Exhibit 8(b)


                            (Letterhead of Norton Rose)

22nd December, 1999


TXU Europe Capital I
TXU Europe Funding I, L.P.
Energy Plaza
1601 Bryan Street
Dallas, Texas  75201

TXU Europe Limited
TXU Eastern Funding Company
The Adelphi
1-11 John Adam Street
London, England WC2N 6HT

Ladies and Gentlemen:

          We have acted as English legal advisers to TXU Europe Limited, a
private limited company incorporated under the laws of England and Wales
(Company), TXU Eastern Funding Company, a private unlimited company incorporated
under the laws of England and Wales (Funding), TXU Europe Funding I, L.P., a
Delaware limited partnership (Partnership) and TXU Europe Capital I, a Delaware
statutory business trust (Trust), in connection with the preparation and filing
by the Company, Funding, the Partnership and the Trust with the Securities and
Exchange Commission of a Registration Statement on Form S-1 (Registration
Statement) under the Securities Act of 1933, as amended, with respect to (i) the
preferred trust securities (Preferred Trust Securities) to be issued by the
Trust, (ii) the guarantee to be issued by the Company to The Bank of New York,
as trustee, for the benefit of the holders of the Preferred Trust Securities,
(iii) the  preferred partnership securities (Preferred Partnership Securities)
to be issued by the Partnership, (iv) the guarantee to be issued by the Company
to The Bank of New York, as trustee, for the benefit of holders of the Preferred
Partnership Securities, (v) the junior subordinated debentures (Funding
Debentures) to be issued by Funding pursuant to an indenture (Funding
Indenture), (vi) the guarantee to be issued by the Company to The Bank of New
York, as trustee, for the benefit of the holders of Funding Debentures
pursuant to the terms of the Funding Indenture, and (vii) the guarantees to be
issued by the Company to The Bank of New York, as trustee, for the benefit of
the holders of junior subordinated debentures to be issued by one or more of the
Company's eligible subsidiaries, each pursuant to the terms of one or more
indentures, each substantially in the form filed as exhibits to the Registration
Statement.

          Our opinion is based upon facts described in the Registration
Statement and upon facts represented to us or determined by us as of the date
hereof.  Our opinion is also based upon existing United Kingdom law, practice
and judicial and administrative precedent, all of which are subject to change
either prospectively or retroactively.




          Based upon the foregoing, it is our opinion that the summary of
current law and practice in the United Kingdom relating to taxation of interest
on the subsidiary debentures as set out under the heading MATERIAL INCOME TAX
CONSIDERATIONS - "UK Tax Considerations" is a summary of current United
Kingdom tax consequences in respect of such interest for those holders of
Preferred Trust Securities to whom that summary relates.  We express no opinion
on the two statements of intention on the part of the partnership (a) as to the
collection of interest on the subsidiary debentures from a paying agent in New
York or Luxembourg, and (b) as to its not appointing a UK collecting agent in
respect of that interest.



                                                Yours faithfully,

                                                /s/ Norton Rose

                                                NORTON ROSE



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