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                                                                       EXHIBIT 8


                                January 29, 2001



Kinder Morgan Energy Partners, L.P.
One Allen Center, Suite 1000
500 Dallas Street
Houston, Texas 77002

Ladies and Gentlemen:

We have acted as counsel to Kinder Morgan Energy Partners, L.P. (the
"Partnership"), a Delaware limited partnership, in connection with the proposed
offering by the Partnership from time to time of up to an aggregate amount of
$2,000,000,000 of the Partnership's common units representing limited
partnership interests (the "Units") and debt securities, whether senior or
subordinated (collectively, the "Debt Securities"). The Partnership has filed
with the Securities and Exchange Commission (the "Commission") a registration
statement on Form S-3 (the "Registration Statement"), under the Securities Act
of 1933, as amended (the "Securities Act"), relating to the Units and the Debt
Securities. The Registration Statement also constitutes Post-Effective Amendment
No. 1 to Registration Statement No. 333-66931 relating to previously registered
and as yet unsold securities.

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
Kinder Morgan G.P., Inc., the general partner of the Partnership, 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 Relating to Units" in
the Registration Statement summarizes the material United States federal income
tax considerations relevant to the ownership and disposition of the Units.


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Kinder Morgan Energy Partners, L.P.
January 29, 2001
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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 Relating to Units" 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,



                                        Bracewell & Patterson, L.L.P.