EXHIBIT 8



January 31, 2005



Consumers Energy Company
One Energy Plaza
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 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 its 4.40% First Mortgage Bonds due
2009, Series N; 5.00% First Mortgage Bonds due 2012, Series O; and 5.50% First
Mortgage Bonds due 2016, Series P (collectively 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/ Jay M. Silverman
                                                   ----------------------------
                                                   Jay M. Silverman
                                                   Director of Tax Planning and
                                                   Assistant Tax Counsel