Exhibit 8.1


                                                     May 1, 1998


Yorkshire Power Group Limited
Wetherby Road, Scarcroft
Leeds LS14 3HS, England

Yorkshire Power Finance Limited
Wetherby Road, Scarcroft
Leeds LS14 3HS, England

     Re:  Registration Statement on Form S-1
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Ladies and Gentlemen:

     We are acting as United States counsel to Yorkshire Power Group Limited and
Yorkshire Power Finance Limited in connection with the preparation of a
Registration Statement on Form S-1, including a preliminary prospectus, filed
with the Securities and Exchange Commission (the "Commission") on March 13, 1998
(the "Registration Statement").

     We hereby confirm our opinion that the statements as to matters of law and
legal conclusions set forth under the caption "Certain Income Tax Considerations
- - US Federal Income Tax Considerations" in the preliminary prospectus included
in the Registration Statement are correct in all material respects.

     We hereby consent to the filing of this opinion with the Commission as an
exhibit to the Registration Statement and to the use of our name under the
heading "Certain Income Tax Considerations - US Federal Income Tax
Considerations" in the preliminary prospectus forming part of the Registration
Statement. In giving the foregoing consent, we do not hereby admit that we come
within the category of persons whose consent is required under Section 7 of the
Securities Act of 1933, as amended, or the rules and regulations of the
Commission thereunder.

                                            Very truly yours,


                                            DEWEY BALLANTINE LLP