EXHIBIT 8



                                October 4, 2002




Kinder Morgan, Inc.
One Allen Center, Suite 1000
500 Dallas Street
Houston, Texas 77002

Ladies and Gentlemen:

We have acted as counsel to Kinder Morgan, Inc. (the "Company"), a Kansas
corporation, in connection with the offer by the Company to exchange up to
$750,000,000 aggregate principal amount of its 6.50% Exchange Senior Notes due
2012 (the "Exchange Notes") for its 6.50% Senior Notes due 2012 (the "Original
Notes") (said offer being referred to herein as the "Exchange Offer"). The
Exchange Notes and the Original Notes are referred to herein collectively as the
"Notes." The Company has filed with the Securities and Exchange Commission (the
"Commission") a registration statement on Form S-4 with respect to the Exchange
Offer (the "Registration Statement"), under the Securities Act of 1933, as
amended (the "Securities Act").

We have examined originals or copies of the Registration Statement and such
other documents and records as we have deemed necessary and relevant for the
purposes hereof. In addition, we have relied on certificates of officers of the
Company, and of public officials and others as to certain matters of fact
relating to this opinion and have made such investigations of law as we have
deemed necessary and relevant as a basis hereof. In such examination, we have
assumed the genuineness of all signatures, the authenticity of all documents and
records submitted to us as copies, the conformity to authentic original
documents and records of all documents and records submitted to us as copies,
and the truthfulness of all statements of fact contained therein.

On the basis of the foregoing and upon consideration of applicable law, we are
of the opinion that, subject to the qualifications stated therein, the
discussion as to the United States federal income tax matters set forth under
the caption "Material Federal Income Tax Considerations" in the Prospectus
contained in the Registration Statement summarizes the material United States
federal income tax consequences relevant to the Exchange Offer and to the
purchase, ownership and disposition of the Notes.

We hereby consent to the filing of this opinion with the Commission as Exhibit 8
to the Registration Statement and to the references to our firm under the
heading "Material Federal Income Tax Considerations" in the Prospectus included
in the Registration Statement. By giving such consent, we do not admit that we
are experts with respect to any part of the Registration Statement, including
this Exhibit, within the meaning of the term "expert" as used in the Securities
Act or the rules and regulations thereunder.

                                             Very truly yours,


                                             /s/ Bracewell & Patterson, L.L.P.

                                             Bracewell & Patterson, L.L.P.