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                                                                     EXHIBIT 8.1

                    [FULBRIGHT & JAWORSKI L.L.P. LETTERHEAD]

April 27, 2001

Lakehead Pipe Line Partners, L.P.
Lake Superior Place 21 West Superior Street
Duluth, Minnesota 55802

Gentlemen:

     We have acted as special tax counsel to Lakehead Pipe Line Partners, L.P.,
a Delaware limited partnership (the "Partnership"), and Lakehead Pipe Line
Company, Inc., a Delaware corporation and the general partner of the
Partnership, in connection with the Registration Statement on Form S-3 (the
"Registration Statement") of the Partnership, relating to the registration of
the offering and sale (the "Offering") of up to $500,000,000 of Class A Common
Units representing Class A limited partner interests of the Partnership (the
"Class A Common Units"). In connection therewith, we have participated in the
preparation of the discussion set forth under the caption "Tax Considerations"
(the "Discussion") in the Registration Statement. Capitalized terms used and not
otherwise defined herein are used as defined in the Registration Statement. The
Discussion, subject to the qualifications stated therein, constitutes our
opinion as to the material United States federal income tax consequences for
purchasers of Class A Common Units pursuant to the Offering.

     We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and to the use of our name in the Discussion. The
issuance of such consent does not concede that we are an "expert" for the
purposes of the Securities Act of 1933.


                                        Very truly yours,


                                        Fulbright & Jaworski L.L.P.