EXHIBIT 5.1


                             KELEHER & MCLEOD, P.A.
                                    PO BOX AA
                              ALBUQUERQUE, NM 87103

June 12, 2003


Public Service Company of New Mexico
Alvarado Square
Albuquerque, New Mexico  87158

Ladies and Gentlemen:

         We are acting as counsel for Public Service Company of New Mexico, a
New Mexico corporation (the "Company"), in connection with the preparation and
filing with the Securities and Exchange Commission (the "Commission") on or
about the date hereof of a registration statement on Form S-3 (the "Registration
Statement") to register under the Securities Act of 1933, as amended (the
"Act"), $500,000,000 maximum aggregate offering price of senior unsecured notes
(the "Notes") to be issued under an indenture, dated as of August 1, 1998 (the
"Indenture"), which is filed as Exhibit 4.1 to the Registration Statement,
between the Company and JPMorgan Chase Bank, as trustee, and shares of the
Company's preferred stock (the "Preferred Stock").

         In our capacity as such counsel, we have either participated in the
preparation of or have reviewed and are familiar with the Registration Statement
and exhibits thereto, including the prospectus comprising a part thereof (the
"Prospectus"), and the Indenture. We have also reviewed such other documents and
have satisfied ourselves as to such other matters as we have deemed necessary in
order to render this opinion.

         Based upon the foregoing, and subject to the qualifications and
limitations stated herein, we are of the opinion that:

         1. With respect to the Preferred Stock, after (a) the Board of
Directors of the Company (the "Board") has taken all necessary corporate action
to approve the issuance and establish the terms of any particular series of
Preferred Stock, the offering thereof and related matters, including the filing
of a statement conforming to the New Mexico Business Corporation Act regarding
the Preferred Stock with the Public Regulation Commission of New Mexico ("PRC"),
(b) the Registration Statement has become effective and the securities or "blue
sky" laws of various states have been complied with, and (c) the PRC has
approved the issuance of the Preferred Stock and any other applicable regulatory
approvals have been obtained, then when shares of such series of Preferred Stock
have been issued and sold by the Company in the manner contemplated by the
Registration Statement and in any relevant amendment thereto or in any
supplement to the Prospectus and in accordance with such Board action, and the


consideration therefor has been received by the Company, such shares of such
series of Preferred Stock will be duly authorized, validly issued, fully paid
and nonassessable.

         2. With respect to the Notes, after (a) the Board has taken all
necessary corporate action to approve the issuance and establish the terms of
such Notes, the terms of the offering of the Notes and related matters, (b) the
Registration Statement has become effective and the securities or "blue sky"
laws of various states shall have been complied with, and (c) the PRC has
approved the issuance of the Notes and any other applicable regulatory approvals
have been obtained, then when (i) any supplemental indenture to the Indenture or
other instrument thereunder to be entered into, or otherwise executed or
adopted, in connection with the issuance of the Notes has been duly executed and
delivered by the Company and the trustee named therein, (ii) the Notes have been
duly executed, authenticated and delivered in accordance with the terms of the
Indenture, and (iii) the Notes have been issued and sold, and the purchase price
therefor has been paid to the Company, in the manner contemplated by the
Registration Statement and in any relevant amendment thereto or in any
supplement to the Prospectus and in accordance with the Indenture, the Notes
will be valid and legally binding obligations of the Company, enforceable
against the Company in accordance with their terms, and entitled to the benefits
of the Indenture, except as may be limited by applicable bankruptcy, insolvency,
reorganization, moratorium, fraudulent conveyance and similar laws affecting or
relating to the rights of creditors generally, by general principles of equity
(regardless of whether considered in a proceeding in equity or at law), and by
requirements of reasonableness, good faith and fair dealing.

         The foregoing is subject to no stop order with respect to the
Registration Statement having been issued by the Commission or any state
securities commission.

         We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and to the use of our name under the caption "Validity"
in the Prospectus. In giving such consent, we do not thereby admit that we are
within that category of persons whose consent is required under Section 7 of the
Act or the rules and regulations of the Commission thereunder.

         We are members of the bar of the State of New Mexico. The opinions
expressed herein are limited solely to the laws of the State of New Mexico and
the laws of the United States of America (except that we express no opinion as
to New Mexico securities or blue sky laws) and we express no opinion on the laws
of any other jurisdiction. We note that the Indenture is governed by and
construed in accordance with the law of the State of New York, without regard to
conflicts of laws principles thereof. We understand that Pillsbury Winthrop LLP,
special New York counsel to the Company, is delivering an opinion to you with
respect to matters of New York law. Insofar as this opinion relates to matters
which are governed by the laws of the State of New York, we have relied upon the
opinion of Pillsbury Winthrop LLP addressed to you of even date herewith, which
is being filed as an exhibit to the Registration Statement.

         This opinion is expressed as of the date hereof and we do not assume
any obligation to update or supplement it to reflect any change in any fact or
circumstance that hereafter comes to our attention, or any change in law that
may occur hereafter.


                                                Very truly yours,

                                                KELEHER & McLEOD, P.A.



                                                By /s/ Charles L. Moore
                                                   --------------------
                                                   Charles L. Moore