Exhibit 5.1


                               November 20, 1995





Arizona Public Service Company
400 North Fifth Street
Phoenix, Arizona  85004


Ladies and Gentlemen:

        Reference is made to (a) your proposed offering of up to $150,000,000 of
your Securities (the  "Securities"),  as contemplated by the combined prospectus
contained in the Registration  Statement (the "Registration  Statement") on Form
S-3 to be filed by you on November 20, 1995,  with the  Securities  and Exchange
Commission  under the  Securities  Act of 1933,  as amended (the  "Act"),  which
Securities  include (i)  $25,000,000 of either New Bonds or Debt  Securities (as
such  terms are  defined  in the  Registration  Statement),  or any  combination
thereof,  to  be  registered  pursuant  to  the  Registration  Statement,   (ii)
$25,000,000 of either New Bonds or Debt Securities  previously  registered under
Registration  No.  33-55473,  and (iii)  $100,000,000  of First  Mortgage  Bonds
previously registered under Registration No. 33-61228;  and (b) any registration
statement  registering  additional Securities pursuant to Rule 462(b) of the Act
that  relates  to the  Registration  Statement  (the "Rule  462(b)  Registration
Statement").

        We have examined originals or copies,  certified or otherwise identified
to  our  satisfaction,   of  such  corporate  records,   agreements,  and  other
instruments,   certificates,   orders,  opinions,   correspondence  with  public
officials, certificates provided by your officers and representatives, and other
documents as we have deemed  necessary or advisable  for the purposes of rending
the opinions set forth herein.

         Based  on  the  foregoing,  it  is  our  opinion  that  after  (i)  the
Registration   Statement,   and  the  Rule  462(b)  Registration  Statement,  if
applicable,  shall have become  effective,  and (ii) you shall have entered into
one or more underwriting agreements with the underwriters of the Securities then
to be  offered or the  representatives  of such  underwriters,  and you and such
underwriters or  representatives  shall have determined by agreement the initial
public  offering  price  for  each of  such  Securities  and  the  underwriters'
discounts  therefrom and commission  therefor,  pursuant to the authorization of
your Board of  Directors  and the  applicable  order of the Arizona  Corporation
Commission,  then,  when (i) the Securities  have been issued,  sold,  executed,
authenticated, and delivered, and (ii) the purchase price therefor has been paid
to you as  contemplated  in the  Registration  Statement,  and the  Rule  462(b)
Registration  Statement,  if applicable,  including  the Exhibits thereto and in
any relevant  amendment  thereto or in any Rule 424 supplement to the prospectus
contained in the Registration  Statement,  the Securities will be validly issued
and will constitute legal,  valid, and binding  obligations of you except as the
same may be  limited  by (a)  general  principles  of equity  or by  bankruptcy,
insolvency, reorganization,  arrangement, moratorium, or other laws or equitable
principles  relating  to or  affecting  the  enforcement  of  creditors'  rights
generally,  or  by  equitable  principles  that  limit  the  right  to  specific
performance  or  otherwise  limit  remedial  action  or the  enforcement  of the
security provided for the Securities,  (b) the necessity for compliance with the
statutory  procedural  requirements  governing  the  exercise  of  remedies by a
secured creditor,  and (c) the qualification  that certain waivers,  procedures,
remedies,  and other provisions of the Securities may be unenforceable  under or
limited by the law of the State of  Arizona;  however,  such law does not in our
opinion substantially prevent the practical realization of the benefits thereof.

        In giving the  foregoing  opinion,  we are  relying  upon the opinion of
Keleher &  McLeod,  P.A.,  your New  Mexico  counsel,  to the  effect  that your
activities  to date do not  constitute  you a "public  utility"  as that term is
defined  in  the  laws  of New  Mexico,  and  that,  accordingly,  no  approval,
authorization,  or consent of the New Mexico  Public  Service  Commission or any
other  public  board or body of the  State of New  Mexico  is  required  for the
issuance and sale of the Securities.

         Consent  is  hereby  given  to the use of this  opinion  as part of the
Registration   Statement,   and  the  Rule  462(b)  Registration  Statement,  if
applicable,  and to the use of our name wherever it appears in said Registration
Statement,  the related prospectus,  and the Rule 462(b) Registration Statement,
if applicable.

                                     Very truly yours,



                                    Snell & Wilmer L.L.P.