April 27, 2023

VIA EDGAR

Securities and Exchange Commission

450 Fifth Street, NW

Washington, DC 20549

RE:    Principal Life Insurance Company

    Variable Life Separate Account

    Principal Variable Universal Life Income

    Post-Effective Amendment No. 20 to Registration Statement on Form N-6

    File No. 333-115269

I am Counsel for the above-referenced Registrant. I have reviewed the attached post-effective amendment filed pursuant to Rule 485(b) under the Securities Act of 1933 and hereby represent that the amendment does not contain disclosures that would render it ineligible to become effective pursuant to Rule 485(b).

Sincerely,

/s/ Doug Hodgson

Doug Hodgson

Counsel

515-362-2384

Hodgson.Doug@principal.com