April 20, 2009

Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

Re: PHL Variable Insurance Company
    Post-Effective Amendment No. 7 on Form S-1
    File No. 333-87218

Ladies and Gentlemen:

On behalf of PHL Variable Insurance Company ("PHLVIC"), transmitted herewith is
a registration statement on Form S-1 under the Securities Act of 1933, as
amended ("Securities Act").

PHLVIC is filing this registration statement to update financial information
and to make other non-material and conforming changes.

We request that the Registration Statement be accelerated to May 1, 2009 and
have included an acceleration request pursuant to Rule 461 of the Securities
Act of 1933.

The Registrant acknowledges that:

   .   should the Commission or the staff, acting pursuant to delegated
       authority, declare the filing effective, it does not foreclose the
       Commission from taking any action with respect to the filing;

   .   the action of the Commission or the staff, acting pursuant to delegated
       authority, in declaring the filing effective, does not relieve the
       registrant from its full responsibility for the adequacy and accuracy of
       the disclosure in the filing; and

   .   the Registrant may not assert this action as a defense in any proceeding
       initiated by the Commission or any person under the federal securities
       laws of the United States.

Please direct any questions or comments concerning this amendment to the
undersigned at 860-403-6625.

Sincerely,

/s/ Kathleen A. McGah
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Kathleen A. McGah, Esq.
Vice President and Assistant Secretary
PHL Variable Insurance Company