Exhibit 6

                                                                  April 24, 2002

The Prudential Insurance Company of America
Prudential Plaza
Newark, New Jersey 07102-3777

To Prudential:

This opinion is furnished in connection with the  registration by The Prudential
Insurance  Company of America of variable  appreciable life insurance  contracts
(the "Contracts")  under the Securities Act of 1933. The prospectus  included in
Post-Effective  Amendment No. 24 to the  Registration  Statement No. 33-20000 on
Form S-6 describes the  Contracts.  I have reviewed the two Contract forms and I
have  participated in the preparation and review of the  Registration  Statement
and Exhibits thereto. In my opinion:

     (1)  The illustrations of cash surrender values and death benefits included
          in the section of the prospectus entitled "Hypothetical  Illustrations
          of Death Benefits and Cash Surrender Values", based on the assumptions
          stated in the illustrations, are consistent with the provisions of the
          respective forms of the Contracts. The rate structure of the Contracts
          has not been designed so as to make the relationship  between premiums
          and benefits, as shown in the illustrations,  appear more favorable to
          a prospective purchaser of a Contract issued on a male age 35, than to
          prospective  purchasers  of  Contracts  on males  of other  ages or on
          females.

     (2)  The  deduction  in an  amount  equal  to 1.25%  of each  premium  is a
          reasonable  charge in  relation  to the  additional  income tax burden
          imposed upon The Prudential Insurance Company of America as the result
          of the  enactment  of Section 848 of the  Internal  Revenue  Code.  In
          reaching  that  conclusion a number of factors were taken into account
          that,  in  my  opinion,  were  appropriate  and  which  resulted  in a
          projected after-tax rate of return that is a reasonable rate to use in
          discounting  the tax benefit of the deductions  allowed in Section 848
          in taxable  years  subsequent  to the year in which the  premiums  are
          received.

I hereby  consent to the use of this  opinion as an exhibit to the  Registration
Statement  and to the  reference  to my name under the heading  "Experts" in the
prospectus.

Very truly yours,


/s/
-----------------------------------------------
Pamela A. Schiz, FSA, MAAA
Vice President and Actuary
The Prudential Insurance Company of America