EXHIBIT 8


                       WINTHROP, STIMSON, PUTNAM & ROBERTS
                             One Battery Park Plaza
                             New York, NY 10004-1490


                                                          


                                               June 15, 1998


Baltimore Gas and Electric Company
39 W. Lexington Street
Baltimore, Maryland  21201

BGE Capital Trust I
c/o Baltimore Gas and Electric Company
39 W. Lexington Street
Baltimore, Maryland  21201

   Re:  BGE Capital Trust I -- 7.16% Trust Originated Preferred Securities
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Ladies and Gentlemen:

                  As special tax counsel to Baltimore Gas and Electric  Company,
a Maryland  corporation  (the  "Company"),  and BGE Capital  Trust I, a Delaware
business  trust (the  "Issuer"),  we have  assisted  in the  preparation  of the
prospectus supplement (the "Prospectus Supplement") and the prospectus (together
with  the  Prospectus  Supplement,  the  "Prospectus")  that  form a part of the
registration statement on Form S-3 under the Securities Act of 1933 (the "Act"),
as  filed  with  the  Securities  and  Exchange  Commission  (the  "Registration
Statement"),  in  connection  with  the  proposed  offering  by  the  Issuer  of
10,000,000  of its 7.16%  Trust  Originated  Preferred  Securities  (liquidation
amount $25 per preferred security),  and the proposed issuance by the Company to
the Issuer of its 7.16% Deferrable  Interest  Subordinated  Debentures due 2038.
Unless otherwise  defined herein,  all terms used herein shall have the meanings
ascribed to them in the Prospectus.

                  We have  examined and relied upon the  Registration  Statement
and, in each case as filed as an exhibit to the Registration Statement,  (i) the
form of  Amended  and  Restated  Declaration  of Trust of the  Issuer  among the
Company, as Depositor,  and the several trustees named therein, (ii) the form of
Indenture  between  the  Company  and The  Bank of New  York,  as  Trustee  (the
"Trustee"),  (iii) the form of First Supplemental  Indenture between the Company
and the Trustee and (iv) the form of Guarantee Agreement between the Company and
The  Bank  of  New  York,  as  Preferred  Guarantee  Trustee  (the  "Transaction
Documents").

                  Based on the foregoing and on our  consideration of such other
information as we have deemed necessary and  appropriate,  we are of the opinion
that  (i)  under  current  law  and  based  on the  representations,  facts  and
assumptions  described in the Prospectus,  and assuming full compliance with the
terms of the Transaction Documents,  the Issuer will be characterized for United
States federal income tax purposes as a grantor trust and will not be taxable as
a corporation,  and (ii) the statements made in the Prospectus  Supplement under
the caption "United States  Taxation," to the extent they constitute  matters of
law or legal conclusions,  are accurate and correct in all material respects and
fairly present the information set forth therein.

                  We hereby  consent to the filing of this opinion as an exhibit
to the  Registration  Statement  and to the  references  to our firm  under  the
headings "Legal  Opinions" in the Prospectus and "United States Taxation" in the
Prospectus  Supplement.  In giving such consent, we do not thereby admit that we
are included in the category or persons whose consent is required  under Section
7 of the Act.

                                      Very truly yours,

                              /s/ Winthrop, Stimson, Putnam & Roberts