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                                                                    Exhibit 8


                     [CMS ENERGY CORPORATION LETTERHEAD]

July 27, 1998

Consumers Energy Company
212 West Michigan Avenue
Jackson, Michigan  49201


Ladies and Gentlemen

         Reference is made to the prospectus, (the "Prospectus"), which
constitutes part of the registration statement on Form S-4 (the "Registration
Statement"), to be filed by Consumers Energy Company ("Consumers") with the
Securities and Exchange Commission on or about the date hereof pursuant to the
Securities Act of 1933, as amended, for the registration of 6 7/8% Senior 
Notes due 2018, Series B of Consumers (the"Exchange Notes").

         I am of the opinion that the statements set forth under the caption
"Certain United States Federal Income Tax Consequences" in the Prospectus
constitute an accurate description, in general terms, of certain United States
federal income tax consideration that may be relevant to the prospective holders
of the Exchange Notes.

I hereby consent to the filing of this opinion as an exhibit to the Registration
Statement.



                                             Very Truly Yours


                                             /s/Theodore J. Vogel