Exhibit 8

             [Letterhead of Ballard Spahr Andrews & Ingersoll, LLP]

                                                   May 30, 2003

PSEG Power LLC
80 Park Plaza
P.O. Box 1171
Newark, NJ  07101

Ladies and Gentlemen:

      We have acted as tax counsel to you (the  "Company"),  in connection  with
the  preparation  of a  Registration  Statement  on  Form  S-3  relating  to the
registration of Preferred Securities to be issued by PSEG Power Capital Trust I,
PSEG Power  Capital  Trust II, PSEG Power  Capital Trust III, PSEG Power Capital
Trust IV and PSEG Power  Capital  Trust V  (collectively,  the "Trusts") and the
related Guarantee Agreements and Deferrable Interest Subordinated  Debentures of
the Company.

      We  are  familiar  with  the  proceedings  to  date  with  respect  to the
Registration  Statement and have examined such records,  documents and questions
of  law,  and  satisfied  ourselves  as to  such  matters  of  fact,  as we have
considered relevant and necessary as a basis for this opinion.  In addition,  we
have assumed that there will be no change in the laws  currently  applicable  to
the Company  and the Trusts and that such laws will be the only laws  applicable
to the Company and the Trusts.

      Based upon and subject to the  foregoing,  the statements set forth in the
Prospectus   included  in  the   Registration   Statement   under  the  headings
"Description of the Preferred  Securities - Certain United States Federal Income
Tax  Consequences," to the extent they constitute  matters of federal income tax
law or legal conclusions with respect thereto, represent our opinion.

      In giving the foregoing  opinion,  we express no opinion as to the laws of
any jurisdiction other than the law of the United States of America.

      This opinion letter is limited to the matters stated herein and no opinion
is implied or may be inferred beyond the matters  expressly stated herein.  This
opinion  is  rendered  as of the  date  hereof  based  on the law and  facts  in
existence on the date hereof, and we do not undertake,  and hereby disclaim, any
obligation to advise you of any changes in law or fact, whether or not material,
which may be brought to our attention at a later date.

      We hereby  consent to the filing of this opinion with the  Securities  and
Exchange Commission as Exhibit 8 to the Registration  Statement. We also consent
to the use of our name  under the  heading  "Legal  Matters"  in the  Prospectus
included in the Registration Statement. In giving this consent, we do not hereby
admit that we are within the category of persons whose consent is required under
Section 7 of the Securities Act of 1933, as amended, or the rules or regulations
of the Commission promulgated thereunder.

                                      Very truly yours,

                                      /s/ Ballard Spahr Andrews & Ingersoll, LLP