Diane N. Ledger, CLU
Vice President
Variable Regulatory Compliance
Law Department
(949) 219-3743 Telephone
(949) 219-6952 Facsimile
dledger@pacificlife.com

December 14, 2004

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

RE: Pacific Odyssey
Individual flexible premium deferred variable annuity contracts
Post-Effective Amendment No. 14, File No. 333-53040
Separate Account A (File Number 811-08946) of Pacific Life Insurance Company

Dear Sir or Madam:

On behalf of Pacific Life Insurance Company (“Pacific Life”) and Separate Account A (“Separate Account”) of Pacific Life, enclosed for electronic filing under the Securities Act of 1933 (“1933 Act”) is Post-Effective Amendment No. 14 to the Registration Statement on Form N-4. This Registration Statement relates to a variable annuity contract designated as the Pacific Odyssey individual flexible premium deferred variable annuity contract, which is funded by the Separate Account.

This Post-Effective Amendment is being filed in reliance on Rule 485 (a)(1) under the 1933 Act, and nothing in this filing would make it ineligible to be filed pursuant to paragraph (a) of Rule 485. This Post-Effective Amendment shall become effective on December 30, 2004, or as soon thereafter as practicable.

No fees are required in connection with this filing.

The purpose of this Post-Effective Amendment is to: (1) provide disclosure regarding the Portfolio Optimization service; (2) add additional disclosure pursuant to Staff comments received on November 29, 2004; and (3) bring information up to date pursuant to Section 10(a)(3) of the 1933 Act.

If you have any questions or comments with respect to this filing, please contact me at the number listed above, or Ruth Epstein, Esq., of Dechert LLP at (202) 261-3322.

Very truly yours,

/s/ Diane N. Ledger

Diane N. Ledger

cc:          R. Epstein, Esq. (Dechert LLP)