EXHIBIT 25.1

SECURITIES AND EXCHANGE COMMISSION

Washington, D. C. 20549

FORM T-1

STATEMENT OF ELIGIBILITY
UNDER THE TRUST INDENTURE ACT OF 1939 OF
A CORPORATION DESIGNATED TO ACT AS TRUSTEE

CHECK IF AN APPLICATION TO DETERMINE ELIGIBILITY OF
A TRUSTEE PURSUANT TO SECTION 305(b)(2)           

J. P. MORGAN TRUST COMPANY, NATIONAL ASSOCIATION
(Exact name of trustee as specified in its charter)

		95-4655078
(State of incorporation		(I.R.S. employer
if not a national bank)		identification No.)
1999 Avenue of the Stars – Floor 26
Los Angeles, CA		90067
(Address of principal executive offices)		(Zip Code)

William H. McDavid
General Counsel
270 Park Avenue
New York, New York 10017
Tel: (212) 270-2611
(Name, address and telephone number of agent for service)

PG&E Corporation
(Exact name of obligor as specified in its charter)

CALIFORNIA		94-3234914
(State or other jurisdiction of		(I.R.S. employer
incorporation or organization)		identification No.)
One Market, Spear Tower
Suite 2400
San Francisco, California		94105
(Address of principal executive offices)		(Zip Code)

6 7/8% Senior Secured Notes due 2008

Item 1.				General Information.
				Furnish the following information as to the trustee:
		(a)		Name and address of each examining or supervising authority to which it is subject.
				Comptroller of the Currency, Washington, D.C. Board of Governors of the Federal Reserve System, Washington, D.C.
		(b)		Whether it is authorized to exercise corporate trust powers.
				Yes.

Item 2.		Affiliations with Obligor.
		If the Obligor is an affiliate of the trustee, describe each such affiliation.
		None.

No responses are included for Items 3-15 of this Form T-1 because the Obligor is not in default as provided under Item 13.

Item 16. List of Exhibits.

     List below all exhibits filed as part of this statement of eligibility.

Exhibit 1.		Articles of Association of the Trustee as Now in Effect (see Exhibit 1 to Form T-1 filed in connection with Form 8K of the Southern California Water Company filing, dated December 7, 2001, which is incorporated by reference).
Exhibit 2.		Certificate of Authority of the Trustee to Commence Business (see Exhibit 2 to Form T-1 filed in connection with Registration Statement No. 333-41329, which is incorporated by reference).
Exhibit 3.		Authorization of the Trustee to Exercise Corporate Trust Powers (contained in Exhibit 2).
Exhibit 4.		Existing By-Laws of the Trustee (see Exhibit 4 to Form T-1 filed in connection with Form 8K of the Southern California Water Company filing, dated December 7, 2001, which is incorporated by reference).
Exhibit 5.		Not Applicable
Exhibit 6.		The consent of the Trustee required by Section 321 (b) of the Act (see Exhibit 6 to Form T-1 filed in connection with Registration Statement No. 333-41329, which is incorporated by reference).
Exhibit 7.		A copy of the latest report of condition of the Trustee, published pursuant to law or the requirements of its supervising or examining authority.
Exhibit 8.		Not Applicable

2

Exhibit 9. Not Applicable

3

SIGNATURE

     Pursuant to the requirements of the Trust Indenture Act of 1939, the Trustee, J. P. Morgan Trust Company, National Association, has duly caused this statement of eligibility and qualification to be signed on its behalf by the undersigned, thereunto duly authorized, all in the City of Los Angeles, and State of California, on the 13th day of April, 2004.

		J. P. Morgan Trust Company, National Association
		By		/s/ Janice Ott Rotunno
				Janice Ott Rotunno Authorized Officer

4

Exhibit 7

J. P. Morgan Trust Company, National Association
Statement of Condition

December 31, 2003

		($000)
Assets
Cash and Due From Banks		$	22,115
Securities			141,598
Loans and Leases			106,261
Premises and Fixed Assets			13,111
Intangible Assets			403,878
Goodwill			250,539
Other Assets			50,801
Total Assets		$	988,303
Liabilities
Deposits		$	119,625
Other Liabilities			112,490
Total Liabilities			232,115
Equity Capital
Common Stock			600
Surplus			701,587
Retained Earnings			54,001
Total Equity Capital			756,188
Total Liabilities and Equity Capital		$	988,303