February 9, 2009

VIA EDGARLINK

Securities and Exchange Commission

450 Fifth Street, NW

Washington, DC 20549

RE:	Protective Life Insurance Company
	Pre-Effective Amendment for
	Registration Statement on Form S-1 for
	Modified Guaranteed Annuity Contracts
	File No.  333-156285

Commissioners:

Pursuant to Rule 461 under the Securities Act of 1933, the Registrant referenced above hereby requests that the effective date of the above-captioned registration statement filed on Form S-1 be accelerated to February 13, 2009 or as soon thereafter as is reasonably practicable.

Protective Life Insurance Company
By:	/s/ John D. Johns
Name:	John D. Johns
Title:	Chairman of the Board, Chief Executive Officer and President

INVESTMENT DISTRIBUTORS, INC.

2801 Highway 280 South · Birmingham, AL · 35223 · (205)268-1000

February 9, 2009

VIA EDGARLINK

Securities and Exchange Commission

450 Fifth Street, NW

Washington, DC 20549

RE:	Protective Life Insurance Company
	Pre-Effective Amendment No. 1 for
	Registration Statement on Form S-1 for
	Modified Guaranteed Annuity Contracts
	File No.  333-156285

Commissioners:

Pursuant to Rule 461 under the Securities Act of 1933, Investment Distributors, Inc., as principal underwriter, hereby joins in a request by the above referenced Registrant that the effective date of the above-captioned registration statement filed on Form S-1 be accelerated to February 13, 2009 or as soon thereafter as is reasonably practicable.

Investment Distributors, Inc.
By:	/s/ Edwin V. Caldwell II
Name:	Edwin V. Caldwell, II
Title:	President and Secretary