(for affirmance). In 1969, the Michigan Legislature enacted 1969 PA 312, an act to provide for the compulsory interest arbitration of municipal police and fire department disputes. MCL 423.231 et seq.; MSA 17.455(31) et seq. The purpose and intent of the act is described in § 1:
"It is the public policy of this state that in public police and fire departments, where the right of employees to strike is by law prohibited, it is requisite to the high morale of such employees and the efficient operation of such departments to afford an alternate, expeditious, effective and binding procedure for the resolution of disputes, and to that end the provisions of this act, *433providing for compulsory arbitration, shall be liberally construed.” MCL 423.231; MSA 17.455(31).
This case involves two major issues: (1) whether 1969 PA 312, as amended, includes an unconstitutional delegation of "legislative and political responsibility to politically unaccountable arbitrators”, to use the words of the plaintiff City of Detroit; and (2) whether the arbitration panel’s award was supported by "competent, material and substantial evidence on the whole record” as required by § 12 of Act 312, MCL 423.242; MSA 17.455(42), as well as Const 1963, art 6, § 28.
The first issue has been inconclusively considered by four Justices of this equally-divided Court in Dearborn Fire Fighters v Dearborn, 394 Mich 229; 231 NW2d 226 (1975), where pre-amendment Act 312 was assessed. All four Justices found that there existed sufficient standards to guide the exercise of delegated authority. Beyond this consensus, however, one Justice would hold the preamendment act constitutional on the facts with relation to public accountability where the impartial chairperson of the arbitration panel was appointed by the Michigan Employment Relations Commission ("MERC”) chairperson, but indicated that the act was of doubtful constitutionality in that instance where the panel chairperson was alternatively selected by the parties’ delegates alone. Two Justices would hold the act unconstitutional because both the method of panel member selection and tenure of the panel chairperson did not provide sufficient political responsibility and accountability. Another Justice would hold the act constitutional in all respects.
Subsequent and responsive to the Dearborn opinion, the Legislature significantly amended Act 312 by providing for the composition of an arbitra*434tion panel including a representative of each party plus an impartial chairperson selected by MERC from a permanent panel established by MERC and known as the MERC Panel of Arbitrators.1 Eligibility for this permanent panel is restricted to impartial, competent and reputable United States citizens, who must be residents of Michigan. Members of the panel must subscribe an oath or affirmation of office. The term of these panelists is *435indeterminate and they are subject to removal without cause by the MERC. Such persons are appointed to this panel by the MERC Commissioners who are, in turn, direct appointees of the Governor with the advice and consent of the state Senate.
The first question before us, then, is whether a delegation, accompanied by otherwise sufficient standards, to such an arbitration panel as provided in Act 312, as amended, is constitutional.
The second issue raises the question whether the arbitration panel’s award as to the economic issue of cost of living allowance ("COLA”) and wages and as to the non-economic issue of a residency hardship exemption was supported by competent, material and substantial evidence on the whole record. More specifically, as to the economic issue, we must answer the threshold question whether the city’s last best offer of elimination of the already existing police officers’ cost of living program plus wage increases over a three-year period of 4.8%, 4% and 4% more nearly complied with the applicable legislative standards than did the defendant Detroit Police Officers Association’s ("DPOA”) last best offer of continuation of the already existing cost of living program and the somewhat lower wage increases of 4.5%, 4% and 3.5% over a three-year period. As to the non-economic award of a residency hardship exemption, we must determine the threshold question whether that award was based on the applicable legislative standards.
Since the Dearborn decision, similar schemes have been enacted in many jurisdictions,2 upheld *436as constitutional by the overwhelming weight of authority,3 and stamped by many with the imprimatur of success in averting critical-service strikes.4 Guided by this ample judicial and schol*437arly authority, we are compelled to conclude that 1969 PA 312, as significantly amended by 1976 PA 84, is constitutional in all respects.5 Furthermore, after careful review of the record and its relationship to the act’s § 9 factors, MCL 423.239; MSA 17.455(39), relative to both economic and non-economic issues, and mindful of the statutorily prescribed standard of judicial review codified in § 12, we hold that the arbitration panel’s economic award must also be upheld, whereas the record does not sustain the panel’s non-economic award as to the residency hardship exemption. Interest is denied. The lower court is affirmed except as to the residency hardship exemption.
I. Facts
The city and the DPOA, the certified bargaining *438agent of the police officers of Detroit, reached an impasse in 1977 on several of the terms and conditions of employment in bargaining for a new contract. Thereafter, upon demand of the DPOA, the MERC appointed an arbitration panel pursuant to 1969 PA 312, as amended ("act” or "Act 312”); the unsettled issues remaining between the parties were submitted to that panel for binding arbitration. After some 15 hearings before this panel, plus oral arguments by the parties, conducted over a period of eight months, the panel issued its award on December 20, 1978.
In essence, the panel majority6 accepted the city’s "last offer of settlement”7 as to all disputed economic issues except its COLA and wage proposals.8 On these two items, the DPOA’s last offers — a preservation of the parties’ previous COLA arrangement and a lower three-year wage increase than that proposed by the city — were adopted by the panel.9 As to the non-economic issues, most were settled, withdrawn or remanded to the par*439ties.10 One of the remanded issues involved the prior contractual provision that all city police officers be residents of the City of Detroit. The city had won this provision in the parties’ previous *440contract through the award of another Act 312 arbitration panel (Platt panel) issued September 5, 1977. Although the present panel upheld the city’s position that the residency provision be maintained, it ruled for the DPOA that some provision should be made for the exercise of reasonable discretion by either the mayor or a city official designated by the mayor to exempt persons with hardship circumstances. Accordingly, the panel remanded this narrow issue to the parties with the instruction that should they be unable to resolve the matter themselves within 30 days of the issuance of the award, the panel would do so.
