(dissenting in part). In these cases we are asked to decide whether the Court of Appeals erred in ordering the Wayne *267County Apportionment Commission (hereinafter the WCAC) and the Ingham County Apportionment Commission (hereinafter the ICAC) to draft and submit to that Court new plans for reapportionment of the commissioner districts of those counties. The Court of Appeals determined that the plans adopted by those commissions did not meet "the requirements of the laws of this state” pursuant to MCL 46.406; MSA 5.359(6). We conclude that the Court of Appeals did err in the case of the WCAC, but we are not persuaded that error has been demonstrated in the resolution of the ICAC case. Accordingly, we would reverse the judgment of the Court of Appeals in Apportionment of Wayne County Board of Comm’rs—1982. Because we disagree with part of the order in Apportionment of Ingham County Board of Comm’rs—1982, the judgment of the Court of Appeals should be affirmed in part and reversed in part.
I
We dissent from the reasoning employed in the opinion of our colleagues. The Legislature is not bound by Const 1963, art 7, § 7.1 That provision of the constitution has been declared unconstitutional. Nor can the Legislature be bound by a "concept” that is judicially engrafted upon a defunct provision.
Today the Court steps well beyond attempting to sever some language from a dead constitutional provision or reviving a portion of a phrase or a *268clause. Here the Court creates and embellishes a judicial concept, knights it with a constitutional badge of honor, and constrains the Legislature to follow the concept by redrafting 1966 PA 261 and 293. It is a stark usurpation of legislative discretion without constitutional foundation to direct that the goal of preserving boundary lines of local governmental units must take precedence over the valid legislatively determined purpose of devising districts as "nearly of equal population as is practicable”.
A
. We agree with the opinion of our colleagues that the language of art 7, § 7 of the Michigan Constitution which requires in organized counties a board of supervisors (commissioners) consisting of one and only one member from each organized township violates the Equal Protection Clause of the Fourteenth Amendment.2 The apportionment of one and only one representative to a township without regard to population clearly runs afoul of the precepts of Reynolds v Sims, 377 US 533; 84 S Ct 1362; 12 L Ed 2d 506 (1964), and Avery v Midland County, 390 US 474; 88 S Ct 1114; 20 L Ed 2d 45 (1968).
It is clear that the drafters of our constitution rejected a more egalitarian method of selecting county officials.3 The method finally adopted which provided for township, not people, representation cannot stand. Unlike our colleagues, we would end our Michigan constitutional analysis at this point.
From the premise that art 7, § 7 of the constitu*269tion embodies "a scheme of township and city representation in county boards of supervisors”, our colleagues take a large quantum leap in logic to conclude that the Legislature was not constitutionally free "to provide for the establishment of election districts having boundary lines that do not follow the boundary lines of townships and cities” except to the extent required by the Equal Protection Clause. It is readily observable that this section, which has been lifted out of our constitution, did not specify boundary line requirements for election districts.
The purported scheme or goals for representation for political units (township and city) cannot remain without the words of the constitutional provision. The "scheme” of representation referred to by our colleagues has no constitutional viability today. The goals and concepts of a constitutional provision do not have a separate life or meaning apart from the words of the provision. There can be no manifestation of any constitutional goal except through the language of a constitution. The concepts underlying the language of a provision are inseparable from the words which embody the concept. Once the language is removed, the underlying goals are no longer viable.
The alleged concept presented in the constitution is inseparable from the invalid allotment of one supervisor for each township. "The invalidity here declared goes to the heart of the political process in a constitutional democracy.” In re Apportionment of State Legislature—1982, 413 Mich 96; 321 NW2d 565 (1982). The representation and governance of organized counties is severely altered once the absolute requirement of one supervisor from each township is eliminated. This is no *270longer the type of board of supervisors for which the people voted when they adopted the Constitution of 1963.
The federal Equal Protection Clause requires that the art 7, § 7 scheme of township representation be voided. Accordingly, this Court must invalidate the concept of township representation including the goals which are inseparable from the words of the provision. When faced with the question of the constitutionality of Act 261 in light of art 7, § 7 this Court stated:
"PA 1966, No 261 is valid, section 7 of article 7 notwithstanding. For Avery has just lifted section 7 out of our Constitution, leaving the rest of article 7 intact with the legislature free to implement it in the same manner as if no section 7 had ever appeared therein.” Advisory Opinion re Constitutionality of PA 1966, No 261, 380 Mich 736, 740; 158 NW2d 497 (1968).
See Brouwer v Kent County Clerk, 377 Mich 616; 141 NW2d 98 (1966) (equally divided Court affirmed circuit court decision voiding art 7, § 7), and In re Apportionment of Ontonagon County Board of Supervisors—1967 (On Rehearing), 11 Mich App 348; 157 NW2d 698 (1968) (declaring art 7, § 7 unconstitutional). This did not, however, leave a vacuum regarding the apportionment of county boards.
B
Our constitution grants the Legislature extensive powers, limited only by specific provisions of the federal and state constitutions. See Washington-Detroit Theatre Co v Moore, 249 Mich 673, 680; 229 NW 618 (1930), Hudson Motor Car Co v Detroit, 282 Mich 69, 79; 275 NW 770 (1937). Thus *271the Legislature is the appropriate body to determine the scheme of county governance.
