EXHIBIT 25(A)


                       SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C. 20549

                                -----------------


                                    FORM T-1

                    STATEMENT OF ELIGIBILITY UNDER THE TRUST
                     INDENTURE ACT OF 1939 OF A CORPORATION
                          DESIGNATED TO ACT AS TRUSTEE

              CHECK IF AN APPLICATION TO DETERMINE ELIGIBILITY OF A
               TRUSTEE PURSUANT TO SECTION 305(b)(2)
                                                     ------------

                                -----------------

                              THE BANK OF NEW YORK
               (Exact name of trustee as specified in its charter)


          New York                                              13-5160382
(Jurisdiction of incorporation                               (I.R.S. Employer
 if not a U.S. national bank)                               Identification No.)

One Wall Street, New York, New York                                10286
(Address of principal executive offices)                        (Zip code)

                                -----------------

                              MINNESOTA POWER, INC.
               (Exact name of obligor as specified in its charter)


           Minnesota                                            41-0418150
 (State or other jurisdiction                                (I.R.S. Employer
of incorporation or organization)                           Identification No.)

   30 West Superior Street
      Duluth, Minnesota                                            55802
(Address of principal executive offices)                         (Zip code)

                                -----------------

                              FIRST MORTGAGE BONDS*
                       (Title of the indenture securities)


- ------------------------
     *Specific title(s) to be determined in connection with sale(s) of First
Mortgage Bonds.





ITEM 1.   GENERAL INFORMATION.*

          Furnish the following information as to the Trustee:

     (a)  Name and address of each examining or supervising authority to which
          it is subject.

Superintendent of Banks of the            2 Rector Street, New York, N.Y. 10006
  State of New York                         and Albany, N.Y. 12203
Federal Reserve Bank of New York          33 Liberty Plaza, New York, N.Y. 10045
Federal Deposit Insurance Corporation     550 17th Street, N.W., Washington,
New York Clearing House Association         D.C. 20429
                                          New York, N.Y. 10005

     (b)  Whether it is authorized to exercise corporate trust powers.

          Yes.

ITEM 2.   AFFILIATIONS WITH OBLIGOR.

          If the obligor is an affiliate of the trustee, describe each such
affiliation.

          None. (See Note on page 2.)

ITEM 16.  LIST OF EXHIBITS.

          Exhibits identified in parentheses below, on file with the Commission,
are incorporated herein by reference as an exhibit hereto, pursuant to Rule
7a-29 under the Trust Indenture Act of 1939 (the "Act") and 17 C.F.R.
ss.229.10(d).

          1.   -    A copy of the Organization Certificate of The Bank of New
                    York (formerly Irving Trust Company) as now in effect, which
                    contains the authority to commence business and a grant of
                    powers to exercise corporate trust powers. (Exhibit 1 to
                    Amendment No. 1 to Form T-1 filed with Registration
                    Statement No. 33-6215, Exhibits 1a and 1b to Form T-1 filed
                    with Registration Statement No. 33-21672 and Exhibit 1 to
                    Form T-1 filed with Registration Statement No. 33-29637.)

          4.   -    A copy of the existing By-laws of the Trustee. (Exhibit 4
                    to Form T-1 filed with Registration Statement No. 33-31019.)

          6.   -    The consent of the Trustee required by Section 321(b) of
                    the Act. (Exhibit 6 to Form T-1 filed with Registration
                    Statement No. 33-44051.)

          7.   -    A copy of the latest report of condition of the Trustee
                    published pursuant to law or to the requirements of its
                    supervising or examining authority.


- ------------------------
     *Pursuant to General Instruction B, the Trustee has responded only to Items
1, 2 and 16 of this form since to the best of the knowledge of the Trustee the
obligor is not in default under any indenture under which the Trustee is a
trustee.





                                      NOTE

          Inasmuch as this Form T-1 is being filed prior to the ascertainment by
the Trustee of all facts on which to base a responsive answer to Item 2, the
answer to said Item is based on incomplete information.

          Item 2 may, however, be considered as correct unless amended by an
amendment to this Form T-1.

                                    SIGNATURE

          Pursuant to the requirements of the Act, the Trustee, The Bank of New
York, a corporation organized and existing under the laws of the State of New
York, has duly caused this statement of eligibility to be signed on its behalf
by the undersigned, thereunto duly authorized, all in The City of New York, and
State of New York, on the 18th day of July, 2000.