Shortly after the issuance of this arbitration panel’s December 20, 1978 award, this matter began its complicated procedural course in our courts. On January 9, 1979, the city filed suit in the circuit court for Wayne County seeking judicial review of the arbitration panel’s award. Initially, the city sought review of the award limited to those portions which dealt with COLA, wages and the residency hardship exemption. Thereafter, the city filed the first of two amended complaints, the first one raising the issue of Act 312’s constitutionality. Meanwhile, both the DPOA and the Detroit Fire Fighters Association ("DFFA”), which had been allowed to intervene by stipulation of the parties, filed counterclaims seeking enforcement of the panel’s December 20, 1978 award and the payment of interest on the economic awards from the time of their issuance.
The circuit court initially declined to either stay the proceeding as requested by the city or to order immediate city compliance with the arbitration award as requested by both the DPOA and the DFFA. On February 13, 1979, however, the circuit court issued an opinion pendente lite which or*441dered enforcement of the panel’s award in its entirety pending that court’s complete review of the panel’s decision and order. The reasons given by the trial court in its interlocutory opinion ordering enforcement of the arbitration panel’s award were threefold:
"(1) The public policy underlying and expressed in Act 312 encourages immediate enforcement under the circumstances present in this case;
"(2) The city is not likely to prevail in the proceedings for judicial review [the court had earlier stated that the order of the panel seemed to be supported by competent, material and substantial evidence on the whole record]; and
"(3) The DPOA and DFFA [Detroit Fire Fighters Association] make a somewhat stronger showing than the city on the issue of irreparable or disproportionate injury.”
In an addendum to its opinion, also dated February 13, 1979, the trial court found no reason to alter its order of enforcement despite the city’s first amended complaint challenging the act’s constitutionality. The trial court reasoned, inter alia, that: every statute enacted by the Legislature is presumed constitutional; the presumed constitutionality of Act 312 was left unaltered by our equally divided decision in Dearborn Fire Fighters v Dearborn, supra, which affirmed the Court of Appeals ruling of constitutionality; and, the weight of national authority favored the constitutionality of compulsory arbitration statutes in public labor disputes.
The city appealed the trial court’s interlocutory order to the Court of Appeals. On February 26, 1979, that Court applied the "clearly erroneous” standard to uphold the trial court’s order of immediate enforcement. The ruling was made applicable *442to the period commencing January 1, 197911 and continuing until completion of either the trial court’s review or until further order of the Court of Appeals. As to the award period commencing July 1, 1977 (the date on which the previous contract between the city and the DPOA had expired) and ending December 31, 1978, the Court of Appeals stayed enforcement of the arbitration award until the trial court should enter final judgment. On July 5, 1979, we denied the city’s emergency application for leave to appeal from this decision.
Thereafter, acting pursuant to the DPOA’s and DFFA’s motions seeking dismissal of the city’s complaint and an order of enforcement, the trial court, on April 6, 1979, remanded the residency hardship exemption issue to the arbitration panel for completion of its award. This was done because the parties had failed to reach agreement on this issue pursuant to the panel’s remand order. In response to the trial court remand, the panel issued a supplemental opinion and award on May 21, 1979. This award granted the DPOA’s minimum request of a hardship exemption to the residency requirement as contemplated in the panel’s original December 20, 1978 opinion. That award was supplemented, however, with an additional grievance procedure , provision, including final and binding arbitration, to contest the grant or denial of such an exemption. The city’s delegate to the panel dissented to the inclusion of this grievance procedure, while the city itself filed a second amended complaint based on this same provision, claiming that the supplemental award was invalid.
*443On June 29, 1979, the DPOA and the DFFA again sought to dismiss the city’s complaint and enforce the arbitration panel’s award. However, the circuit court again denied these motions and sua sponte remanded the hardship exemption issue to the panel for findings relating its May 21, 1979 supplemental award to the applicable factors of § 9 of Act 312. In its opinion on remand dated August 8, 1979, the panel found its supplemental award on the residency hardship exemption to have met the applicable § 9 factors. The panel also concluded that the use of grievance arbitration as a terminal provision in the resolution of individual hardship cases was proper.
In response to the arbitration panel’s opinion on remand of the residency issue, the DPOA and the DFFA again filed motions for enforcement of the panel’s award. Accordingly, on August 31, 1979, the circuit court issued a final order enforcing the panel’s award in its entirety and holding the city’s complaints to be without merit. In doing so, the trial court relied on the reasoning found in its pendente lite opinion of February 13, 1979. In this final order the trial court also denied the DPOA’s and DFFA’s prayer for interest. Shortly thereafter, the city filed a motion for a stay of proceedings with the Court of Appeals in conjunction with its appeal of the trial court’s order granting the motion for enforcement of the entire award. The DPOA and DFFA cross-appealed on the trial court’s ruling which denied interest.
By a 2-to-l order dated October 5, 1979, the Court of Appeals denied the city’s motion for a stay of proceedings and ordered the award enforced in its entirety. This order included the July 1, 1977 to December 31, 1978 retroactive period which the Court of Appeals had earlier exempted *444from its enforcement order of the trial court’s pendente lite decision; one judge would have continued the stay as to the retroactive period. The Court of Appeals based its decision on the belief that: (1) the city was not likely to prevail on appeal; (2) a balancing of hardships favored immediate enforcement; and (3) the act had as its stated policy the provision of an "alternate, expeditious, effective and binding procedure for the resolution of disputes”, was to be liberally construed, and was subject to a statutorily limited scope of judicial review.
