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                                                          Exhibit 8




September 21, 1998



Consumers Energy Company
212 West Michigan Avenue
Jackson, Michigan  49201

Ladies and Gentleman

         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 Senior Notes, 6.20%
Reset Put Securities(SM), Series B, Due 2008 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