p. 45). Clarify the maximum
                                            withdrawal percentages are for the SecurePay rider. Add the words “SecurePay rider”
                                            after “Max Withdrawal Percentages” in the first sentence.

Response:
We made the requested modification.

RATE SHEET PROSPECTUS SUPPLEMENT (Protective
Investors Benefit Advisory Variable Annuity 333-237747)

 4. Staff
                                            Comment: In the preamble to the “OPTIONAL DEATH BENEFIT FEES” section,
                                            references “three” optional death benefits, please change that to read “four”
                                            optional death benefit are available.

Response:
We made the requested modification.

 5. Staff
                                            Comment: Clarify that Maximum Withdrawal Percentage relates to the SecurePay percentage.

Response:
We made the requested modification.

* * * * *

We believe that the foregoing
responds to all Commission Staff comments. We respectfully request that the Staff review these materials as soon as possible.

If you have any questions
regarding this letter, please contact me at 205-898-7409. We greatly appreciate the Staff's efforts in assisting the Company with this
filing.

    Sincerely,

    /s/ Lindsay Thorpe

    Lindsay Thorpe

    Counsel

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