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BRANDON J. CAGE

Pacific Life Insurance Company

Assistant Vice President

Managing Associate General Counsel

Office of General Counsel

Phone: 949-219-3943

Fax: 949-219-3706

Brandon.Cage@pacificlife.com

August 26, 2022

Yoon Choo

Senior Counsel

Office of Insurance Products

Division of Investment Management

U.S. Securities & Exchange Commission

100 F Street, NE

Washington, DC 20549-0506

   Re: Separate Account A of Pacific Life Insurance Company (File No. 811-08946)

Initial Registration Statement on Form N-4

Pacific Life Retirement Growth and Income Annuity (File No. 333-265390)

Separate Account A of Pacific Life & Annuity Company
(811-09203)

Initial Registration Statement on Form N-4

Pacific Life Retirement Growth and Income Annuity (File No. 333-265389)

Dear Ms. Choo:

On behalf of Pacific Life Insurance Company (“PLIC”) and
Separate Account A of Pacific Life (811-08946), Pacific Life & Annuity Company (“PLAC”), and Separate Account A of
PLA (811-09203) (hereinafter referred to as “Registrants”), set forth below are responses to Staff comments received on August 1,
2022, in connection with the above referenced Initial Registration Statements (filed on June 3, 2022) on Form N-4. All disclosure
changes include in this response will be made to all registration statements referenced above, as applicable, be pre-effective amendment.

GENERAL

 1. Staff Comment: Our comments are made with respect to the PLIC Registration Statement and reference page numbers
in that Registration Statement. Unless otherwise specified, please apply these comments, to the extent applicable, to the parallel disclosure
in the PLAC Registration Statement.

Response: Duly noted and will carry over any applicable
comments to the PLAC Registration Statement.

 2. Staff Comment: Please confirm that all missing information will be filed in pre-effective

Yoon Choo

August 26, 2022

Page 2 of 13

amendments to the Registration Statements.
We may have additional comments on such portions when you complete them in the pre-effective amendments, on disclosures made in response
to this letter, on information supplied supplementally, or on exhibits filed in the pre-effective amendments.

Response: We hereby confirm that any missing information
will be included and filed via a pre-effective amendment to this Registration Statement.

 3. Staff Comment: Where a comment is made with regard to disclosure in one location of the Registration Statement, it is
applicable to all similar disclosure appearing elsewhere in the Registration Statement. Please ensure that corresponding changes are made
to all similar disclosure.

Response: Duly noted.

 4. Staff Comment: Please clarify supplementally whether there are any guarantees or support agreements with third parties
to support any policy features or benefits, or whether the Company will be solely responsible for any benefits or features associated
with the Policy issued by the Separate Account.

Response:
Other than reinsurance contracts, we hereby confirm that there are no third-party support agreements; the Company is primarily responsible
for paying out any guarantees associated with the Policies.

PROSPECTUS

General

 5. Staff Comment:  The Contract offers one living benefit rider and one death benefit rider, which must be purchased
with the Contract, and one Variable Investment Option. We note, however, that the Registration Statement uses defined terms and includes
disclosure that suggests that multiple benefit riders and Funds are available. The Registration Statement also includes disclosure that
is not relevant to the Contract (e.g., disclosure on investment allocations). Please revise the Registration Statement so that
the disclosure is tailored to the specific features of the Contract being offered (i.e., a single, mandatory living benefit rider,
death benefit rider and Fund). In this regard, please revise disclosure that suggests that investors have a choice with respect to any
of these Contract features. We have provided specific comments to Important Information You Should Consider About the Contract as
examples of the type of changes to be made.

Response: We made modifications that are more tailored to
this product design.

 6. Staff Comment: The formatting makes the disclosure difficult to follow and to quickly locate information. Please make
formatting changes to make it easier for investors to navigate the document (e.g., spaces between sections and subsections, rather
than presenting without breaks, and adding semi-colons between section references in the table under Important Information You Should
Consider About the Contract).

Yoon Choo

August 26, 2022

Page 3 of 13

Response: Duly noted. We will make changes to make it easier
to navigate the document.