The Legislature, in 1966, understanding the constitutional underpinnings of equality of representation, provided for apportionment of counties generally and also for charter counties. 1966 PA 261, 1966 PA 293.4 The action of the Legislature filled *272the void left by the uncoiistitutionality of art 7, § 7. Furthermore, the constitution specifically *273grants the Legislature the authority to provide for the powers of counties. Const 1963, art 7, §§ 1, 2.5
In addition, the Constitution of 1963 made a significant break with the historical scheme of township and city representation as political units on county boards of commissioners. Art 7, § 2 permits the Legislature to draft procedures for county home rule. See 1966 PA 293. Thus, the constitution does not require township qua township representation on the county board in charter counties and specifically "permit[s] the organization of county government in form different from that set forth in this constitution”. Const 1963, art 7, §2.
Unlike the opinion of our colleagues, we conclude that returning the drafting of a procedure for county apportionment to the Legislature is consistent with our opinion In re Apportionment of State Legislature—1982, and that the question involved does go "to the heart of the political process” in county government. In the state legis*274lative apportionment case, this Court invalidated the constitutional apportionment requirements and the process of apportionment by a commission. We concluded that the constitutional apportionment standards were not severable from the invalidly weighted land area-population formulae. Furthermore, we determined that an apportionment commission without standards could not survive.
Therefore, this Court, in order to preserve orderly elections and to permit the necessary reapportionment, ordered the preparation of a legislative apportionment plan consistent with guidelines which found their genesis in Michigan’s constitutional history. By directing a plan to be developed that would meet strict and narrow guidelines, this Court attempted to develop standards for the drafting of a neutral and nonpartisan plan. These guidelines were only that, and not constitutional requirements. The Court-ordered plan is to continue only until the people or the other two branches of government in this state act.
Finally, in the legislative apportionment case, the Court directed that the Court’s plan could be superseded at any time by a contrary plan developed by the Legislature and approved by the Governor. Such a plan need not follow the guidelines of the Court-ordered plan. Having declared unconstitutional the apportionment rules of art 4, §§ 2-6,6 this Court is without the legitimate power to order the other two branches of government to follow non-constitutionally required guidelines. Therefore, in the legislative apportionment case, *275as in the case of apportionment of counties, the Legislature is limited only by the federal constitution and any requirements of the Michigan Constitution which apply, but not the invalid apportionment rules. There is no scheme of township and city representation with a viable constitutional base which demands virtually unyielding adherence to boundary lines. Thus, the Legislature is free to design any system of apportionment as long as it does not run afoul of the Equal Protection Clause of the federal constitution.7
C
The opinion of our colleagues concludes that the statutory apportionment guidelines for county commissioner districts require that boundary lines be drawn to preserve city and township lines. Apparently their opinion would place precinct boundaries above a goal of more equality than 11.9%.8 In Abate v Mundt, 403 US 182; 91 S Ct 1904; 29 L Ed 2d 399 (1971), the United States Supreme Court found that a county reapportionment plan which provided for a 11.9% population deviation between districts did not contravene the Equal Protection Clause of the United States Constitution. Compare Mahan v Howell, 410 US 315; 93 S Ct 979; 35 L Ed 2d 320 (1973); Chapman v Meier, 420 US 1; 95 S Ct 751; 42 L Ed 2d 766 (1975). We believe it is erroneous to conclude that (1) the "stated order” of Act 261 must be read so as not to violate the "scheme of township and city representation in county boards” of the Michigan *276Constitution; (2) the allowable divergence of 11.9% is the proper standard; and (3) a standard of allowable divergence must be set at this time.
We address these issues seriatim. Act 261, as amended, requires the county apportionment commission to be governed by apportionment guidelines in the stated order of importance. Eight guidelines are set forth, the primary guideline being population equality. It is apparent that the legislative plan of apportionment appropriately makes equality of population the controlling consideration in the apportionment of commissioner districts. See Reynolds v Sims, 377 US 567. The words and structure of the statute place population equality first, but do require that all of the guidelines are to be considered and followed without excluding any, but observing the stated order. Thus, the duty of the apportionment commission is to consider and apply the guidelines as mandated by the statute.
By reviving the invalid constitutional requirements of adherence to township lines under the new guise of guidelines, the majority opinion rewrites the statute, exalting boundary lines over an apportionment commission’s attempt to reach the statutory standard of equality of population.
In practical terms the opinion of our colleagues concludes that the ICAC and WCAC provided for districts too nearly equal in population. That is an incorrect conclusion and is unsupported by law or logic. The majority opinion, after rearranging the stated order of criteria in Act 261 so that the boundaries of political subdivisions are given primacy, goes on to conclude that apportionment commissions are free to adopt plans which deviate from population equality among districts so long as the deviation does not exceed 11.9% per Abate, *277supra. In doing so the majority has transformed an ad hoc decision of the United States Supreme Court which turned upon whether the deviation in a county apportionment plan was unconstitutional into a standard to be followed. In other words, the effect of the majority decision is to tell apportionment commissions that they shall deviate from population equality to preserve the inviolability of the boundaries of political subdivisions. Thus is the essentially negative finding of Abate (the plan was not unconstitutional) by metamorphosis transformed into an affirmative command by this Court.
Obedience to an 11.9% deviation
"disregards the critical fact that adherence to a percentage deviation that is at the outside limits of constitutionality cannot be squared with the overriding constitutional objective of 'substantial equality of population’ among districts. The Pennsylvania Constitution [similar to Act 261] plainly states that districts shall be 'as nearly equal in population as practicable.’ [Pa Const, art 2, § 16.] Thus, the clear constitutional directive is that reapportionment shall strive to create districts as equal, not as unequal, as possible.” In re Reapportionment Plan for Pennsylvania General Assembly, 497 Pa 525, 536; 442 A2d 661, 667 (1981).