On November 8, 1979, this Court granted the city’s delayed application for leave to appeal prior to a Court of Appeals decision on the merits. We also granted the city’s motion to stay enforcement, pending appeal, of the arbitration award restricted to the retroactive period beginning July 1, 1977 . and ending December 31, 1978. 407 Mich 909 (1979). Oral arguments of the city, the DPOA, and the DFFA were heard by this Court on January 10, 1980.
II. Issues
Since our order granting leave to appeal simply requested the parties "to include among the issues to be briefed whether 1969 PA 312 is constitutional”, 407 Mich 909 (1979), we have framed the following general issues in accordance with our sense of the parties’ statement of the issues and their arguments:
(1) Whether 1969 PA 312, as amended, constitutes an invalid delegation of authority?12
*445(2) Whether 1969 PA 312, as amended, impermissibly usurps constitutionally vested home rule powers?
(3) Whether 1969 PA 312, as amended, unconstitutionally denies the right to cast effective ballots in municipal elections?
(4) Whether the instant panel’s award is unsupported by competent, material and substantial evidence on the whole record?13
*446(5) Whether interest should be permitted on the panel’s award?
For the reasons offered below, we resolve all five issues in the negative except that part of issue 4 re the panel’s residency hardship exemption, which we remand. Because issue 2 was definitively addressed and rejected in Dearborn by all four participating Justices, we will not consider the home rule argument further.14 Because issue 3 is without merit and has been universally rejected by other courts considering this equal protection challenge to similar binding arbitration schemes, we will likewise not consider this argument further.15
III. 1969 PA 312
A brief survey of Act 312, as amended, will be of assistance in understanding our rulings. *
*447 A. The Constitutional Background of 1969 PA 312, as Amended
Constitution 1963, art 4, § 48 replaced the former provision of Const 1908, art 16, § 7 for "courts of conciliation”. The contemporary provision reads as follows:
"The legislature may enact laws providing for the resolution of disputes concerning public employees, except those in the state classified civil service.”
The convention’s committee comment to art 4, § 48 stated the article’s purpose in the following terms:
"The purpose of this section is to make it clear that the legislature has power to establish procedures for settling disputes in public employment. This section does not say what the procedure should be, but leaves that decision up to future legislatures.” 2 Official Record, Constitutional Convention 1961, p 2337.16
*448Unlike the 1908 Constitution, therefore, art 4, § 48 did not specify the type of legislation which it authorized but posited wide discretion in the Legislature to establish those means and methods most effective for the accomplishment of the article’s objective.
A legislative response to the 1908 organic grant of authority was the 1947 enactment of the public employment relations act ("PERA”), MCL 423.201 et seq.; MSA 17.455(1) et seq.
Twenty-two years later, the Legislature enacted 1969 PA 312, a statutory scheme to provide for the compulsory interest arbitration of labor disputes in municipal police and fire departments, MCL 423.231 et seq.; MSA 17.455(31) et seq. The Legislature stated the act’s purpose as follows:
"It is the public policy of this state that in public police and fire departments, where the right of employees to strike is by law prohibited, it is requisite to the high morale of such employees and the efficient operation of such departments to afford an alternate, expeditious, effective and binding procedure for the resolution of disputes * * *.” MCL 423.231; MSA 17.455(31).
In considering the constitutional propriety of Act 312 prior to its critical amendments in 197217 and 1976,18 then-Justice, now-Chief Justice Cole*449man summarized the raison d’étre of the scheme:
"PERA procedurally requires the parties to meet at the bargaining table and confer in good faith with an open mind and a sincere desire to reach an agreement. It does not mandate agreement. If the parties fail to agree on one or more mandatory subjects, an 'impasse’ situation is reached and the employer may take unilateral action on an issue consistent with its final offer to the employees’ representative. The duty to bargain is then suspended until there is a change in the surrounding conditions or circumstances.
"In the private sector 'impasse’ often results in a strike. The employees refuse to accept the unilateral conditions imposed by the employer and withhold their services as a bargaining weapon. In the public sector strikes are prohibited but nevertheless occur. If the public employees do strike, the public employer may resort to the courts in order to return the labor situation to the status quo. By the time that court relief is obtained, however, the public may well have been left for a long period without the services and protection of the striking employees.
"When policemen engage in a strike, the community becomes immediately endangered by the withdrawal of their services. Likewise, our case law has often focused on the fact that fire fighters have a distinct and crucial employment relationship with a public employer.
"The Legislature, with knowledge of the vital character of police and fire services and with reference to the specific recommendations of the Governor’s Advisory Committee on Public Employee Relations (February, 1967) moved to foreclose strikes to police officers and fire fighters by enacting 1969 PA 312.” Dearborn, supra, 278-279 (opinion of Coleman, J.) (footnotes omitted).
There is and has been no question that pursuant to the broad discretionary grant of authority embodied in art 4, § 48, the Legislature may enact *450such supplementary labor schemes subject to other constitutional constraints. Indeed, this was made clear by each of the four Justices participating in Dearborn19 and is supported by a series of earlier decisions.20 However, it is on the topic of the application of such constitutional constraints to Act 312 that the parties differ. Before responding to these differences, a brief sketch of the act as amended will be of assistance in analyzing the scheme’s constitutional viability.
