Tucson Electric Power Company
88 East Broadway Boulevard
Tucson, AZ 85701
November 26, 2018
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Consumer Products
100 F Street, N.E.
Washington, D.C. 20549
Attention: Ms. Katherine Bagley
Re: | Tucson Electric Power Company |
| Registration Statement on FormS-1 |
Dear Ms. Bagley:
In accordance with Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), we hereby request acceleration of the effective date of the Registration Statement on FormS-1 (FileNo. 333-227356) (the “Registration Statement”) of Tucson Electric Power Company (the “Company”). We respectfully request that the Registration Statement become effective as of 1:00 p.m., Eastern time, on November 26, 2018, or as soon as practicable thereafter. Once the Registration Statement has been declared effective, please confirm that event with our counsel, Morgan, Lewis & Bockius LLP, by calling John T. Hood at (212)309-6281.
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