Thus, it should not be presumed that an apportioning body which complies with the overriding objective of population equality must have its plan reversed by a court. To allow this to happen would turn the constitutional requirement of equality on its head and exalt district representation over people representation.
Furthermore, the posture and language of the Mahan case and more appropriately the Abate case do not suggest that this Court should reverse the- work of the county apportionment commissions. In Abate and Mahan, the Supreme Court *278reviewed apportionment plans which had been developed and adopted by the appropriate apportioning bodies. The approval of each plan, based on a full record of justification for any deviation from mathematical equality, is far different from a court acting as a super-apportionment commission setting population standards at the outer limit of decided case law. In Abate and Mahan, the Supreme Court permitted and approved the apportionment plans drafted by the representatives of the people. Today, the Court apparently invalidates plans because the "good faith effort” to achieve population equality has been too good-faith. Cf. Lucas v Forty-Fourth General Assembly of Colorado, 377 US 713, 735, fn 27; 84 S Ct 1459; 12 L Ed 2d 632 (1964).
Furthermore, the population deviation that has been approved in one state or county apportionment plan is no guaranty nor does it have much bearing on the question of the validity of a plan for a different locale. Reynolds v Sims, 377 US 578; Mahan v Howell, 410 US 328-329; Swann v Adams, 385 US 440, 445; 87 S Ct 569; 17 L Ed 2d 501 (1967).
Finally, like the United States Supreme Court, we believe the preferable course to follow in reviewing apportionment cases is on a case-by-case basis. See, e.g., Chapman v Meier, 420 US 22; Swann v Adams, 385 US 445. Each plan must be examined. The Supreme Court has not set a benchmark standard, neither should this Court.
We recognize that equality of population under the federal Equal Protection Clause and the statutory apportionment guidelines does not mean precise mathematical equality. Deviation from the perfect district is constitutionally and statutorily permissible. Each case and plan should be examined on its facts. The county apportionment com*279mission9 is well able to determine the constitutional and statutory meaning of equal protection. This Court need not and should not set a standard now, particularly one which developed out of a particular fact situation with different justifications than the instant cases.
II
A
We now turn to analyze these cases in accordance with the statute. The WCAC convened on November 2, 1981. In an election held on November 3, 1981, the voters of Wayne County approved the Wayne County Charter. That charter, inter alia, reduced the number of commissioners of the county from 27 to 15. Most of the provisions of the charter are to be effective on January 1, 1983.10 The charter further provided in § 8.120(a):
"The existing county apportionment commission shall provide the apportionment plan as provided by law for the initial election of county commissioners under this charter in the 1982 primary and general elections for the commission established under this charter.”11
After receiving the 1980 United States official census figures, the WCAC proceeded to apportion the commissioner districts. For purposes of this appeal it may be assumed the apportionment was completed under MCL 46.404; MSA 5.359(4).12
At its meeting of December 8, 1981, the WCAC received a proposed reapportionment plan from its own staff. One of the commission members, Hubert *280Holley, also submitted a proposed apportionment plan for eastern Wayne County.
At the next meeting, held on December 14, 1981, Mr. Holley submitted a revised plan which encompassed the entire county. In addition, Mr. Holley submitted a written comparison of his plan with that of the staff plan.
At its meeting of January 6, 1982, the WCAC discussed the revised Holley plan and the staff plan which had been revised as of this same date. The members of the WCAC agreed that both plans were in "substantial compliance” with the apportionment guidelines. It was noted, however, that other plans might be submitted for review.
Two other proposed apportionment plans were Submitted. In addition, Mr. Holley submitted a third revision of his proposed plan on January 12, 1982. The WCAC agreed, unanimously, to adopt and file Mr. Holley’s third revised plan.
MCL 46.406; MSA 5.359(6) states:
"Any registered voter of the county within 30 days after the filing of the plan for his county may petition the court of appeals to review such plan to determine if the plan meets the requirements of the laws of this state. Any findings of the court of appeals may be appealed to the supreme court of the state as provided by law.”
Two petitions were filed pursuant to this statutory provision. The petitioners, citizens of the cities of Dearborn, Dearborn Heights, and Westland, complained that the revised staff plan was preferable to the plan adopted by the WCAC. The petitioners from Dearborn Heights and Westland stated that their cities had been unnecessarily divided into three districts, that the shape of the commissioner districts was "violative of the guide*281lines as set forth in MCL 46.404”, and that there had been "partisan political considerations” in adopting the plan. The petitioner from Dearborn argued that further study by the WCAC would produce a better plan. He objected to the division of Dearborn into two districts, to the shape of the districts, and to "partisan political considerations” in adopting the plan.
On February 16, 1982, the Court of Appeals issued the following order:
"In this cause petitions for review of the apportionment of the Wayne County Board of Commissioners having been filed by John B. O’Reilly, in Docket No. 62576, and Donald Bishop, et al., in Docket No. 62577, all registered voters of said county, pursuant to MCL 46.406; MSA 5.359(6), and due consideration thereof having been had by the Court;
"It is ordered that the Wayne County Apportionment Commission show cause on or before February 26, 1982, why its plan of apportionment should not be held invalid or unconstitutional under applicable statutes and constitutional provisions. The commission’s answer shall include the following:
"1. Justification for all population variances from equality, no matter how small, in each district of the adopted plan.
"2. A complete set of census materials as provided by the apportionment commission by the Secretary of State.