B. 1969 PA 312, as Amended
Act 312, as it read at the time of the Dearborn case, substantially resembles the amended statute except as to both the § 5 mechanism for appointment of arbitrators21 and the § 8 consideration of last offer economic issues.22 The following précis of the act’s present structure will, therefore, largely reflect the pre-amendatory as well as post-amendatory scheme except in those two significant respects.
As was earlier stated, the act has as its principal objective the provision of "an alternate, expeditious, effective and binding procedure for the reso*451lution of [interest] disputes”. MCL 423.231; MSA 17.455(31).
Act 312 seeks to accomplish this purpose through the development of a final and binding compulsory arbitration scheme emanating from the broad constitutional grant of discretionary authority in Const 1963, art 4, § 48. Attempting to constitutionally animate the act’s stated policy, the Legislature has provided through § 3 that, in those instances where the public employer and employee representatives have arrived at an impasse concerning a dispute other than a grievance, within 30 days of such dispute’s submission to a mediator, either party may initiate binding arbitration to avert a proscribed strike. MCL 423.233; MSA 17.455(33).23
Binding arbitration having been initiated, the following mechanism has been legislatively prescribed for the selection of three arbitration panel members. First, pursuant to § 4, the employer and employee are each required to select a single delegate to represent their respective interests on a three-member panel. MCL 423.234; MSA 17.455(34).
Next, § 5, as amended, clearly describes the important selection of the chairperson/third, public, member of the panel:
*452"(1) Within 7 days of a request from 1 or both parties, the employment relations commission shall select from its panel of arbitrators, as provided in subsection (2), 3 persons as nominees for impartial arbitrator or chairman of the arbitration panel. Within 5 days after the selection each party may peremptorily strike the name of 1 of the nominees. Within 7 days after this 5-day period, the commission shall designate 1 of the remaining nominees as the impartial arbitrator or chairman of the arbitration panel.
"(2) The employment relations commission shall establish and appoint a panel of arbitrators, who shall be known as the Michigan employment relations commission panel of arbitrators. The commission shall appoint members for indefinite terms. Members shall be impartial, competent, and reputable citizens of the United States and residents of the state, and shall qualify by taking and subscribing the constitutional oath or affirmation of office. The commission may at any time appoint additional members to the panel of arbitrators, and may remove existing members without cause.”24
Once the panel is composed, its action is bounded by both express time limitations and procedural guidelines. For instance, the panel is directed to commence its hearing within 15 days of impanelment and, unless otherwise agreed by the parties, to conclude its hearing within 30 days of commencement. MCL 423.236; MSA 17.455(36). Also, unless either otherwise agreed or in the event the dispute has been remanded for further bargaining subject to a three-week limitation, MCL 423.237a; MSA 17.455(37a),25 the Legislature has mandated rendition of a decision within 30 days of the hearing’s conclusion. MCL 423.238; *453MSA 17.455(38). Additionally, evidentiary guidelines are detailed — the onus, of course, being on the parties to introduce supporting evidence — MCL 423.236; MSA 17.455(36), subpoena power is imparted for the production of documents and the attendance of witnesses, MCL 423.237; MSA 17.455(37), and the panel is directed to make written findings of fact and to promulgate a written opinion and order upon the issues presented based upon the record developed by the parties. MCL 423.238; MSA 17.455(38).
Beyond these careful time limitations and evidentiary guidelines, the panel’s decisional authority has been significantly channeled by eight specific factors or standards listed in § 9. MCL 423.239; MSA 17.455(39). That section trenchantly circumscribes the arbitral tribunal’s inquiry to only those disputes involving "wage rates or other conditions” of employment embraced by a newly proposed or amended labor agreement, and commands the panel to "base its findings, opinions and order” relative to those narrow disputes on the eight listed "factors, as applicable”:
"Where there is no agreement between the parties, or where there is an agreement but the parties have begun negotiations or discussions looking to a new agreement or amendment of the existing agreement, and wage rates or other conditions of employment under the proposed new or amended agreement are in dispute, the arbitration panel shall base its findings, opinions and order upon the following factors, as applicable:
"(a) The lawful authority of the employer.
"(b) Stipulations of the parties.
"(c) The interests and welfare of the public and the financial ability of the unit of government to meet those costs.
"(d) Comparison of the wages, hours and conditions of *454employment of the employees involved in the arbitration proceeding with the wages, hours and conditions of employment of other employees performing similar services and with other employees generally:
"(i) In public employment in comparable communities.
"(ii) In private employment in comparable communities.
"(e) The average consumer prices for goods and services, commonly known as the cost of living.
"(f) The overall compensation presently received by the employees, including direct wage compensation, vacations, holidays and other excused time, insurance and pensions, medical and hospitalization benefits, the continuity and stability of employment, and all other benefits received.
"(g) Changes in any of the foregoing circumstances during the pendency of the arbitration proceedings.
"(h) Such other factors, not confined to the foregoing, which are normally or traditionally taken into consideration in the determination of wages, hours and conditions of employment through voluntary collective bargaining, mediation, fact-finding, arbitration or otherwise between the parties, in the public service or in private employment.” See MCL 423.238; MSA 17.455(38).
Perhaps of interest here is that among the standards listed are two interacting legislative directives: first, that the panel invest its deliberations with. specific contemplation of the public welfare, both as a distinct inquiry as well as an inexorable adjunct of the governmental unit’s financial ability to sustain the proposed costs; and, second, that the tribunal consider comparable public- and private-sector wages, hours and conditions of employment.