Cover page

 7. Staff Comment: The disclosure states that the “primary benefit” of the [GMWB] rider is “guaranteeing
withdrawals.” Here and in the first paragraph under Overview of the Contract, please disclose the following with respect
to the rider:

 a. The rider focuses on providing an income stream through withdrawals during the accumulation phase, beginning at age 59½, if
certain conditions are met; and

 b. because the rider must be purchased with the Contract, the Contract is designed for owners who intend to take regular withdrawals
each year after the qualifying age and that an investor should not purchase the Contract if he or she does not intend to take regular
withdrawals or intends to take withdrawals in excess of the GLWB rider’s annual withdrawal limits as doing so may result in adverse
consequences such as a permanent reduction in rider benefits or termination of the rider.

Response: We added the following disclosure to the cover
page:

“The guaranteed minimum withdrawal benefit rider focuses
on providing an income stream through withdrawals during the accumulation phase, beginning at age 59½, if certain conditions are
met. This Contract is designed for Owners who intend to take withdrawals each year after reaching age 59½ . An Owner should not
purchase this Contract if the Owner intends to take regular withdrawals in excess of the rider annual withdrawal amount or does not intend
to take any regular withdrawals. Withdrawals in excess of the rider annual withdrawal amount may result in adverse consequences such as
a permanent reduction in rider benefits or termination of the rider.”

 8. Staff Comment: Please add a statement that Purchase Payment(s) must be invested in
the single Fund identified in the Prospectus.

Response:
We added the following disclosure “Purchase Payment(s) must be invested in the available Investment Option. For California
applicants age 60 or older, see the STATE CONSIDERATIONS and APPENDIX: FUNDS AVAILABLE UNDER THE CONTRACT sections
for allocation options during the free look period.”

Special Terms

 9. Staff Comment: Please address the following comments:

 a. Remove the term Variable Account Value (there is no distinction for purposes of this Contract);

 b. Remove the term Investment Option or Variable Investment Option (there is no distinction for purposes of this Contract); and

 c. Remove the term Investment or Purchase Payment (identical definitions).

Response: For sub “a” above, we respectfully
decline to make the requested modification since it does have an impact on how certain charges under the rider are assessed – separate
account level against variable account value (ME&A charges, death benefit rider charges)

Yoon Choo

August 26, 2022

Page 4 of 13

or at the contract level (living benefit rider charges).
For sub “b”, we removed the reference to Variable Investment Option throughout and kept “Investment Option”. For
sub “c” above, we removed the term “Investment”.

Important Information You Should Consider About the
Policy

 10. Staff Comment: Please supplementally confirm that the key information table cross-references in the electronic versions
of the summary and statutory Prospectuses will link directly to the location in the statutory Prospectus where the subject matter is discussed
in greater detail, or will provide a means of facilitating access to that information through equivalent methods or technologies. [Instruction
1(b) to Item 2.]

Response: We confirm that we will comply with the requirements
of the above referenced instruction.

 11. Staff Comment: Under Ongoing Fees and Expenses (annual charges), please address the following comments:

 a. Tailor the introduction to reflect that the Contract does not permit an investor to choose Investment Options or benefit riders; and

 b. In the third footnote, revise “a living benefit” and “a death benefit” to “the living benefit”
and “the death benefit,” respectively.

Response: We made the requested modifications.

 12. Staff Comment: Under Risks – Risks Associated with Investment Option, please address the following comments:

 a. revise the disclosure to make clear that a single Investment Option is offered; and

 b. add a statement to the effect that since only one Investment Option is available, if an investor is not satisfied with the Fund or
it does not meet their investment objectives, there only option may be to surrender the Contract ( and forego any of its benefits).

Response: We made the requested modifications.

 13. Staff Comment: Under Restrictions – Investments, please remove “currently” from the first sentence,
change “A Fund” in the second sentence to “The Fund,” and change “Funds” to “the Fund in the
third sentenced.

Response: We made the requested modification.

 14. Staff Comment: Under Restrictions – Investments please add that if the Fund is substituted with another
Fund, the substitute Fund will have a similar investment objective, investment strategy, and fees and expenses.

Response: We made the requested modification.

Yoon Choo

August 26, 2022

Page 5 of 13

 15. Staff Comment: Under Rider Benefits, please address the following comments:

 a. remove the second sentence under the Restrictions column; and

 b. if accurate, replace the last sentence under the Restrictions column, and the fourth sentence under Withdrawals –
Optional Withdrawals – Amount Available for Withdrawal, with the following:

Taking a withdrawal before the youngest Designated Life is
59 ½, during the ten year period when an annual credit may be applied, or a withdrawal that is greater than the annual withdrawal
amount under the living benefit rider may result in adverse consequences such as a permanent reduction in rider benefits, the failure
to receive lifetime withdrawals under the rider, or termination of the rider. Taking a withdrawal may reduce the benefits provided by
the death benefit rider.