"3. A complete set of the minutes of the meetings of the apportionment commission, together with a copy of the plan adopted, as well as copies of all plans submitted for consideration. These plans shall consist of visually drawn maps and verbal descriptions of commissioner districts by identified enumeration districts, with United States census figures for each ED and totals for each commissioner district. The apportionment commission shall state specific reasons for the commission’s rejection of each plan submitted to them for their consideration.
*282"4. A written reply to any additional issues raised in the petitions for review.”
The WCAC responded to this order. However, the Court of Appeals was unsatisfied by the response, and on March 31, 1982, it held:
"In this cause petitions to review the apportionment plan of the Wayne County Board of Commissioners having been filed, and a response having been filed by the Wayne County Apportionment Commission, and due consideration thereof having been had by this Court; therefore
"It is ordered that the plan adopted by the Wayne County Apportionment Commission is void because it does not meet the requirements of the laws of this state, and it is in violation of 1966 PA 261. A lack of good-faith effort to achieve districts of equal population is evidenced by at least the following in the record: (1) Mathematical exactness was never the primary goal of the commission as required by this Court. Apportionment of Oakland County Board of Comm’rs—1972, 40 Mich App 493 (1972); Apportionment of Kent County Board of Comm’rs—1972, 40 Mich App 508 (1972). (2) The commission placed the inviolability of political subdivisions and out-county election precincts before mathematical exactness. Apportionment of Ionia County Board of Comm’rs—1972, 39 Mich App 676 (1972); Apportionment of Oakland County—1972, supra. (3) A reluctance to split census tracts by removing blocks to another district to achieve mathematical exactness. Given the refinement of the census materials in Wayne County and this Court’s opinions ten years ago in Oakland and Kent resulting in zero-deviance plans, the Court can accept no less from Wayne County.
"We remand the cause to the Wayne County Apportionment Commission with express instructions to modify the adopted plan or to adopt a new plan in accordance with this order and the provisions of 1966 PA 261 and, further, to submit the new plan to this Court for review within 12 days of the date of the certification of this order. Apportionment of Delta County—1982, File *283No. 61566. Any plan before the apportionment commission shall first be completely verified as to boundaries and population by the Wayne County Apportionment Commission staff before a vote may be taken on the plan. Each plan submitted on remand must have an individual vote on it, with individual members explaining their vote on the record. Such record and copies of all plans shall be submitted to this Court together with a justification for any variance from zero deviance in each district of the adopted plan with reference to census material. The Court points out the answer of the commission to the show-cause order of this Court was unresponsive in this respect.
"The issues raised by the petitioners are considered without merit in that there was (1) no showing that the splitting of political subdivisions was unnecessary in order to achieve equality of population. (2) Even if petitioners had achieved the admissions they sought by their motion to depose, it would not be sufficient to meet the test of actual evidence of an intentional and systematic disenfranchisement as established in Kent and Oakland, supra. Accordingly, petitioners’ motion to compel deposition is denied.”
The WCAC applied for leave to appeal. The application was granted, and this Court stayed further proceedings in this matter.
B
The ICAC held its first meeting on November 3, 1981. In all, 13 plans were submitted to the commission for its review. Several of that number, however, were revisions of earlier submittals. All plans had a zero population deviation among the districts. However, the plans differed in many respects with regard to the degree to which they adhered to the rest of the guidelines set forth in MCL 46.404; MSA 5.359(4).
The first two plans which were submitted were *284not moved for consideration. The next two plans were so moved, but the motions failed by a 3 to 2 vote. Thereafter several plans were submitted, but were not moved for consideration or failed to receive a sufficient number of votes to carry the motion. Finally, at its meeting of February 2, 1982, the commission had available for consideration four plans known as the Baker Plan #2, the Brewer Plan #1, the Brewer Plan #2, and the Houk Plan #3. The ICAC decided, by vote of 3 to 2, to adopt and file the Baker Plan #2.
On March 3, 1982, Jane Schoneman filed a petition for review of the plan in the Court of Appeals. The petitioner complained that the plan "violated” the guidelines contained in MCL 46.404(c), (d), (e) and (f); MSA 5.359(4)(c), (d), (e) and (f). Specifically it was charged that:
"In adopting the Baker Plan #2, the commission majority selected from the plans before it the plan which has (a) the most irregular lines and oddly-shaped districts; (b) the greatest number of districts combining cities with townships; (c) the greatest number of districts dividing townships and cities; and (d) divided the greatest number of precincts in the county.”
The petitioner claimed that the plan which the ICAC had adopted compared unfavorably in these respects with the McKeague Plan #3, the Brewer Plan #2, and the Houk Plan #3. The petitioner asked the Court of Appeals to either order the ICAC to adopt a new plan or to approve "that plan which was submitted to the commission which best conforms to the requirements of the law”.
On March 4, 1982, the Court of Appeals issued a show-cause order directed to the ICAC which was virtually identical to that previously issued to the *285WCAC. The ICAC responded to the order. However, on April 5, 1982, the Court of Appeals issued the following order:
"In this cause a petition to review the apportionment of the Ingham County Board of Commissioners having been filed, and a response having been filed by the Ingham County Apportionment Commission, and due consideration thereof having been had by this Court; therefore
"It is ordered that the plan adopted by the Ingham County Apportionment Commission is void because it does not meet the requirements of the laws of this state, and it is in violation of 1966 PA 261, for failure to comply with the subsidiary guidelines of § 4. The record reveals that all plans filed before the commission achieved zero deviance. However, the commission selected the plan which mathematically violated the subsidiary guidelines (c), (d), (e) and (f) more than other plans before the commission. The Court has stated that the subsidiary guidelines of the statute must give deference to the primary guideline of districts of equal population. Apportionment of Ionia County Board of Comm’rs—1972, 39 Mich App 676 (1972). However, once mathematical exactness in population is achieved, this Court shall then apply those subsidiary guidelines in any review. Apportionment of Allegan County Board of Supervisors—1968, 13 Mich App 692 (1968); Apportionment of Oakland County Board of Comm’rs—1972, 40 Mich App 493 (1972).