The panel’s decisional authority is further restricted by § 8, as significantly amended by 1972 PA 127, to provide for last-offer arbitration of *455economic issues subject to the factors enunciated in § 9.26 Section 8 provides in pertinent part:
"As to each economic issue, the arbitration panel *456shall adopt the last offer of settlement which, in the opinion of the arbitration panel, more nearly complies with the applicable factors prescribed in section 9. The findings, opinions and order as to all other issues shall be based upon the applicable factors prescribed in section 9.” MCL 423.238; MSA 17.455(38).
Significantly, the conjunction of the § 9 factors with the panel’s consideration of both economic and non-economic issues, therefore, further circumscribes the panel’s scope of decisional authority.
Finally, the Legislature has made specific provision for appellate review of such limited orders of the panel as to both economic and non-economic issues. Thus, although the tribunal’s order "shall be final and binding upon the parties”, MCL 423.240; MSA 17.455(40), that decision
"shall be reviewable * * * for reasons that the arbitration panel was without or exceeded its jurisdiction; the order is unsupported by competent, material and substantial evidence on the whole record;[27] or the order was procured by fraud, collusion or other similar and unlawful means.” MCL 423.242; MSA 17.455(42).28
*457IV. Proper/Improper Delegation to Politically Unaccountable Arbitrators?
Plaintiff city has framed the first of its major arguments in the following terms:
"1969 PA 312, insofar as it provides for compulsory arbitration, violates the United States Constitution and the Constitution of the State of Michigan by improperly delegating legislative and political responsibility to politically unaccountable arbitrators.”
As a matter of procedure in addressing ourselves to this argument as posited by the city, let us analyze the constitutionality of the Act 312 delegation scheme first without, and then in conjunction with, consideration of the city’s point of political accountability.
*458 A. Constitutionality of Delegation Generally: Act 312 Standards Are as Reasonably Precise as the Subject Matter Requires or Permits
The Michigan doctrine of delegation was succinctly stated by this Court in Osius v St Clair Shores, 344 Mich 693, 698; 75 NW2d 25 (1956), in terms of the following "standards” test:29
"There is no doubt that a legislative body may not delegate to another its lawmaking powers. It must promulgate, not abdicate. This is not to say, however, that a subordinate body or official may not be clothed with the authority to say when the law shall operate, or as to whom, or upon what occasion, provided, however, that the standards prescribed for guidance are as rea*459sonably precise as the subject matter requires or permits. ”30 (Emphasis supplied.)
*460Factually addressing the adequacy of Act 312’s legislatively prescribed standards, we need only highlight our précis of Act 312’s provisions in Part III, B, supra, that Act 312: specifically enunciates its guiding purpose, MCL 423.231; defines the parties to whom it is and is not applicable, MCL 423.232; establishes specific time limits circumscribing arbitral initiation and resolution, MCL 423.233, 423.236 and 423.238; provides a detailed procedure for both the appointment and removal of a permanent MERC panel of potential chairpersons as well as for the selection of the arbitration panel’s representative delegates and public chairperson, MCL 423.234 and 423.235; formulates procedural guidelines relative to the arbitral hearing and remand, MCL 423.236, 423.237 and 423.237a; narrowly channels the panel’s scope of decisional authority to eight specific factors in its review of last-offer economic issues, MCL 423.238 and 423.239; mandates the application of eight specific factors in rendering a finding, opinion and order relative to both economic and non-economic issues, MCL 423.238 and 423.239; and details the effect of an arbitral decision subject to the availability of judicial review, MCL 423.240 and 423.242.
*461It is generally acknowledged that the instant and similar statutory schemes are directed toward the resolution of complex contractual problems which are as disparate as the towns and cities comprising the locations for these critical-service labor disputes.31 The Legislature, through Act 312, has sought to address this complicated subject through the promulgation of express and detailed standards to guide the arbitrators’ decisional operations.32
We must conclude that the eight factors expressly listed in § 9 of the act provide standards at least as, if not more than as, "reasonably precise as the subject matter requires or permits” in effectuating the act’s stated purpose "to afford an alternate, expeditious, effective and binding procedure for the resolution of disputes”. MCL 423.231; MSA 17.455(31). These standards must be considered by the panel in its review of both economic and non-economic issues. In its resolution of non-economic issues, the panel "shall base its findings, opinions and order upon the following factors, as applicable”, MCL 423.239; MSA 17.455(39) (emphasis supplied). See MCL 423.238; MSA 17.455(38), *462"The findings, opinions and order as to all other issues [i.e., non-economic issues] shall be based upon the applicable factors prescribed in section 9.” (Emphasis supplied.) When these eight specific § 9 factors are coupled with the § 8 mandate that "[a]s to each economic issue, the arbitration panel shall adopt the last offer of settlement which, in the opinion of the arbitration panel, more nearly complies with the applicable factors prescribed in section 9”, MCL 423.238; MSA 17.455(38) (emphasis supplied), the sufficiency of these standards is even more patent.33
Four Justices of this Court have already, in Dearborn, individually recognized that Act 312 provides sufficient standards to guide the exercise of delegated authority.34 In Dearborn, each of the four participating Justices agreed to this proposi*463tion even before the § 9 factors had become operative to both non-economic and § 8 last offer economic issues alike.35 As Justice Levin remarked in this regard: "All that is generally required has been done.” Dearborn, supra, 259 (opinion of Levin, J.).
