Exhibit 8



                                Christy & Viener
                               Rockefeller Center
                                620 Fifth Avenue
                            New York, New York 10020



                                February 5, 1997




Southwestern Electric Power Company
SWEPCO Capital I
428 Travis Street
Shreveport, Louisiana  71156-0001

Ladies and Gentlemen:

          We have acted as special tax counsel to you in connection with the
proposed offering by SWEPCO Capital I, a Delaware statutory business trust (the
"Trust"), of its Trust Preferred Securities, Series A (the "Series A Preferred
Securities"), as described in the Registration Statement on Form S-3 (the
"Registration Statement"), which is being filed by Southwestern Electric Power
Company, a Delaware corporation (the "Company"), the Trust, and SWEPCO Capital
II, a Delaware statutory business trust, with the Securities and Exchange
Commission pursuant to the Securities Act of 1933, as amended. The Registration
Statement includes the Prospectus and the Prospectus Supplement (collectively,
the "Prospectuses") relating to such offering.

          In rendering the opinion expressed below, we have examined the
Prospectuses and such other documents as we have deemed relevant and necessary,
including, without limitation, the Trust Agreement dated as of January 29, 1997,
the Form of the Amended and Restated Trust Agreement, the Form of the Indenture,
the Form of the First Supplemental Indenture, and the Form of the Guarantee
Agreement attached as Exhibits to the Registration Statement. Such opinion is
conditioned, among other things, upon the accuracy and completeness of the
facts, information, and representations contained in the Prospectuses as of the
date hereof and the continuing accuracy and completeness thereof as of the date
of the issuance of the Series A Preferred Securities. We have not undertaken any
independent investigation of any factual matters set forth in the Prospectuses
or such other documents. We have assumed that the transactions contemplated by
the Prospectuses and such other documents will occur as provided therein and
that there will be no material change to the Prospectuses or any of such other
documents between the date hereof and the date of the issuance of the Series A
Preferred Securities.

          Based upon and subject to the foregoing, we are of the opinion that
the discussion set forth in the Prospectus Supplement under the caption "CERTAIN
FEDERAL INCOME TAX CONSIDERATIONS" is a fair and accurate summary of the matters
addressed therein, based upon current law and the assumptions stated or referred
to therein.

          We assume no obligation to update or supplement this letter to reflect
any facts or circumstances which may hereafter come to our attention with
respect to the opinion expressed above, including any changes in applicable law
which may hereafter occur.

          We hereby consent to the filing of this letter as an Exhibit to the
Registration Statement and to the references to our firm under the captions
"CERTAIN FEDERAL INCOME TAX CONSIDERATIONS" and "LEGAL OPINIONS" in the
Prospectus Supplement.

                              Very truly yours,
                              /s/ Christy & Viener