SecProbe.io

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                             Eaton Vance Management
                                255 State Street
                           Boston, Massachusetts 02109
                       Ph: 617-482-8260; Fx: 617-598-0432

April 22, 2005

VIA EDGAR

Alison T. White
U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Judiciary Plaza
Washington, DC  20549

     Re:  Eaton Vance Variable Trust (File Nos. 811-10067 and 333-44010)
          --------------------------------------------------------------

Dear Ms. White:

This letter  responds  to comments  provided  via email  correspondence  to Fred
Marius on April 5, 2005 and further  discussions with Maureen Gemma on April 20,
2005  for  the   registration   statement   for  Eaton  Vance   Variable   Trust
("Registrant").  Our  summaries of the comments  and our  responses  thereto are
provided below.

Attached is the  requested  Tandy  Letter  (Attachment  A) as well as the marked
pages  from the Eaton  Vance  Variable  Trust's  prospectus  and SAI  reflecting
certain changes made in response to the comments. A post-effective amendment for
the Registrant will be filed pursuant to Rule 485(b) under the Securities Act of
1933, as amended ("1933 Act"), with the U.S.  Securities and Exchange Commission
via the Edgar  filing  system  before  the  effective  date of the  registration
statement filed on February 25, 2005 pursuant to Rule 485(a) under the 1933 Act,
incorporating the responses highlighted below.

PROSPECTUS

Restrictions on Excessive Trading and Market Timing - Pages 10-11

1.   Comment: We note that you may cancel a purchase order when market timing is
     suspected.  Please  disclose  the time frame in which you may do so. If the
     time frame is  greater  than two days,  we will need to  consult  the front
     office of the Division of Investment Management.

     Response: Each Fund or its principal underwriter will immediately reject or
     cancel a purchase  order,  suspend or terminate  the exchange  privilege or
     terminate  the  ability of an  investor  to invest in the Eaton Vance funds
     when market  timing is  suspected.  Such  cancellation  normally will occur
     within two days of the time market  timing is  suspected by the Fund or its
     principal underwriter. In addition, please note that the current prospectus
<PAGE>
Ms. White
April 22, 2005
Page 2 of 2

     disclosure has been revised to more clearly  reflect the Funds' reliance on
     financial intermediaries to monitor for frequent, short-term trading within
     each Fund. Please see Attachment B.

2.   Comment: Because your policies are discretionary,  please state that you do
     not have uniformly applied policies in place to prevent market timing,  and
     that different shareholders may be treated differently.

     Response: The disclosure has been revised. Please see Attachment B.

STATEMENT OF ADDITIONAL INFORMATION

Portfolio Managers - Page 18

3.   Comment:  Please  note  that you will  need to  include  portfolio  manager
     compensation  information  pursuant to Item 15(b) of Form N-1A in your next
     filing.

     Response: The requested draft disclosure is attached. Please see Attachment
     C.

Disclosure of Portfolio Holdings - Page 23

4.   Comment:  Please  disclose the procedures that the Fund uses to ensure that
     disclosure  of  information  about  portfolio  securities  is in  the  best
     interests of Fund shareholders,  including  procedures to address conflicts
     between the interests of Fund  shareholders,  on the one hand, and those of
     the  Fund's  investment  adviser;  principal  underwriter;   or  any  other
     affiliated  person of the Fund,  its investment  adviser,  or its principal
     underwriter, on the other. See Item 11(f)(1)(vi) of Form N-1A.

     Response: The requested disclosure has been added. Please see Attachment D.

                                 * * * * * * * *

Should you have any questions or comments regarding this letter,  please contact
the undersigned at 617.598.8570.

Very truly yours,

/s/ Kathryn A. McElroy
----------------------
Kathryn A. McElroy

cc:  Linda Nishi
     Eaton Vance Management
<PAGE>
                                  ATTACHMENT A
<PAGE>
                             Eaton Vance Management
                                255 State Street
                           Boston, Massachusetts 02109
                       Ph: 617-482-8260; Fx: 617-598-0432

April 22, 2005

VIA ELECTRONIC EMAIL

Alison T. White
U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Judiciary Plaza
Washington, DC  20549

     Re:  Eaton Vance Variable Trust (File Nos. 811-10067 and 333-44010)

Dear Ms. White:

Eaton Vance Variable Trust  ("Registrant")  is responsible  for the adequacy and
accuracy of the disclosure in the filing.  Further,  the  Registrant  recognizes
that the staff comments,  or changes to disclosure in response to staff comments
in the filing  reviewed by the staff,  do not foreclose the U.S.  Securities and
Exchange  Commission  ("SEC") from taking any action with respect to the filing.
Lastly,  the Registrant  acknowledges that it may not assert staff comments as a
defense in any  proceeding  initiated by the SEC or any person under the federal
securities laws of the United States.