Applying the Osius explication of the delegation doctrine, all that is required to constitutionally sustain this dispute resolution mechanism is that the statutory scheme provide standards at least as reasonably precise as the subject matter requires or permits. We have found that the standards embraced by the § 9 factors fulfill this requirement. The Legislature has determined that these express and detailed § 9 standards must be considered in the panel’s resolution of economic "last best offer” issues as well as non-economic issues alike. Although the Legislature has chosen to provide for the resolution of economic issues on a last offer of settlement basis expressly circumscribed by the applicable § 9 standards in an apparent attempt to effectuate the act’s § 1 purpose of "afford[ing] an alternate, expeditious, effective and binding procedure for the resolution of disputes”, we do not believe that either the presence or absence of this last best offer provision is necessary to the act’s constitutionality under the dictates of the delegation doctrine or otherwise.36 *464However, we are unaware of any court which has declared a similar critical-service act unconstitutional on the basis of the inclusion of such an economic issue provision but can point to two cases which have considered last-best offer settlement and have willingly sustained their act’s constitutionality provided sufficient standards are enumerated to focus arbitral decision-making.37
In reaching this conclusion, we are also persuaded by the fact that the Act 312 standards are patently more precise than those which this and other courts have previously upheld under similar modes of delegation analysis and involving subject matters at least as complex as that considered here.38 Other jurisdictions have sanctioned their compulsory interest arbitration schemes even *465though presented with less precise39 or even non-explicit standards for decision.40 Furthermore, in two cases where standards identical to those codified in Act 312 were subjected to judicial scrutiny, their sufficiency was upheld.41 Also, in another case *466where the prescribed standards were found insufficient, the court expressly indicated that its decision would have been otherwise had the Legislature modeled its standards after those found in Michigan’s Act 312.42
B. Public Accountability
We have just made clear that Act 312 meets the constitutional delegation requirements as framed in Osius without directly considering the city’s question of "political responsibility”. Does, however, the theory of public accountability nonetheless require us to rule Act 312, as amended, unconstitutional? For the reasons offered below, we conclude not. Indeed, since we find as a practical matter that the act as now amended sufficiently provides for public responsibility and accountability, this Court in this matter is neither required to accept nor reject the city’s argument that political responsibility is necessary to sustain the act’s constitutionality separate and apart from the overall question of constitutional delegation.
In Dearborn, lack of political, or public, accountability was basically approached from two view*467points. First, individuals chosen as arbitrators were thought by two Justices to have been provided insufficient tenure to ensure responsibility and accountability. Then-Chief Justice T. G. Kavanagh referred, for example, to pre-amendment Act 312 arbitrators as "hit-and-run arbitrators”. Dearborn, supra, 273 (opinion of T. G. Kavanagh, C.J.).43 Second, the system of arbitrator selection was attacked as rendering the line of accountability between the arbitrators and the people too tenuous.44 One opinion indicated that choice of the panel’s impartial chairperson by the parties’ delegates alone would provide insufficient public accountability even though one party represented a municipal corporation; appointment of that impartial arbitrator by the MERC chairperson, however, provided sufficient public accountability and responsibility largely because the MERC chairperson *468was the Governor’s direct appointee with the advice and consent of the Michigan Senate.45 It was also recognized that there existed an inherent tension, if not dichotomy, in the twin objectives of affording the arbitrators a high degree of independence on the one hand, and, on the other, requiring public accountability and responsibility.46
1976 PA 84 significantly modified the Act 312 scheme addressed in Dearborn both as to the § 5 tenure of the impartial chairperson and as to the § 5 method of the chairperson’s selection.47
1. Tenure of the Impartial Chairperson
As to the tenure of the impartial chairperson, the Legislature responded to the "hit-and-run” characterization of Act 312 arbitrators by significantly modifying § 5 of the original act in four major respects. First, eligibility for and MERC appointment as panel chairperson is now restricted to MERC-appointed members of a MERCestablished permanent panel — "the Michigan Employment Relations Commission Panel of Arbitrators” — whereas, before, any "impartial, competent and reputable person” might be selected by either the delegates or the chairperson of the State Labor Mediation Board to fulfill this role. Second, members of the MERC-established and -appointed permanent panel now not only have to be "impartial, competent, and reputable citizens of the United States” but must also be "residents of the state” of Michigan; this latter requirement was absent from the earlier act’s express terms. Third, permanent panelists must "qualify by taking and subscribing *469the constitutional oath or affirmation of office”, whereas neither an oath nor an affirmation had been previously required. Fourth, the term of office on the MERC Panel of Arbitrators is indeterminate; tenure can either run as long as a panelist chooses — for that matter, for life — or the panelist may be removed without cause by the MERC.
The four modifications wrought by the 1976 PA 84 amendments to § 5 have greatly altered the atmosphere of accountability surrounding the service of arbitration panel chairpersons. In the first place, the chairperson is no longer treated as an at-large one-time chair of a single and particular labor dispute panel. Rather, the chairperson is treated as a member of a permanent MERC Panel of Arbitrators who can be called upon by MERC, as appropriate, to serve as panel chairperson for any number of labor disputes.48 This obviously paints out the picture of a "hit-and-run arbitrator” who is allegedly unconcerned about the impact of his or her decision, and paints in the true picture of an arbitrator seeking continued employment by both MERC and public employers/employees over a length of time, and consequently recognizing the impact of his or her decisions as a significant factor in re-employment.49
*470Second, since members of the MERC Panel of Arbitrators must be "residents of the state”, the panelist cannot escape the impact of his or her decision by retreating to a foreign jurisdiction but will be required to bear its impact on his or her reputation and credibility for arbitral employment in Michigan where continued employment is sought.50 This too militates against a "hit-and-run” mentality.