Response: We removed the sentence referred to in sub “a”
above and made the following change based on sub “b” above:

“Taking a withdrawal before age 59½ or a withdrawal
that is greater than the annual withdrawal amount (“excess withdrawal”) under the living benefit rider may result in adverse
consequences such as a permanent reduction in rider benefits, the failure to receive lifetime withdrawals under the rider, or termination
of the rider. Taking a withdrawal (excluding an Emergency Withdrawal) during the ten-year period when an annual credit may be applied,
will discontinue any future annual credits. Taking a withdrawal may reduce the benefits provided by the death benefit rider.”

We left out the reference to Designated Life or youngest
Designated Life given the context; the most important part is the age of 59½ and with the cross reference to the living benefit
rider section, the owner can see a full explanation of the Designated Life or Lives as it applies to withdrawals.

 16. Staff Comment: Under Tax Implications, please add a cross reference to “Principal Risks of Investment in the
Contract – Tax Consequences.”

Response: We made the requested modification.

Overview of the Contract

Phases of the Contract

 17. Staff Comment: Before the fourth sentence of the paragraph, please add a statement to explain that the Purchase Payment(s) is
invested in the Fund.

Response: We modified the last sentence of the first paragraph
as follows [new disclosure underlined for your reference]:

“Purchase Payments made will be invested in the Fund
and the Fund has its own investment objectives, strategies, risks, and expenses.”

Death Benefits

Yoon Choo

August 26, 2022

Page 6 of 13

 18. Staff Comment: Because an investor must purchase the Return of Purchase Payment Death Benefit (Return of Purchase Payments
Death Benefit II for California) rider, the death benefit under the rider is, in effect, the standard death benefit. In light of this,
please address the following comments.

 a. delete the first two sentences of the Death Benefits paragraph.
In addition, please revise the third sentence to explain that the death benefit under the rider is the greater of Contract Value or the
total of all Purchase Payments adjusted for withdrawals;

 b. delete the standard benefits section of Benefits Available Under the Contract; and

 c. under Death Benefits and Death Benefit Riders – Death Benefits –
Death Benefit Amount, revise the first sentence to explain that the death benefit under the rider is the greater of Contract
Value or the total of all Purchase Payments adjusted for withdrawals.

Response: We made the requested modification in sub “a”
and “b” above. For sub “c”, since the death benefit provided under the Contract is through the death benefit rider,
we added the disclosure requested and also included a cross reference to the death benefit rider disclosure which is in the same prospectus
section.

Principal Risks of Investment in the Contract

 19. Staff Comment: Under Withdrawal Risk, please add “or terminate the benefits associated with the rider” to
the end of the last sentence.

Response: We made the requested modification.

How Your Purchase Payments Are Allocated

 20. Staff Comment: This section reads as though investors may choose among multiple Investment Options. Please revise this
section, including the subsection headings, to make clear that there is only one Investment Option under the Contract and investors have
no choice on allocation.

Response: We made modifications to provide clarity. We also
added cross references language to address California applicants that are seniors and have the option to allocate their purchase payment
to the money market investment option during the free look period. We have not made a final determination on the investment options available,
but the money market will be a 1940 Investment Company Act registered mutual fund.

Benefits Available Under the Contract

 21. Staff Comment: In the Brief Description of Restriction/Limitations column for the [GMWB] rider, please add “or
when the Contract Value is reduced to zero” to the end of the last bullet point.

Yoon Choo

August 26, 2022

Page 7 of 13

Response: We respectfully decline to make the requested
change. It would make the bullet point incorrect.

Charges, Fees and Deductions

Withdrawal Charge—How the Withdrawal Charge is
Determined

 22. Staff Comment: The disclosure states that the Company will “calculate your withdrawal charge by assuming your
withdrawal is applied to Purchase Payments in the order your Purchase Payments were received …” Please disclose how Earnings
on the Contract are counted for purposes of calculating the withdrawal charge. If Earnings are disregarded for purposes of calculating
the Withdrawal Charge, please supplementally explain why this is appropriate.

Response: This product is designed and priced to impose
any withdrawal charges on a Purchase Payment first-in, first-out basis, excluding earnings. To provide clarity, we added additional disclosure
that earnings are not taken into account when determining the withdrawal charge for this product. We have latitude in how the withdrawal
charges are determined in our product design and is not a ques