Please direct any questions or additional  comments you may have concerning this
letter to the undersigned at (617) 482-8260.

/s/ Maureen A. Gemma
--------------------
Maureen A. Gemma
Assistant Secretary
<PAGE>
                                  ATTACHMENT B
<PAGE>
RESTRICTIONS ON EXCESSIVE TRADING AND MARKET TIMING.  The Funds are not intended
for excessive trading or market timing.  Market timers seek to profit by rapidly
switching money into a fund when they expect the share price of the fund to rise
and  taking  money out of the fund when they  expect  those  prices to fall.  By
realizing profits through short-term trading,  shareholders that engage in rapid
purchases  and sales or  exchanges  of a fund's  shares  may dilute the value of
shares held by  long-term  shareholders.  Volatility  resulting  from  excessive
purchases  and sales or  exchanges of fund shares,  especially  involving  large
dollar  amounts,  may disrupt  efficient  portfolio  management.  In particular,
excessive  purchases  and sales or exchanges of a fund's shares may cause a fund
to have difficulty implementing its investment strategies, may force the fund to
sell  portfolio  securities  at  inopportune  times to raise  cash or may  cause
increased  expenses (such as increased  brokerage costs,  realization of taxable
capital  gains  without   attaining  any   investment   advantage  or  increased
administrative  costs). Shares of the Funds are offered for purchase by separate
accounts to serve as  investment  options for  variable  annuity  contracts  and
variable life  insurance  policies  ("Variable  Contracts")  issued by insurance
companies,  and as investment options for a qualified pension plan or retirement
plan. Shares of the Fund are primarily sold through financial intermediaries who
choose to hold shares through omnibus accounts

The Funds  rely on  financial  intermediaries  to monitor  frequent,  short-term
trading  within a Fund by the financial  intermediaries'  customers.  You should
review the materials provided by your financial intermediary  including,  in the
case of a Variable Contract, the prospectus that describes the contract, for its
policies regarding frequent,  short-term trading. The Funds seek assurances from
financial  intermediaries  that they have  procedures  adequate  to monitor  and
address frequent,  short-term trading. There is no guarantee that the procedures
of the  financial  intermediaries  will be able to identify  all cases of market
timing and excessive trading.

Because a Fund invests its assets in foreign  securities,  it may be susceptible
to a time  zone  arbitrage  strategy  in  which  shareholders  attempt  to  take
advantage  of Fund share prices that may not reflect  developments  in a foreign
securities  market  that occur  after the close of such  market but prior to the
pricing of Fund shares. In addition, a fund that invests in securities that are,
among other things,  thinly traded,  traded  infrequently or relatively illiquid
(including  certain  securities that may be held by a Fund, such as Senior Loans
and  restricted  securities ) is susceptible to the risk that the current market
price for such securities may not accurately  reflect  current market values.  A
shareholder may seek to engage in short-term  trading to take advantage of these
pricing differences  (commonly referred to as "price arbitrage").  Each Fund has
procedures  authorizing  the  investment  adviser  to use the  fair  value  of a
security if market prices are  unavailable  or deemed  unreliable  (see "Valuing
Shares").  The use of fair value pricing the  restrictions on excessive  trading
and market timing described below are intended to reduce a shareholder's ability
to engage in price or time zone arbitrage to the detriment of the Funds.

The Boards of  Trustees  of the Eaton  Vance  funds  have  adopted  policies  to
discourage  short-term  trading and market timing and to seek to minimize  their
potentially  detrimental  effects.  Pursuant to these  policies,  if an investor
(through  one or  more  accounts)  makes  more  than  two  round-trip  exchanges
(exchanging  from one fund to another fund and back again) within 12 months,  it
will be deemed to  constitute  market  timing or  excessive  trading.  Under the
policies,  each  Fund or its  principal  underwriter  will  reject  or  cancel a
purchase  order,  suspend or terminate  the exchange  privilege or terminate the
ability of an investor to invest in the Eaton Vance  funds,  including  purchase
orders that have been accepted by a financial  intermediary,  if the Fund or the
<PAGE>
principal  underwriter  determines that a proposed  transaction  involves market
timing or excessive  trading that it believes is likely to be detrimental to the
Fund.  Each Fund and its principal  underwriter  cannot ensure that they will be
able to identify all cases of market timing and excessive trading, although they
believe they have adequate procedures in place to attempt to do so. Each Fund or
its  principal  underwriter  may  also  reject  or  cancel  any  purchase  order
(including  an exchange)  from an investor or group of  investors  for any other
reason.  Decisions to reject or cancel purchase orders (including  exchanges) in
each Fund are inherently  subjective and will be made in a manner believed to be
in the best  interest of the Fund.  No Eaton Vance fund has any  arrangement  to
permit market timing.

