Report of Independent Registered Public
Accounting Firm

To the Board of Trustees and Shareowners of
Pioneer Variable Contracts Trust
In planning and performing our audit of the
financial statements of the portfolios identified
in Appendix A, eighteen of the portfolios
constituting the Pioneer Variable Contracts
Trust (the Company), as of and for the year
ended December 31, 2008, in accordance
with the standards of the Public Company
Accounting Oversight Board (United States),
we considered the Company's internal control
over financial reporting, including controls
over safeguarding securities, as a basis for
designing our auditing procedures for the
purpose of expressing our opinion on the
financial statements and to comply with the
requirements of Form N-SAR, but not for the
purpose of expressing an opinion on the
effectiveness of the Company's  internal
control over financial reporting. Accordingly,
we express no such opinion.
The management of the Company is
responsible for establishing and maintaining
effective internal control over financial
reporting. In fulfilling this responsibility,
estimates and judgments by management are
required to assess the expected benefits and
related costs of controls. A company's internal
control over financial reporting is a process
designed to provide reasonable assurance
regarding the reliability of financial reporting
and the preparation of financial statements for
external purposes in accordance with
generally accepted accounting principles. A
company's internal control over financial
reporting includes those policies and
procedures that (1) pertain to the
maintenance of records that, in reasonable
detail, accurately and fairly reflect the
transactions and dispositions of the assets of
the company; (2) provide reasonable
assurance that transactions are recorded as
necessary to permit preparation of financial
statements in accordance with generally
accepted accounting principles, and that
receipts and expenditures of the company are
being made only in accordance with
authorizations of management and directors
of the company; and (3) provide reasonable
assurance regarding prevention or timely
detection of unauthorized acquisition, use or
disposition of a company's assets that could
have a material effect on the financial
statements.
Because of its inherent limitations, internal
control over financial reporting may not
prevent or detect misstatements. Also,
projections of any evaluation of effectiveness
to future periods are subject to the risk that
controls may become inadequate because of
changes in conditions, or that the degree of
compliance with the policies or procedures
may deteriorate.
A deficiency in internal control over financial
reporting exists when the design or operation
of a control does not allow management or
employees, in the normal course of
performing their assigned functions, to
prevent or detect misstatements on a timely
basis. A material weakness is a deficiency, or
a combination of deficiencies, in internal
control over financial reporting, such that
there is a reasonable possibility that a
material misstatement of the company's
annual or interim financial statements will not
be prevented or detected on a timely basis.
Our consideration of the Company's internal
control over financial reporting was for the
limited purpose described in the first
paragraph and would not necessarily disclose
all deficiencies in internal control that might
be material weaknesses under standards
established by the Public Company
Accounting Oversight Board (United States).
However, we noted no deficiencies in the
Company's internal control over financial
reporting and its operation, including controls
over safeguarding securities, that we consider
to be a material weakness as defined above
as of December 31, 2008.
This report is intended solely for the
information and use of management and the
Board of Trustees of Pioneer Variable
Contracts Trust and the Securities and
Exchange Commission and is not intended to
be and should not be used by anyone other
than these specified parties.


Ernst & Young LLP

Boston, Massachusetts
February 6, 2009


Appendix A

Pioneer Variable Contracts Trust

1)	Pioneer Bond VCT Portfolio
2)	Pioneer Cullen Value VCT Portfolio
3)	Pioneer Emerging Markets VCT
Portfolio
4)	Pioneer Equity Income VCT Portfolio
5)	Pioneer Fund VCT Portfolio
6)	Pioneer Global High Yield VCT
Portfolio
7)	Pioneer Growth Opportunities VCT
Portfolio
8)	Pioneer High Yield VCT Portfolio
9)	Pioneer Ibbotson Aggressive
Allocation VCT Portfolio
10)	Pioneer Ibbotson Growth Allocation
VCT Portfolio
11)	Pioneer Ibbotson Moderate Allocation
VCT Portfolio
12)	Pioneer Independence VCT Portfolio
13)	Pioneer International Value VCT
Portfolio
14)	Pioneer Money Market VCT Portfolio
15)	Pioneer Mid Cap Value VCT Portfolio
16)	Pioneer Oak Ridge Large Cap VCT
Portfolio
17)	Pioneer Small Cap Value VCT
Portfolio
18)	Pioneer Strategic Income VCT
Portfolio