June 11, 2019

David Hutchens
President and Chief Executive Officer
Tucson Electric Power Company
88 E. Broadway Boulevard
Tucson, Arizona, 85701

       Re: Tucson Electric Power Company
           Registration Statement on Form S-3
           Filed June 6, 2019
           File No. 333-231982

Dear Mr. Hutchens:

       This is to advise you that we have not reviewed and will not review your
registration
statement.

        Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you
that the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

       Please contact Scott M. Anderegg at 202-551-3342 with any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Consumer
Products