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                                                                   Exhibit 8.1


                      ON LETTERHEAD OF SIDLEY AUSTIN LLP


                                  May 3, 2007


FPL Recovery Funding LLC
700 Universe Boulevard
Juno Beach, FL 33408-0420

Florida Power & Light Company
700 Universe Boulevard
Juno Beach, FL 33408-0420

Re: Storm-Recovery Bonds

Ladies and Gentlemen:

          We have acted as special counsel to Florida Power & Light Company
("FPL") and FPL Recovery Funding LLC, a Delaware limited liability company
(the "Company"), in connection with the preparation of the Registration
Statement filed on Form S-3 (the "Registration Statement") with the Securities
and Exchange Commission (the "Commission") under the Securities Act of 1933,
as amended (the "Securities Act"), relating to the proposed issuance of up to
$652,000,000 of Senior Secured Bonds, Series A (the "Storm-Recovery Bonds"),
of the Company to be offered as described in the form of the prospectus (the
"Prospectus") included as part of the Registration Statement. The
Storm-Recovery Bonds are to be issued under an Indenture (the "Indenture")
between the Company and The Bank of New York, as trustee.

          We are familiar with the proceedings taken and proposed to be taken
by the Company in connection with the proposed authorization, issuance and
sale of the Storm-Recovery Bonds. We have examined and relied upon originals,
or copies of originals, certified or otherwise identified to our satisfaction
of such records of the Company and such agreements, certificates of public
officials, certificates of officers or other representatives of the Company
and other instruments, and examined such questions of law and satisfied
ourselves to such matters of fact as we deemed relevant or necessary as a
basis for this letter. In rendering the opinions expressed in this letter, we
have assumed the legal capacity of all natural persons, the genuineness of all
signatures, the authenticity of all documents submitted to us as originals and



      Sidley Austin LLP is a limited liability partnership practicing in
              affiliation with other Sidley Austin partnerships





SIDLEY AUSTIN LLP
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SIDLEY


May 3, 2007
Page 2




the conformity with the original documents of any copies thereof submitted to
us for examination. As to any facts material to the opinions expressed herein
which we have not independently established or verified, we have relied upon
statements and representations of officers and other representatives of the
Company or others.

          Based upon the foregoing, it is our opinion that for U.S. federal
income tax purposes, (1) the Company will not be treated as a taxable entity
separate and apart from FPL and (2) the Storm-Recovery Bonds will be treated
as debt of FPL.

          Our opinion is limited to the United States federal income tax
matters specifically covered hereby, and we have not been asked to address,
nor have we addressed, any other tax consequences regarding the transaction
referred to above or any other transaction. This opinion is rendered as of the
date hereof based on the current provisions of the Internal Revenue Code and
the Treasury regulations issued or proposed thereunder, Revenue Rulings,
Revenue Procedures and other published releases of the Internal Revenue
Service and current case law, any of which can change at any time. Any change
could apply retroactively and modify the legal conclusions upon which our
opinions are based. This opinion is rendered as of the date hereof and we do
not undertake, and hereby disclaim, any obligation to advise you of any
changes in law or fact, whether or not material, which may be brought to our
attention at a later date.

          We are furnishing this opinion to you solely in connection with the
issuance of the Storm-Recovery Bonds described above, and this opinion is not
to be relied on, circulated, quoted or otherwise referred to for any other
purpose. However, we hereby consent to the filing of this opinion as an
exhibit to the Registration Statement and to the references to this Firm in
the Prospectus under the section captioned "Prospectus Summary - Federal
Income Tax Status", the Prospectus under the section captioned "Material U.S.
Federal Income Tax Consequences", the Prospectus under the section captioned
"Legal Matters", and the Prospectus Supplement under the section captioned
"Material U.S. Federal Income Tax Consequences". In giving such consent, we do
not thereby admit that we are within the category of persons whose consent is
required under Section 7 of the Securities Act, or the rules and regulations
of the Commission thereunder.

Very truly yours,

/s/ SIDLEY AUSTIN LLP
---------------------
    Sidley Austin LLP