Exhibit 8


                              Dewey Ballantine LLP
                           1301 Avenue of the Americas
                            New York, New York 10019


                                                                 June 14, 2001


Consolidated Edison Company of
  New York, Inc.
4 Irving Place
New York, New York 10003

            Re:  Registration Statement on Form S-3

Dear Sirs:

            We have acted as special tax counsel to Consolidated Edison Company
of New York, Inc. (the "Company") in connection with the issuance of $400
million aggregate principal amount of the Company's 7.50% Public Income Notes
(7.50% Debentures, Series 2001 A) due 2041 ("PINES"). We have participated in
the preparation of the Registration Statement on Form S-3 relating to the
Company's debt securities (No. 333-61008), which was declared effective on May
24, 2001, and the Prospectus Supplement, dated today, relating to the PINES (the
"Prospectus Supplement"). The PINES will be issued pursuant to the Indenture,
dated as of December 1, 1990, between the Company and the Chase Manhattan Bank,
as Trustee, as amended and supplemented by the First Supplemental Indenture,
dated as of March 6, 1996, in the form filed as an exhibit to the Registration
Statement.

            On the basis and subject to the accuracy of the statements contained
in the materials referred to above, and our consideration of such other matters
as we have deemed necessary, it is our opinion that under current law the
material federal income tax consequences to holders of PINES will be as
described under the heading "Material Federal Income Tax Consequences" in the
Prospectus Supplement. You have not requested, and we do not express, an opinion
concerning any other tax consequences of the issuance of the PINES. This opinion
is not to be used, circulated, quoted or otherwise referred to for any purpose
without our express written permission.

            We hereby consent to this opinion being incorporated by reference
into the Registration Statement and to the references to our firm in the section
captioned "Material Federal Income Tax Consequences" in the Prospectus
Supplement. In giving the foregoing consent, we do not thereby admit that we
come within the category of persons whose consent is required under Section 7 of
the Securities Act of 1933 or the rules and regulations of the Securities and
Exchange Commission thereunder.


                                Very truly yours,


                                /s/ Dewey Ballantine LLP