Exhibit 5.1

                               Balch & Bingham LLP
                              1901 Sixth Ave. North
                            Birmingham, Alabama 35203
                                  205-251-8100

                                November 5, 2001



Alabama Power Company
600 North 18th Street
Birmingham, AL 35291

                     Re: Registration Statement on Form S-3

Ladies and Gentlemen:

         We have acted as counsel to Alabama Power Company (the "Company") in
connection with the preparation of a Registration Statement on Form S-3,
including a preliminary prospectus (the "Registration Statement"), which is to
be filed with the Securities and Exchange Commission (the "Commission") under
the Securities Act of 1933, as amended (the "Act"), for the registration under
the Act of (1) First Mortgage Bonds (the "new Bonds") to be issued by the
Company, (2) Class A Preferred Stock (the "new Stock") to be issued by the
Company, (3) Senior Notes (the "Senior Notes") to be issued by the Company, (4)
Junior Subordinated Notes (the "Junior Subordinated Notes") to be issued by the
Company, (5) Trust Preferred Securities to be issued by Alabama Power Capital
Trust IV and Alabama Power Capital Trust V and (6) the Company's Guarantees (as
defined in the Registration Statement) with respect to such Trust Preferred
Securities. The new Bonds will be issued pursuant to an Indenture, as
supplemented, between the Company and the trustee named therein (the "First
Mortgage Bond Indenture"), the Senior Notes will be issued pursuant to a senior
note indenture, as supplemented, between the Company and the trustee named
therein (the "Senior Note Indenture"), the Junior Subordinated Notes will be
issued pursuant to a subordinated note indenture, as supplemented, between the
Company and the trustee named therein (the "Subordinated Note Indenture") and
the Guarantees will be issued pursuant to separate guaranty agreements between
the Company and the trustee named therein (the "Guaranty Agreements"), in each
case in the respective forms filed as exhibits to the Registration Statement.

         We are of the opinion that, upon compliance with the pertinent
provisions of the Act, the Trust Indenture Act of 1939, as amended, and the
Public Utility Holding Company Act of 1935, as amended, upon compliance with
applicable securities or blue sky laws of various jurisdictions, upon the
adoption of appropriate resolutions by the Board of Directors of the Company,
when the new Bonds, the new Stock, the Senior Notes, the Junior Subordinated
Notes and the Guarantees have been issued and sold upon the terms specified in
the orders of the Alabama Public Service Commission:





Alabama Power Company
November 5, 2001
Page 2



(1)      When the First Mortgage Bond Indenture and any supplemental indenture
         to be entered into in connection with the issuance of the new Bonds has
         been duly executed and delivered by the proper officers of the Company
         and the trustee named therein, and when the new Bonds have been
         executed, authenticated and delivered in accordance with the terms of
         the First Mortgage Bond Indenture, the new Bonds will be valid, binding
         and legal obligations of the Company, subject to applicable bankruptcy,
         moratorium and similar laws from time to time in force and to general
         principles of equity, whether considered in a proceeding at law or in
         equity, the holders and owners thereof will be entitled to all the
         rights and security afforded by the First Mortgage Bond Indenture and
         the new Bonds will rank equally as to security with the bonds of other
         series presently outstanding under the First Mortgage Bond Indenture,
         which is, in our opinion, a direct first lien on substantially all the
         Company's fixed property and franchises, used or useful in its public
         utility business, subject only to excepted encumbrances as defined in
         the First Mortgage Bond Indenture.

(2)      Upon the filing in the Office of the Secretary of State of Alabama of
         an appropriate certificate of the resolutions of the Board of Directors
         establishing the new Stock, and when certificates for the new Stock
         have been executed, countersigned and registered in accordance with
         such resolutions of the Board of Directors and the By-Laws of the
         Company, the shares of new Stock will be legally issued, fully paid and
         non-assessable shares of the Company and the holders and owners thereof
         will be entitled to all the rights and preferences to be set forth in
         the charter of the Company, as amended.

(3)      When the Senior Note Indenture and any supplemental indenture to be
         entered into in connection with the issuance of the Senior Notes, the
         Subordinated Note Indenture and any supplemental indenture to be
         entered into in connection with the issuance of the Junior Subordinated
         Notes or the Guaranty Agreements, as applicable, have been duly
         executed and delivered by the proper officers of the Company and the
         trustees named therein, and when the Senior Notes, the Junior
         Subordinated Notes and the Guarantees, as the case may be, have been
         executed, authenticated and delivered in accordance with the terms of
         the Senior Note Indenture, the Subordinated Note Indenture and the
         Guarantees, as applicable, the Senior Notes, the Junior Subordinated
         Notes and the Guarantees will be valid, binding and legal obligations
         of the Company, subject to applicable bankruptcy, moratorium and
         similar laws from time to time in force and to general principles of
         equity, whether considered in a proceeding at law or in equity.

         We hereby consent to the filing of this opinion as an exhibit to the
aforementioned Registration Statement and to the statements with respect to our
firm under the caption "Legal Matters" in the prospectus.

                                Very truly yours

                             /s/Balch & Bingham LLP