December 14, 2004

U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549-0506

RE: Registration Statement for Pacific Odyssey (File No. 333-53040) funded by Separate Account A (File Number 811-08946) of Pacific Life Insurance Company, Request for Acceleration

Dear Sir or Madam:

Pursuant to Rule 461 under the Securities Act of 1933, we hereby request on behalf of Pacific Life Insurance Company (“Pacific Life”) and Pacific Select Distributors, Inc. (“PSD”), acceleration of the effective date of the above referenced Registration Statement to December 30, 2004, or as soon thereafter as practicable.

Pacific Life and PSD hereby acknowledge that should the Commission or the Staff, acting pursuant to delegated authority, declare the above referenced Registration Statement 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 Pacific Life or PSD from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and Pacific Life or PSD 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.

Sincerely, SEPARATE ACCOUNT A OF PACIFIC LIFE INSURANCE COMPANY
By:	/s/ Diane N. Ledger
	Diane N. Ledger
	Vice President
PACIFIC SELECT DISTRIBUTORS, INC.
By:	/s/ Ed Byrd
	Ed Byrd
	Vice President and Chief Financial Officer