
October 6, 1995



Securities and Exchange Commission
450 Fifth Street NW
Washington, DC  20549

     Re:  $300,000,000 principal amount of
          First Mortgage Bonds of Northern
          States Power Company, a Minnesota
          corporation

Gentlemen:

I am participating in the proceedings incident to the issuance
and sale by Northern States Power Company, a Minnesota
corporation (the Company) of up to $300,000,000 principal amount
of First Mortgage Bonds, (the New Bonds).  I have examined all
statutes, records, instruments, and documents which I have
deemed necessary to examine for the purposes of this opinion.

Based upon the foregoing and upon my general familiarity with
the Company and its affairs, I am of the opinion that:

     1.   The Company was incorporated and is now a legal
          existing corporation under the laws of the state of
          Minnesota; has corporate power, right and authority to
          do business and to own property in the States of
          Minnesota, North Dakota and South Dakota in the manner
          and as set forth in the Registration Statement, Form
          S-3, to which this opinion is an exhibit; and has
          corporate power, right, and authority to create,
          issue, and sell the New Bonds.

     2.   When and if (a) the above mentioned Registration
          Statement has become effective pursuant to the
          provisions of the Securities Act of 1933, as amended;
          (b) the Minnesota Public Utilities Commission has
          issued its order approving Capital Structure which
          permits the Company to issue the New Bonds; (c) the
          Supplemental Trust Indenture relating to the New Bonds
          from the Company to Harris Trust and Savings Bank,
          Trustee, has been duly authorized, executed,
          delivered, filed and recorded as required by law; and
          (d) the New Bonds have been duly authorized, executed,
          authenticated, and delivered and the consideration for
          the New Bonds has been received by the Company, all in
          the manner contemplated by the said Registration
          Statement, the New Bonds will be legally issued and
          binding obligations of the Company and entitled to the
          benefits and security of the Company's Trust
          Indenture, dated February 1, 1937, as supplemented.

     3.   The statements made in the above mentioned
          Registration Statement and related Prospectus,
          purporting to be made or based upon the opinion of
          counsel, correctly set forth my opinion upon said
          matters.

Respectfully submitted,



(Gary R. Johnson)
Gary R. Johnson
Vice President and General Counsel