"We remand the cause to the Ingham County Apportionment Commission with the express instructions to adopt a new plan in accordance with this order and the provisions of 1966 PA 261 and further, to submit the new plan to this Court for review within ten days of the date of the certification of this order. On remand the commission shall: (1) Meet daily and hold its first meeting within 48 hours of the date of the certification of this order. At this meeting the commission shall first re-determine the size of the board. In a situation where plans for any size board are all zero deviance, we decline to interfere with the commission’s statutory *286discretion as to size. Such discretion may only be questioned by the necessity to achieve districts of equal population. Apportionment of Van Buren County Board of Comm’rs—1972, 39 Mich App 658 (1972). To qualify board size discretion with the subsidiary guidelines would, in most cases, force the commission to the smallest board size and, thereby, destroy such discretion. However, within the context of zero deviance and a chosen board size, a commission must develop and choose such a plan which mathematically produces the least violations of the subsidiary guidelines. (2) At the first two meetings any commission member may submit a plan for the approved board size, provided it is a zero deviance plan. Apportionment of Delta County—1982, File No. 61566. (3) Each plan must be verified by the Tri-County Regional Planning Commission within 48 hours and amendments to the plans within 24 hours in the following form: (A) Verification of the population figures within each district and the legal description of such district; (B) Determine the compactness of each district by computing the land area (excluding land outside the county) outside the district which has been circumscribed by a circle. In re Apportionment of State Legislature—1982, No. 68777; (C) Total the townships or parts thereof attached to cities or parts thereof within each district, and the totals for the entire plan; (D) Specifically identify each township, village or city divided, and the total number of divisions for the individual political subdivision in the plan; (E) Total the number of precincts divided by the plan. (4) After initial verification, any plan submitted may be amended by the member submitting the plan within 24 hours. (5) The commission shall then vote upon each plan submitted with each member giving reasons for his vote. (6) The proceedings of the commission shall be recorded by means of a verbatim transcript prepared in copy form overnight. (7) The plan adopted, all other plans, the TriCounty Regional Planning Commission’s verifications, the transcript, and a justification for the variance of each guideline in § 4(c) through (f), and a justification for not adopting any plan with fewer mathematical counts in each guideline shall be filed with the clerk of this Court. A map for each plan shall also be filed, but *287it must be a legible census map and not a so-called '1978 Jurisdictional Map’. Petitioner may file objections within 24 hours.”
The ICAC filed an application for leave to appeal with this Court. The application was granted, and we have stayed further proceedings in this matter.
C
Pursuant to MCL 46.406; MSA 5.359(6), the Court of Appeals, upon the filing of a petition for review, must ascertain whether the apportionment plan adopted by the commission "meets the requirements of the laws of this state”. Thus, it is clear that if the Court of Appeals determines that the plan fails to adhere to statutory mandates or constitutional requirements, it cannot approve the plan.
In the case of the WCAC’s plan, the order of the Court of Appeals indicates only one area of deficiency — a failure to achieve absolute mathematical equality (zero deviation) among commissioner districts. The "ideal district” for Wayne County in terms of mathematical equality is 155,859.4. The plan which was eventually adopted by the WCAC had a variance range of 471. That is, the district which most exceeded the ideal size in terms of population had 183.6 more people than would be "ideal”. The district which had the largest variance in terms of underpopulation measured against the ideal had 287.4 less people than would be "ideal”. In terms of percentage of difference from zero deviance, the plan adopted by the WCAC had 0.3% deviation. On the other hand, the revised staff plan, lauded by the petitioners, had a variance range of 745 people with a 0.48% devia*288tion factor. The revised staff plan also had more splits (division of townships, cities, and villages) than did the plan adopted by the WCAC.
In spite of the extremely small percentage of deviation, the Court of Appeals rejected the plan. The reason for the rejection was that the Court of Appeals has interpreted MCL 46.404; MSA 5.359(4) to require mathematical equality or zero deviation as a sine qua non for approval. It is only after this requirement has been met that the Court of Appeals will examine the plan for compliance with the other guidelines set forth in this statute.
In the case of the 1982 WCAC plan, the Court of Appeals said:
"Given the refinement of the census materials in Wayne County and this Court’s opinions ten years ago in Oakland and Kent resulting in zero deviance plans, the Court can accept no less from Wayne County.”
The concept of absolute mathematical equality in election districts, so prominently noted in Kirkpatrick, has been revised by subsequent case law, most notably by Abate v Mundt, supra, by Mahan v Howell, supra, and by Gaffney v Cummings, 412 US 735; 93 S Ct 2321; 37 L Ed 2d 298 (1973).
In Abate the Court reviewed the apportionment plan of the Rockland County, New York, Board of Supervisors. There was a total deviation from population equality among the five districts of 11.9%. The Court rejected a claim that the plan violated equal protection standards. The Court observed that some deviations would be permitted provided they were based on rational state policy.
