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                                                                       Exhibit 8







October 18, 1999




Consumers Energy Company
212 West Michigan Avenue
Jackson, Michigan 49201

Ladies and Gentlemen:

I am tax counsel to Consumers Energy Company, Consumers Energy Company Financing
III and Consumers Energy Company Financing IV. Reference is made to the
prospectus, (the "Prospectus"), which constitutes part of the registration
statement on Form S-3 ("Registration Statement"), to be filed by Consumers
Energy Company, Consumers Energy Company Financing III and Consumers Energy
Company Financing IV with the Securities and Exchange Commission on or about the
date hereof pursuant to the Securities Act of 1993, as amended, for the
registration of, among other things, Trust Originated Preferred Securities
("Preferred Securities") of Consumers Energy Company Financing III and Consumers
Energy Company Financing IV.

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 considerations that may be relevant to the prospective purchasers of the
Preferred Securities.

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

Very truly yours,

/s/ Theodore J. Vogel