Third, the oath-taking requirement certainly imposes an aura of tenure.51 It is an aspect of public office and responsibility. This requirement should act as both a psychological deterrent to "hit-and-run” service and an encouragement to public responsibility.
Fourth, the indeterminate term on the permanent panel, although terminable without cause, certainly implies a degree of tenure and continuation. It also implies the importance of continued responsible behavior. This is so especially because obviously irresponsible behavior can terminate tenure.52 Again, this tenure provision encourages accountability and responsibility.
Considered collectively, the aforementioned factors tend to eradicate the image of "hit-and-run arbitrators” and act as a catalyst to the establishment of a class of arbitrators possessing both the aspects of tenure and responsibility which are certainly compatible with the notion of political or public accountability. This complexion of political responsibility and accountability has been further magnified by the 1976 PA 84 intensification of selection responsibility in a traditionally politi*471cally accountable center of authority, i.e., MERC Commissioners who are direct appointees of the Governor subject to Senate confirmation.53
2. Method of Chairperson Selection
Under § 5, as originally enacted, the chairperson selection system alternatively permitted either appointment by the parties’ delegates alone or, in the event of their default, appointment by the MERC chairperson.
Obviously, there was very little political accountability in the first alternative as that approach shielded the private selectors from both public scrutiny and the democratic form of government’s greatest sanction — the vote. The line of political accountability drawn between the private representatives and the public was very far from direct.
The second alternative, however, presented quite a different accountability perspective since that alternative required MERC intervention in the selection process. By appointing the panel chairperson, it could be presumed that the MERC chairperson — a direct appointee of the Governor with the Senate’s advice and consent — would exercise great concern for the Governor’s political welfare as well as the chief executive officer’s concern for good public service. This alternative precluded isolation from the public process and cleared the way for direct public expressions of satisfaction or dissatisfaction to those individuals ultimately responsible for the panel members’ decisions.
The present § 5 selection system, as amended by 1976 PA 84, has eliminated the minimally accountable first alternative of delegate selection and expressly retained the second alternative’s *472spirit of public accountability through its provision for MERC selection of a chairperson from a MERC-appointed permanent panel. Albeit tempered by the parties’ right of exercising a peremptory veto,54 § 5 focuses the power of chairperson appointment in the commission alone to the exclusion of either the parties’ delegates or the MERC chairperson as earlier provided. Furthermore, the MERC appointee is no longer chosen at large but must have been earlier screened by, appointed to, and selected from a permanent panel of MERC arbitrators established by the commission, a gubernatorial^ appointed body.
Considered together, these significant amendments fix a high order of political accountability in the chairperson appointment scheme. Indeed, the majority of jurisdictions which have considered this question have found accountability;55 those *474which have ruled otherwise have done so primarily on the basis of distinguishable constitutional provisions.56 Little interference exists in that line *475of public accountability connecting the Governor, MERC, the panel chairperson and the MERC permanent Panel of Arbitrators. Should the appointees "give away the store” or otherwise invite unfavorable comment,57 the electorate may easily express dissatisfaction by directing complaints to the Governor as well as the gubernatorially appointed MERC Commissioners. These complaints may ultimately be couched in the democratic form of government’s greatest sanction — the vote.
The city’s argument that political accountability is absent since the MERC Commissioners and panel members are not directly accountable to the people of the specific community over which arbitral authority is exercised proves entirely too much.58 Read carefully, the city’s principal objec*476tion to Act 312 is really directed at the underlying legislative wisdom of formulating a state-wide pol*477icy governing resolution of inherently local public-sector labor disputes. Thus, the city claims that the relationship of the Act 312 panel — including the MERC appointed chair — to the City of Detroit electorate is diluted by the §§ 4 and 5 panel selection process.
This argument blinks the reality that the role of both the Act 312 arbitrators and the MERC appointing authority is to effectuate a state labor policy as formulated by the state Legislature serving the state electorate. Work stoppages by municipal police and fire departments, although primarily local in situs, were legislatively deemed to pose a threat to the state’s public health, safety and welfare. Should the people be dissatisfied with the accountability aspect of the engineered scheme which must necessarily transcend local boundaries, the onus is upon the state’s electorate, including the locally affected voting population, to exercise its political will.
3. Inherent Tension Between Independence and Accountability
Inherent in the Act 312 scheme, as well as such delegation schemes in general, is the tension, if not apparent dichotomy, between the act’s dual objective of affording arbitrators sufficient decisional independence to resolve complex disputes on the one hand, and, on the other, maintaining public responsibility and accountability of those arbitrators.59 Indeed, since the act specifically seeks to speedily resolve complex contractual impasses in the dynamic critical-service public labor sector, this tension is especially and necessarily enhanced *478by the scheme’s need to allow flexibility in the resolution of those disputes.
However, we find that these inevitable tensions have been adequately balanced in view of the act’s provision for standards, the extremely public atmosphere in which the Act 312 mechanism operates, and the § 12 provision for judicial review.
As we have seen, operational flexibility has been successfully maintained within the context of legislatively prescribed standards both to check unfettered exercise of arbitral authority and to provide the arbitrators with guideposts of decisional consideration which have been deemed significant by the people through their representatives. Although the panel operates with a certain degree of independence in fashioning economic as well as non-economic awards, its exercise is significantly guided by a well-articulated series of standards for resolving those previously negotiated and sharpened, yet unresolved, matters.