                                        THE BANK OF NEW YORK

                                        By:  STEPHEN J. GIURLANDO
                                           ------------------------------------
                                             Stephen J. Giurlando
                                             Vice President


                                      -2-



                                                                       EXHIBIT 7
                                                                   (Page 1 of 3)

                       Consolidated Report of Condition of
                              THE BANK OF NEW YORK
                    of One Wall Street, New York, N.Y. 10286
     And Foreign and Domestic Subsidiaries, a member of the Federal Reserve
System, at the close of business March 31, 2000, published in accordance with a
call made by the Federal Reserve Bank of this District pursuant to the
provisions of the Federal Reserve Act.

                                                                 Dollar Amounts
ASSETS                                                            In Thousands
- ------                                                           --------------

Cash and balances due from
  depository institutions:
  Noninterest-bearing balances
    and currency and coin......................................     $ 3,843,465
  Interest-bearing balances....................................       5,718,219
Securities:
  Held-to-maturity securities..................................         821,842
  Available-for-sale securities................................       5,134,756
Federal funds sold and Securities
  purchased under agreements to resell.........................       2,498,315
Loans and lease financing
  receivables:
  Loans and leases, net of unearned
    income.....................................................      40,912,488
  LESS:  Allowance for loan and
    lease losses...............................................         580,924
  LESS: Allocated transfer risk
    reserve....................................................          12,597
  Loans and leases, net of unearned
    income, allowance, and reserve.............................      40,318,967
Trading Assets.................................................       8,658,971
Premises and fixed assets (including
  capitalized leases)..........................................         725,709
Other real estate owned........................................           7,309
Investments in unconsolidated subsid-
  iaries and associated companies..............................         225,206
Customers' liability to this bank on
  acceptances outstanding......................................         932,029
Intangible assets..............................................       1,273,011
Other assets...................................................       2,796,228
                                                                    ------------
Total assets...................................................     $72,954,027
                                                                    ============





                                                                       EXHIBIT 7
                                                                   (Page 2 of 3)

LIABILITIES
- -----------

Deposits:
  In domestic offices..........................................     $27,563,469
  Noninterest-bearing..........................................      12,099,757
  Interest-bearing.............................................      15,463,712
  In foreign offices, Edge and
  Agreement subsidiaries, and IBFs.............................      27,705,718
  Noninterest-bearing..........................................         849,483
  Interest-bearing.............................................      26,856,235
Federal funds purchased and Securities
  sold under agreements to repurchase .........................       1,560,406
Demand notes issued to the U.S.
  Treasury.....................................................          68,017
Trading liabilities............................................       2,708,747
Other borrowed money:
  With remaining maturity of one year or less..................       1,397,051
  With remaining maturity of more than
    one year through three years ..............................             351
  With remaining maturity of more than
    three years................................................          31,080
Bank's liability on acceptances
  executed and outstanding.....................................         932,905
Subordinated notes and debentures..............................       1,652,000
Other liabilities..............................................       3,511,774
                                                                    ------------
Total liabilities..............................................      67,131,518
                                                                    ------------


EQUITY CAPITAL
- --------------

Common stock...................................................       1,135,284
Surplus........................................................         866,947
Undivided profits and capital
  reserves.....................................................       3,894,578
Net unrealized holding gains (losses)
  on available-for-sale securities.............................         (46,911)
Cumulative foreign currency
  translation adjustments......................................         (27,389)
                                                                    ------------
Total equity capital...........................................       5,822,509
                                                                    ------------
Total liabilities and equity capital...........................     $72,954,027
                                                                    ============





                                                                       EXHIBIT 7
                                                                   (Page 3 of 3)

     I, Thomas J. Mastro, Senior Vice President and Comptroller of the
above-named bank do hereby declare that this Report of Condition has been
prepared in conformance with the instructions issued by the Board of Governors
of the Federal Reserve System and is true to the best of my knowledge and
belief.

                                        Thomas J. Mastro


     We, the undersigned directors, attest to the correctness of this Report of
Condition and declare that it has been examined by us and to the best of our
knowledge and belief has been prepared in conformance with the instructions
issued by the Board of Governors of the Federal Reserve System and is true and
correct.

     Thomas A. Renyi     )
     Gerald L. Hassell   )         Directors
     Alan R. Griffith    )