In Mahan, the United States Supreme Court *289examined the validity of the Virginia State Legislature redistricting plan. The Court held that while absolute population equality was the sole criterion in congressional apportionment, greater flexibility would be permitted in state legislative apportionment and that a rational state policy could justify minor deviations from precise equality.
In Gaffney the Court held that some deviations in a state legislative plan were "so minimal” that no justification for the population variances was required. The deviation on the average was 1.9% and the maximum deviation was 7.83%.
Based upon these decisions, it is recognized that the federal constitution does not require absolute mathematical equality for county reapportionment. It is clear to us that the ratio decidendi for the Court of Appeals interpretation of MCL 46.404; MSA 5.359(4) as requiring zero population deviance is the Kirkpatrick case. We can discern no legislative intention to require absolute mathematical equality to the virtual exclusion of the other guidelines contained in the statute. It is true that in the hierarchy of the guidelines in the statute the consideration of having districts "as nearly of equal population as is practicable” is given primacy. However, to say that is not to say that the other criteria need only be consulted when and if a plan attains zero population deviance. The phrase "as nearly of equal population as is practicable” does not mean "mathematical equality”. If the Legislature had intended to require mathematical equality, it could easily have done so. It did not, and we interpret the language of MCL 46.404; MSA 5.359(4) as not requiring mathematical equality in the apportioning of commissioner districts on the basis of population.
*290D
In rejecting the plan of the ICAC, the Court of Appeals made a finding that that plan, though a zero deviance plan, compared unfavorably with three other plans which were submitted to the Court of Appeals for purposes of comparison. The petitioners alleged that the plan adopted by the ICAC had districts which were not as compact and of nearly square shape as would be practicable, and combined more townships or parts thereof than was needed to meet the population standard (which was assumed to be zero deviation). In addition, the petitioners claimed that the plan adopted by the ICAC divided more townships, cities, and precincts than any of the other plans which had been before the ICAC.
The Court of Appeals in its order of April 5, 1982, in which it rejected the plan adopted and filed by the ICAC, made a finding that the ICAC’s plan "mathematically violated the subsidiary guidelines (c), (d), (e) and (f) more than other plans before the commission”. In addition, the Court ruled that "within the context of zero deviance and a chosen board size, a commission must develop and choose such a plan which mathematically produces the least violations of the subsidiary guidelines”.
As to the shape of the districts in the ICAC plan, the petitioner alleges that although this is a "difficult” guideline to assess, nevertheless a visual comparison of the ICAC plan vis-á-vis the three other plans used for comparison reveals that the ICAC plan is "comprised of more irregular lines and oddly shaped districts”. The petitioner also contends that an examination of the ICAC plan *291and the three other plans reveals that the ICAC plan was the least "compact” as that term was defined in In re Apportionment of State Legislature-1982.13
With regard to the issue of combining townships with cities to form districts, the petitioner proffers two methods of counting: one would simply count the number of districts with such combinations, while the other would add the number of townships, cities or villages within the county and then count the number that were combined by each plan. (The ICAC argues that the latter method should be employed.) Under either method, argues the petitioner, the ICAC plan is the worst or equal to the worst as compared to the other three plans.
As to division of townships, villages, and cities the petitioner points out that under either of the two methods of counting alluded to above, the ICAC plan, compared to the other three, is not the best plan. Under the first method of counting, the ICAC plan was the worst plan. Under the second method of counting, the ICAC plan is the worst or equal to the worst when compared to the other three plans.
Finally, the petitioner has charged that the ÍCAC plan divides more precincts (85, as opposed to 49, 76, and 76) than the other three plans and that the ICAC has given no credible justification for this other than to charge that this criterion should be ignored because it exists simply for the convenience of clerks._
*292The ICAC, the appellant here, responds to the arguments of the petitioner in two ways. First, the ICAC, as noted above, challenges the manner in which the petitioner has calculated the number of combinations and divisions. In addition, the ICAC claims that the method of calculation employed by the petitioner fails to take into account an annexation by the City of Williamston in 1980. As to "compactness”, the ICAC contends that the Court of Appeals and the petitioner have improperly applied the definition of compactness set forth in our opinion in In re Apportionment of State Legislature—1982 to a plan adopted before that decision was rendered. Finally, as to the splitting of precincts, the ICAC argues that precincts are, indeed, nothing more than artificial entities and that the fact that its plan splits more precincts than the others does not warrant a rejection of the plan.14
The ICAC’s most emphasized point on appeal, however, is that the Court of Appeals erred in invalidating its plan on the theory that the ICAC should have adopted the plan which "mathematically produces the least violations of the subsidiary guidelines”. The standard which should be employed, according to the ICAC, is one of clear abuse of discretion by the commission. The ICAC states, in part:
"The Court of Appeals requirement for the 'perfect plan’ should not be imposed on an apportionment commission. Any plan is capable of improvement in some degree (although improvement in one area may result in a loss in other areas). The effect of the Court of Appeals order is to remove from the apportionment *293commission all discretion in decision-making. The Court of Appeals opinion could result in the adoption of the last 'best’ plan (mathematically speaking). The courts should not overturn an apportionment commission decision unless there is a clear abuse of discretion by that commission in applying the nonconstitutional subsidiary criteria.”
