[Letterhead of Ballard, Spahr, Andrews and Ingersoll, LLP]

                                                                       Exhibit 8

                                                               December 27, 2001

Public Service Electric and Gas Company
80 Park Plaza
P.O. Box 570
Newark, NJ  07101

Ladies and Gentlemen:

      We have acted as special counsel to you (the "Company") in connection with
the  registration  of Trust  Preferred  Securities to be issued by PSE&G Capital
Trust III and  PSE&G  Capital  Trust IV,  and the  registration  of the  related
Guarantee  Agreement  and  Deferrable  Interest  Subordinated  Debentures of the
Company  and hereby  confirm to you our  opinion as set forth  under the heading
"United  States  Taxation"  in  the  Prospectus  included  in  the  Registration
Statement filed on Form S-3.

      We consent to the filing of this opinion as an exhibit to the Registration
Statement  and to the  reference to this firm under the heading  "United  States
Taxation" in the Prospectus included in the Registration Statement.

                                                   Very truly yours,

                                                   Ballard, Spahr, Andrews
                                                        and Ingersoll, LLP