The Funds and the  principal  underwriter  have  provided  guidance to financial
intermediaries   (such  as  banks,   broker-dealers,   insurance  companies  and
retirement  administrators) concerning the application of the Eaton Vance funds'
market  timing and  excessive  trading  policies  to Fund shares held in omnibus
accounts maintained and administered by such intermediaries,  including guidance
concerning  situations where market timing or excessive trading is considered to
be detrimental to a Fund. Each Fund and the principal  underwriter cannot ensure
that these financial  intermediaries will in all cases apply the policies of the
Funds to accounts under their control.
<PAGE>
                                  ATTACHMENT C
<PAGE>
PORTFOLIO MANAGERS.  The co-portfolio managers (each referred to as a "portfolio
manager")  of VT  Floating-Rate  Income  Fund are  Scott H.  Page and  Payson F.
Swaffield.  The members of the management  team of VT Worldwide  Health Sciences
Fund are Samuel D. Isaly, Sven H. Borho,  Richard D. Klemm,  Geoffrey C. Hsu and
Trevor M. Polischuk. Each portfolio manager or member of the management team may
manage other investment  companies and/or investment accounts in addition to the
Fund.  The following  tables show, as of the Fund's most recent fiscal year end,
the number of  accounts  each  portfolio  manager  managed in each of the listed
categories  and the total assets in the accounts  managed  within each category.
The table also shows the number of accounts  with  respect to which the advisory
fee is based on the performance of the account,  if any, and the total assets in
those accounts.

<TABLE>
<CAPTION>
                                                     Total         Number of      Total Assets of
                                       Number      Assets of    Accounts Paying   Accounts Paying
                                       of all         All        a Performance     a Performance
VT Floating-Rate Income Fund          Accounts     Accounts*           Fee              Fee*
----------------------------          --------     ---------    ---------------   ----------------
<C>                                       <C>      <C>                 <C>        <C>
     Scott H. Page
Registered Investment Companies           7        $14,683.2           0          $0
Other Pooled Investment Vehicles          5        $ 2,423.8           4          $1,536.6
Other Accounts                            4        $ 1,662.3           0          $0
     Payson F. Swaffield
Registered Investment Companies           7        $14,683.2           0          $0
Other Pooled Investment Vehicles          5        $ 2,423.8           4          $1,536.6
Other Accounts                            4        $ 1,662.3           0          $0

                                                     Total         Number of      Total Assets of
                                       Number      Assets of    Accounts Paying   Accounts Paying
                                       of all         All        a Performance     a Performance
VT Worldwide Health Sciences Fund     Accounts     Accounts*           Fee              Fee*
---------------------------------     --------     ---------    ---------------   ----------------
     Samuel D. Isaly
Registered Investment Companies            2       $2,648.6             0          $0
Other Pooled Investment Vehicles          25       $5,002.7            24          $4,805.7
Other Accounts                             0       $0                   0          $0
     Sven H. Borho
Registered Investment Companies            2       $2,648.6             0          $0
Other Pooled Investment Vehicles          25       $5,002.7            24          $4,805.7
Other Accounts                             0       $0                   0          $0
    Richard D. Klemm
Registered Investment Companies            2       $2,648.6             0          $0
Other Pooled Investment Vehicles          25       $5,002.7            24          $4,805.7
Other Accounts                             0       $0                   0          $0
<PAGE>
    Geoffrey C. Hsu
Registered Investment Companies            2       $2,648.6             0          $0
Other Pooled Investment Vehicles          25       $5,002.7            24          $4,805.7
Other Accounts                             0       $0                   0          $0
     Trevor M. Polischuk
Registered Investment Companies            2       $2,648.6             0          $0
Other Pooled Investment Vehicles          25       $5,002.7            24          $4,805.7
Other Accounts                             0       $0                   0          $0
</TABLE>

 *   In  millions  of  dollars.  For  registered  investment  companies,  assets
     represent net assets of all open-end investment  companies and gross assets
     of all closed-end investment companies.

The following  table shows the shares  beneficially  owned of the Fund as of the
Fund's most recent fiscal year ended December 31, 2004.

                                       Dollar