E
What standard of review should be applied when the Court of Appeals examines an apportionment plan adopted by a commission pursuant to MCL 46.404; MSA 5.359(4)? MCL 46.406; MSA 5.359(6) simply states that the Court of Appeals must determine if the plan "meets the requirements of the laws of this state”. However, it is clear that the Court of Appeals has adopted a standard which would require a commission to adopt the plan which best meets the requirements of the laws of this state, with the law being the criteria which are set forth in MCL 46.404; MSA 5.359(4). This standard leaves very little discretion, if any, in the apportionment commission. If an individual could demonstrate, for instance, that his or her plan, while in all other respects identical to that favored by a majority of the commission, nevertheless divided fewer precincts, such a plan would qualify as the "best” plan.
We are convinced that the Legislature did not intend to so limit the discretion of the apportionment commission. Certainly the record must support the conclusion that the apportionment commission followed the guidelines in MCL 46.404; MSA 5.359(4). In Reynolds v Sims, supra, the United States Supreme Court, in a state legislative apportionment context, required "an honest and *294good-faith effort” on the part of the states to achieve districts as nearly of equal population as is practicable. We believe this standard should also be applied when assessing the efforts of a county apportionment commission to comply with the guidelines contained in MCL 46.404; MSA 5.359(4). To require more would reduce the apportionment process to a mere mathematical exercise and would constitute an apportionment commission little more than a board of account. To require less would give rise to the evils which prompted the establishment of guidelines in the first instance.
F
Did the plans which the WCAC and the ICAC adopted demonstrate an "honest and good-faith effort” to comply with the criteria specified in MCL 46.404; MSA 5.359(4)? We would answer the question in the affirmative in the case of the WCAC’s plan and in the negative in the case of the ICAC’s plan.
WCAC
As we noted earlier in this opinion, the only two plans which received serious consideration by the WCAC were the one which it ultimately adopted (the "Holley” plan) and the plan submitted to it by its own staff (the "revised staff” plan). We conclude that the record before us clearly demonstrates that the WCAC considered all of the guidelines in their stated order of importance and made an "honest and good-faith effort” to select a plan which adhered to those criteria. Thus, the plan adopted by the WCAC "meets the requirements of the laws of this state”.
*295 ICAC
The minutes of the meetings of the ICAC evidence a predilection on the part of the commission, understandable in view of prior court decisions, to be concerned with population equality virtually to the exclusion of all other factors. However, all 13 plans which, at one time or another, were proffered to the commission were zero deviation plans. In such a situation, it is obvious that adherence to the other guidelines in the statute should determine plan selection.
In this case, the petitioner has convincingly established that compared to three other plans the one which the commission ultimately adopted was, judged against the other guidelines, the worst of the group (if the petitioner’s tests are used) or the worst or equal to the worst of the group (if the ICAC’s tests are used). The Court of Appeals made a finding that the ICAC’s plan was, indeed, the worst of the four. Moreover, we are not persuaded, on the basis of the record before us, that the ICAC gave adequate consideration to the guidelines of MCL 46.404(c)-(f); MSA 5.359(4)(c)-(f).
Ill
The ICAC has raised three other contentions on appeal. Specifically, the ICAC alleges that the Court of Appeals erred: 1) in requiring that each plan submitted be voted on and that each commission member give reasons for his vote; 2) in requiring that the commission choose its board size at the first meeting on record; and 3) in imposing unreasonable time constraints on remand.
We agree with the ICAC that the Court of *296Appeals erred in requiring a vote on all plans submitted and in requiring a statement of reasons for the vote of each commissioner. We would find such requirements to be unnecessary and unwise encroachments upon the actions of a quasi-legislative body. See Giddings v Secretary of State, 93 Mich 1, 8; 52 NW 944 (1892). We would therefore vacate this part of the Court of Appeals judgment.
We would find no error in the order of the Court of Appeals insofar as it required the ICAC to choose its board size at the first meeting, to adopt a new plan and to submit it within ten days, and to submit copies of all plans considered at the first two meetings. Here the Court of Appeals clearly was attempting to insure an orderly and timely procedure to be followed on remand.
IV
The WCAC has filed a motion to strike certain issues raised in the petitioners’ brief on appeal. The issues in question were raised by the petitioners as to the propriety of the Court of Appeals order. The WCAC correctly observes that the petitioners are attempting to raise these issues without ever applying for leave to appeal or for leave to appeal as cross-appellants. GCR 1963, 853. Accordingly, we would not entertain these questions.
V
We would reverse the judgment of the Court of Appeals in Apportionment of Wayne County Board of Comm’rs—1982. We would affirm in part and reverse in part the judgment of the Court of Appeals in Apportionment of Ingham County Board of Comm’rs—1982.
*297Williams and Ryan, JJ., concurred with Blair Moody, Jr., J.Const 1963, art 7, § 7:
"A board of supervisors shall be established in each organized county consisting of one member from each organized township and such representation from cities as provided by law.”
US Const, Am XIV.
1 Official Record, Constitutional Convention 1961, pp 942-952.
1966 PA 261, § 4 as amended:
"In apportioning the county into commissioner districts, the county apportionment commission shall be governed by the following guidelines in the stated order of importance:
"(a) All districts shall be single-member districts and as nearly of equal population as is practicable. The latest official published figures of the United States official census shall be used in this determination, except that in cases requiring division of official census units to meet the population standard, an actual population count may be used to make such division. Other governmental census figures of total population may be used if taken subsequent to the last decennial United States census and the United States census figures are not adequate for the purposes of this act. The secretary of state shall furnish the latest official published figures to the county apportionment commissions forthwith upon this act taking effect, and within 15 days after publication of subsequent United States official census figures.
