Exhibit 8



                                Christy & Viener
                               Rockefeller Center
                                620 Fifth Avenue
                            New York, New York 10020



                           April 11, 1997




Central Power and Light Company
CPL Capital I
539 North Carancahua Street
Corpus Christi, Texas  78401-2802

Ladies and Gentlemen:

           We have acted as special  tax  counsel to you in  connection
with the proposed offering by CPL Capital I, a Delaware statutory business trust
(the "Trust"), of its Cumulative Quarterly Income Preferred Securities, Series A
(the  "Series  A  Preferred  Securities"),  as  described  in  the  Registration
Statement on Form S-3, as amended by Amendment No. 1 thereto (the  "Registration
Statement"),  which is being filed by Central Power and Light  Company,  a Texas
corporation (the "Company"), the Trust, and CPL Capital II, a Delaware statutory
business  trust,  with the  Securities and Exchange  Commission  pursuant to the
Securities  Act of 1933, as amended.  The  Registration  Statement  includes the
Prospectus  and the Prospectus  Supplement  (collectively,  the  "Prospectuses")
relating to such offering.

          In  rendering  the  opinion  expressed  below,  we have  examined  the
Prospectuses  and such other documents as we have deemed relevant and necessary,
including, without limitation, the Trust Agreement dated as of January 23, 1997,
the Form of the Amended and Restated Trust Agreement, the Form of the Indenture,
the Form of the  First  Supplemental  Indenture,  and the Form of the  Guarantee
Agreement  attached as Exhibits to the Registration  Statement.  Such opinion is
conditioned,  among other  things,  upon the  accuracy and  completeness  of the
facts, information,  and representations contained in the Prospectuses as of the
date hereof and the continuing accuracy and completeness  thereof as of the date
of the issuance of the Series A Preferred Securities. We have not undertaken any
independent  investigation  of any factual matters set forth in the Prospectuses
or such other documents.  We have assumed that the transactions  contemplated by
the  Prospectuses  and such other  documents will occur as provided  therein and
that there will be no material  change to the  Prospectuses or any of such other
documents  between the date hereof and the date of the  issuance of the Series A
Preferred Securities.

          Based upon and subject to the  foregoing,  we are of the opinion  that
the discussion set forth in the Prospectus Supplement under the caption "CERTAIN
FEDERAL INCOME TAX CONSIDERATIONS" is a fair and accurate summary of the matters
addressed therein, based upon current law and the assumptions stated or referred
to therein.

          We assume no obligation to update or supplement this letter to reflect
any  facts or  circumstances  which may  hereafter  come to our  attention  with
respect to the opinion expressed above,  including any changes in applicable law
which may hereafter occur.

          We hereby  consent to the  filing of this  letter as an Exhibit to the
Registration  Statement  and to the  references  to our firm under the  captions
"CERTAIN  FEDERAL  INCOME  TAX  CONSIDERATIONS"  and  "LEGAL  OPINIONS"  in  the
Prospectus Supplement.

                                                     Very truly yours,
                                                     /s/ Christy & Viener