Exhibit 5.1
                          [PPL Corporation Letterhead]







                                              May 25, 2004


PPL Capital Funding, Inc.
Two North Ninth Street
Allentown, Pennsylvania 18101

Ladies and Gentlemen:

                  I am Senior Counsel of PPL Services Corporation, a wholly
owned subsidiary of PPL Corporation, a Pennsylvania corporation (the
"Guarantor"), and an affiliate of PPL Capital Funding, Inc., a Delaware
corporation (the "Company") (collectively "PPL"), and as such am familiar with
their affairs, including the Registration Statement on Form S-4 (the
"Registration Statement") to be filed by PPL with the Securities and Exchange
Commission (the "Commission") under the Securities Act of 1933, as amended (the
"Act"), relating to the issuance by the Company of $201,000,000 aggregate
principal amount of 4.33% Notes Exchange Series A due 2009 (the "Exchange
Securities") and the issuance by the Guarantor of a guarantee (the "Guarantee")
with respect to the Exchange Securities.

                  The Exchange Securities and the Guarantee will be issued
pursuant to an indenture dated as of February 26, 2004 (the "Indenture") entered
into between the Guarantor, the Company and JPMorgan Chase Bank, as Trustee (the
"Trustee"). The Exchange Securities will be offered by the Company in exchange
for $201,000,000 aggregate principal amount of its outstanding 4.33% Notes
Series A due 2009.


PPL Capital Funding, Inc.             -2-                          May 25, 2004


                  In rendering the opinions below, I have assumed that at the
time of execution, authentication, issuance and delivery of the Exchange
Securities and the Guarantee, the Indenture will be the valid and legally
binding obligation of the Trustee.

                  I have examined the Registration Statement, the Indenture, the
form of the Exchange Securities and the Guarantee which terms are set forth in
the Indenture, each of which has been filed with the Commission as exhibits to
the Registration Statement. I have also examined or caused to be examined on my
behalf, or there have been examined by predecessors of mine, the franchises
under which the Guarantor operates, consisting of charter rights from the
Commonwealth of Pennsylvania and local consents. Based upon such examination,
upon my familiarity with the Guarantor, and upon an examination of such other
documents and questions of law as I have deemed appropriate for purposes of this
opinion, I am of the opinion that:

                  (1) Each of the Guarantor and the Company is validly organized
and existing as a corporation in good standing under the laws of the
jurisdiction of its organization and is duly qualified to carry on the business
which it is now conducting.

                  (2) The Exchange Securities have been duly authorized by the
Guarantor and by the Company. All other requisite action necessary to make the
Exchange Securities valid, legal and binding obligations of the Company will
have been taken when:

                      (a) the Registration Statement, as it may be amended,
shall have become effective under the Act; and

                      (b) the Exchange Securities shall have been duly executed,
issued and delivered upon the Exchange and in accordance with the provisions of
the definitive Indenture.

                 (3) The Guarantee has been duly authorized by the Guarantor.
All other requisite action necessary to make the Guarantee the valid, legal and
binding obligation of the Guarantor, enforceable in accordance with its terms,
will have been taken when:

                      (a) the Registration Statement, as it may be amended,
shall have become effective under the Act and

                      (b) the Guarantee shall have been duly issued and
delivered upon the Exchange and in accordance with the provisions of the
definitive Indenture (assuming the



PPL Capital Funding, Inc.             -3-                          May 25, 2004



Exchange Securities shall have been duly executed, authorized, issued and
delivered as described above).

                  My opinions set forth in paragraphs 2 and 3 above are subject
to (i) the effects of bankruptcy, insolvency, fraudulent conveyance,
reorganization, moratorium and other similar laws relating to or affecting
creditors' rights generally, (ii) general equitable principles (whether
considered in a proceeding in equity or at law) and (iii) an implied covenant of
good faith and fair dealing.

                  I am a member of the Pennsylvania Bar and the Delaware Bar and
do not hold myself out as an expert on the laws of any other jurisdiction.
Insofar as the opinions herein relate to or are dependent upon matters governed
by laws of the State of New York, I have relied upon the opinion of Simpson
Thacher & Bartlett LLP dated the date hereof.

                  I hereby consent to the use of this opinion as an exhibit to
said Registration Statement and to the use of my name in the Registration
Statement and in the Prospectus constituting a part thereof under the caption
"Legal Matters." I also hereby give my consent to the use of my name in the
opinion of Simpson Thacher & Bartlett LLP, filed as Exhibit 5.2 to said
Registration Statement.

                  In rendering its opinion, Simpson Thacher & Bartlett LLP may
rely upon this opinion as to matters of Pennsylvania law addressed herein as if
this opinion were addressed directly to them.


                                         Very truly yours,


                                         /s/ Thomas D. Salus
                                         -------------------

                                         Thomas D. Salus