“A contract may be entered into with the United States census bureau to make any special census if the latest United States decennial census figures are not adequate.
"(b) All districts shall be contiguous.
"(c) All districts shall be as compact and of as nearly square shape as is practicable, depending on the geography of the county area involved.
"(d) No township or part thereof shall be combined with any city or part thereof for a single district, unless such combination is needed to meet the population standard.
"(e) Townships, villages and cities shall be divided only if necessary to meet the population standard.
"(f) Precincts shall be divided only if necessary to meet the population standard.
"(g) Residents of state institutions who cannot by law register in the county as electors shall be excluded from any consideration of representation.
"(h) Districts shall not be drawn to effect partisan political advantage.” MCL 46.404; MSA 5.359(4).
1966 PA 293, § 14, as amended:
"A county charter adopted under the provisions of this act shall provide for all of the following:
"(b) * * * The charter shall also provide for the partisan election of members of the legislative body from single member districts to be *272established by the county apportionment commission as created in section 5 and pursuant to the standards and guidelines established in section 5(2), (4), (5), (6), (7), and (8) for reapportionment based upon the last official federal decennial census, effective at the first regular general election of the members of the legislative body occurring not less than 12 months after the completion and certification of the federal census. Each city and township shall be apportioned so that it has the largest possible number of complete districts within its boundaries before any part of the city or township is joined to territory outside the boundaries of the city or township to form a district.” MCL 45.514; MSA 5.302(14).
1966 PA 293, § 5, as amended:
"(2) The county apportionment commission, within 30 days after the adoption of the resolution by the county board of commissioners, shall establish Charter commission districts equal to the number of charter commissioners to be elected. All districts shall be single member districts and as equal in population as practicable. The latest official published figures of the United States official census shall be used in this determination, except that in cases requiring a division of official census units to meet the population standard, an actual population count may be used to make the division. Other governmental census figures of total population may be used if taken after the last decennial United States census and the United States census figures are not adequate for the purposes of this act. The secretary of state shall furnish the latest official published figures to the county apportionment commission * * * within 15 days after publication of subsequent United States official census figures. A contract may be entered into With the United States census bureau to conduct a special census if the latest United States decennial census figures are not adequate. Each district shall be contiguous, compact, and * * * as nearly square in shape as is practicable, depending on the geography of the county area involved, and shall be drawn without regard to partisan political advantage. Each city and township shall be apportioned so that it shall have the largest possible number of complete districts within its boundaries before any part of the city or township is joined to territory outside the boundaries of the city or township to form a district. Townships, villages, cities, and precincts shall be divided only if necessary to meet the population standard.” MCL 45.505; MSA 5.302(5).
1980 PA 7 changed "as nearly of equal population as practicable” to "as equal in population as practicable”. We express no opinion on the significance, if any, of this change.
After oral argument the parties in the WCAC case were asked to brief whether the apportionment of Wayne County was governed by § 2 or § 7 of article 7 of the Constitution of 1963 and by Act 293 or Act 261. The parties responded and agreed that Const 1963, art 7, § 7 and Act 261 applied. We would decline, given this situation, to apply Act 293. Cf. fn 35 of the per curiam opinion.
Const 1963, art 7, § 1:
"Each organized county shall be a body corporate with powers and immunities provided by law.”
Const 1963, art 7, § 2:
"Any county may frame, adopt, amend or repeal a county charter in a manner and with powers and limitations to be provided by general law, which shall among other things provide for the election of a charter commission. The law' may permit the organization of county government in form different from that set forth in this constitution and shall limit the rate of ad valorem property taxation for county purposes, and restrict the powers of charter counties to borrow money and contract debts. Each charter county is hereby granted power to levy' other taxes for county purposes subject to limitations and prohibitions set forth in this constitution or law. Subject to law, a county charter may authorize, the county through its regularly constituted authority to adopt resolutions and ordinances relating to its concerns.
"The board of supervisors by a majority vote of its members may, and upon petition of five percent of the electors shall, place upon the ballot the question of electing a commission to frame a charter.
"No county charter shall be adopted, amended or repealed Until approved by a majority of electors voting on the question.”
Apparently all that remains after In re Apportionment of State Legislature—1982, supra, in art 4, §§ 2-6 are the non-apportionment requirements of single-member districts, duties of election for senators, numbers of representatives and senators, and perhaps § 4 relating to annexations and mergers between apportionments and § 5 which concerns contiguity of islands.
It is certainly not clear that the Equal Protection Clauses of the Michigan Constitution have no relevance in the instant case. Compare Brouwer v Kent, 377 Mich 660 (Justice Souris, for affirmance), discussing Const 1963, art 1, §§ 1 and 2 with the discussion in the last two paragraphs of Part IIIC of the opinion of our colleagues. This issue need not be considered.
But see fn 14.
MCL 45.505(1); MSA 5.302(5)(1), MCL 46.403(1); MSA 5.359(3)(1).
Home Rule Charter for Wayne County, Article 8.119.
See the discussion in fn 4.
See fn 4 for the text of the statute.
In In re Apportionment of State Legislature—1982, 413 Mich 134; 321 NW2d 580 (1982), we stated:
"e) An election district, circumscribed by a circle, containing the least land area (excluding land outside of this state or under the Great Lakes) outside of the district, is the most compact.”
1982 PA 2 added a requirement that "[i]n the second year following each federal census, precincts shall be divided pursuant to this subsection”. MCL 168.661(3); MSA 6.1661(3). The inviolability of precincts under Act 261 is thus reduced.