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BRANDON J. CAGE

Vice President and Managing Counsel

Writer’s Direct Number: (205) 268-1889

Facsimile Number: (205) 268-3597

Toll-Free Number: (800) 627-0220

E-mail: brandon.cage@protective.com

December 8, 2023

Via EDGAR and E-mail

Ms. Rebecca Ament Marquigny

Senior Counsel

Disclosure Review Office 2

SEC 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 Life Separate Account

    Post-Effective Amendment No. 4 (PIBA VUL
    333-267465; 811-08537)

    Post-Effective Amendment No. 13 (SOVUL II
    333-232740; 811-08537)

    to the Registration Statements on Form N-6

Ms. Marquigny:

On behalf of Protective Life
Insurance Company (the “Company”) and on behalf of Protective Variable Life Separate Account (the “Registrant”),
we have filed this letter as correspondence via EDGAR to the above referenced Post-Effective Amendments to the Form N-6 Registration
Statements (the “Amendments”) for certain flexible premium variable and fixed life insurance policies (the “Policies”).
This letter provides the Company’s responses to comments received from the staff (the “Staff”) of the Securities and
Exchange Commission (the “Commission”) on December 5, 2023, regarding the above referenced Amendments which were filed
with the Commission on October 20, 2023.

For the Staff’s convenience,
each Staff comment is set forth in full below, followed by the Company’s response. All responses apply to both Registration Statements
unless otherwise noted below.

SUPPLEMENTS

Charges and Deductions

 1. Staff
                                            Comment: Cost of Insurance Rates – First Paragraph. Are the references to the
                                            2017 Commissioners’ Standard Ordinary Mortality Tables the correct tables? If the amendment

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

Ms. Marquigny

December 8, 2023

Page 2

is due to a change in the cost of insurance
rates as for February 1, 2024, are the new rates based on new mortality tables? Please explain supplementally, and if appropriate,
revise the disclosure to clarify.

Response:
The 2017 CSO tables referenced in the disclosure are correct and the current CSO tables available. The fee changes disclosed
in this supplement are not a result of new or updated CSO tables, just a change in costs starting February 1, 2024.

 2. Staff
                                            Comment: Monthly Administrative Fees – First Paragraph. Please clarify what
                                            you mean by “for the first 10 Policy Years on a current basis” and distinguish
                                            between current and guaranteed charges. In addition, if the per $1,000 per Initial Face Amount
                                            fee for policies purchased after February 1, 2024, is otherwise reduced for higher Initial
                                            Face Amount policies please state so.

Response:
We modified the sentence which now states the following [new disclosure underlined for your reference only]:

“We also deduct a monthly administrative
charge for the Initial Face Amount which is equal to a fee per $1,000 of Initial Face Amount per month while the Policy is in effect
on a guaranteed basis (only imposed for the first 10 Policy Years on a current basis).

The Face Amount is one of many factors
(e.g. age, sex, rate classification) that impact the rate that may be imposed. It could be considered misleading to state that
there is any type of correlation between higher Face Amounts and reduced fees.

 3. Staff
                                            Comment: Monthly Administrative Fees – First Paragraph. Consider inserting
                                            the word “current” between “the” and “monthly” so that
                                            it reads that “the current monthly administrative charge…” if correct
                                            to do so.

Response:
We made the requested modification.

PART C

 4. Staff
                                            Comment: Page C-7 Legal Opinion. Please clarify if item (k) Legal Opinion
                                            is a heading or needs to include a legal opinion exhibit.

Response:
We hereby confirm and clarify that the (k) Legal Opinion reference is a heading. Any required legal opinion appears
below that heading.

 5. Staff
                                            Comment: Item 32 – First Paragraph. Please consider adding the prospectus location
                                            to this paragraph where the relevant section can be found in the prospectus.

Response:
We will take that into consideration during the next annual update process.

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Ms. Marquigny

December 8, 2023

Page 3

Initial Summary Prospectus

 6. Staff
                                            Comment: Please confirm that a) there are no changes to the Initial Summary Prospectus
                                            document itself, and b) confirm that all necessary fee updates have been incorporated into
                                            the Initial Summary Prospectus supplements immediately preceding this document.

Response:
We hereby confirm that there are no changes to the Initial Summary Prospectus itself and that all fee changes have been
incorporated into the Initial Summary Prospectus supplements that appear before the actual Initial Summary Prospectus included as an
exhibit to the Registration Statement.

 7. Staff
                                            Comment: Fee Table – Periodic Charges Other Than Fund Operating Expenses –
                                            Administrative Charge. For the updated costs, the reference to “during the first 10
                                            Policy Years” was moved to the amount deducted column in the supplement. For consistency,
                                            you should describe them the same way in this section the next time this document is updated.

Response:
The disclosure in the Initial Summary Prospectus dated May 1, 2023 (as amended September 1, 2023) is accurate
and will not be modified to move the reference to the amount deducted column. When the Initial Summary Prospectus is updated completely
(e.g. May 1, 2024), this section will be modified to include disclosure so it is clear that the disclosure applies to Policies
with an application signed before February 1, 2024. New rows from the supplement will be integrated into this section and will be
clear which rates apply before and after February 1, 2024. No changes will be made at this time.

 8. Staff
                                            Comment: Fee Table – Periodic Charges Other Than Fund Operating Expenses –
                                            Administrative Charge For Face Amount Increases. Please confirm that this charge is not also
                                            now based, in part, on the Face Amount.

Response:
We hereby confirm that there are no changes to how this charge is calculated. This charge is not impacted by the supplement
and was left out by design.

SUPPLEMENT

SO VUL II Only

 9. Staff
                                            Comment: Administrative Charge. If correct, consider clarifying that the Administrative
                                            Charge is discontinued after the Policy has been in effect for 10 years. If not, please explain
                                            that language more clearly.

Response:
To provide come clarity we added “and discontinued thereafter” to this section of the table. We also made
the same change to the PIBA VUL product supplement as it has the same fee disclosure.

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Ms. Marquigny

December 8, 2023

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* * * * *

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 205-268-1889. We greatly appreciate the Staff's efforts in assisting the Company with this
filing.

    Sincerely,

    /s/ Brandon J. Cage

    Brandon J. Cage

    Vice President and Managing Counsel

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