This tension between independence and accountability is further alleviated by the extremely public atmosphere in which the chairperson is appointed by MERC and the Act 312 panel operates. Indeed, the context in which the matter proceeds is one of high visibility and profound scrutiny, where publicity is sharply focused on both MERC’s selection and the panel’s deliberations. Such public attention undoubtedly enhances the accountability of both the appointers and the appointees. Since both bodies are the focal point of great public and political interest during this intense session of activity, any affront to either the legislative mandates or the public will would likely invite immediate and effective reaction. The twin facts that, first, permanent panelists do not serve for a fixed term but are removable at any time at the discre*479tion of the MERC and, second, seek continuing employment in this area of concern, presumably quicken the arbitrator’s awareness that statutory guidelines are to be closely heeded, thereby encouraging enhanced accountability.
Further balancing the exercise of arbitral independence is the act’s § 12 provision for judicial review. See Part V, A, for interdependence of §§ 8 and 9 requirements with § 12. This section resembles the Const 1963, art 6, § 28 provision for review of administrative orders60 which is more expansive than the restrictive court rule provision for the review of arbitral awards in general, GCR 1963, 769.9(1), which precludes judicial inquiry into the factual merits of an arbitrator’s resolution.61 As such, § 12 significantly incorporates all appropriate bases for review without either permitting expansive de novo litigation as some jurisdictions have provided62 — which would likely frustrate the binding and expeditious nature of the Act 312 concept — or, as in the case of GCR 1963, 769.9(1), so narrowly restricting the judiciary’s basis for review as to arguably shelter such significant arbitral decisions from judicial inquiry.63 The inclusion of similar provisions in other acts has likewise recommended their wisdom.64
*480Because Act 312, as amended, provides standards as reasonably precise as the subject matter requires or permits, Osius, supra, and since we find, as a practical matter, that the scheme exhibits adequate accountability, we find the amended act constitutional.
V. Review of the Arbitration Panel’s Award
Having ruled Act 312 constitutional, we turn our attention to the general question of whether the arbitration award should be enforced. In addressing this issue, we must be especially alert to follow the limited scope of judicial review expressly provided by § 12 of the act. That section, in relevant part, states:
"Orders of the arbitration panel shall be reviewable * * * only for reasons that the arbitration panel was without or exceeded its jurisdiction; the order is unsupported by competent, material and substantial evidence on the whole record; or the order was procured by fraud, collusion or other similar and unlawful means.” MCL 423.242; MSA 17.455(42).
As we have just noted, this section neither provides this Court with a license to consider the wisdom of an arbitration award nor to subject an award to de novo review. Dearborn, supra, 318. Rather, the Legislature having confined our scope of review in assessing compulsory, binding arbitration awards, we are statutorily bound to uphold an award if it meets the prescriptions of § 12.
The city claims that the arbitration panel re*481versibly erred in only three particulars: the panel’s ruling and award on wages, COLA, and the hardship exemption to the city’s requirement that all Detroit police officers be residents of Detroit. The main thrust of the city’s attack on the award as to these three items is twofold: (1) the award is violative of § 12 as "unsupported by competent, material and substantial evidence on the whole record”; and (2) the arbitration panel failed to comply with the requirements of §§ 8 and 9 in rendering its award. Except as to one facet of the panel’s residency hardship exemption award which will be discussed infra, fn 73, the city does not assert that the panel was without or exceeded its jurisdiction or that the order was procured by fraud, collusion or other similar and unlawful means.
However, before we may entertain these two central issues, we must dispose of two collateral issues.
A. The Contextual Interdependence of §§ 8, 9 and 12 of the Act: Judicial Review of the § 9 Factors
Preliminary to our consideration of the contested items of the award, it is necessary to stake out the perimeters of judicial review under § 12 of the. act. Close examination of the act, in light of the well-known rule of statutory construction that each section of an act is to be read with reference to every other section so as to produce a harmonious whole, see 2A Sutherland, Statutory Construction, § 46.05, p 56, leads us to conclude that §§ 8, 9 and 12 evidence a contextual interdependence that necessitates their joint consideration by a court sitting in review of an Act 312 arbitration panel’s award.
Section 12 specifically provides that an order of the arbitration panel shall be reviewable for the *482reason that it is unsupported by competent, material and substantial evidence on the whole record. To make such a review, however, we must of necessity have in mind the statutorily mandated requirements of such an order. Section 9 unequivocally directs that where "wage rates or other conditions of employment * * * are in dispute, the arbitration panel shall base its ñndings, opinions and order upon the following [eight listed] factors, as applicable” (emphasis supplied). Section 8 likewise directs the arbitration panel, in its determination of both economic and non-economic issues, to these same § 9 factors: "As to each economic issue, the arbitration panel shall adopt the last offer of settlement which, in the opinion of the arbitration panel, more nearly complies with the applicable factors prescribed in section 9. The findings, opinions and order as to all other issues shall be based upon the applicable factors prescribed in section 9.” It is patent therefore that these sections require the rendition of an ultimate award which is either "based” on the § 9 factors— in the case, of non-economic issues — or "more nearly complies with” the § 9 factors — in the case of economic issues governed by the last offer prescription. In effect then, any finding, opinion or order of the panel on any issue must emanate from a consideration of the eight listed § 9 factors as applicable.
In making an Act 312 disposition which must statutorily be "based upon” or "in compliance with” the § 9 factors as applicable, the Legislature has deemed such a disposition of the panel final and binding "if supported by competent, material and substantial evidence on the whole record”. MCL 423.240; MSA 17.455(40). Section 12 likewise provides that such final and binding determina*483tions or "[o]rders of the arbitration panel” shall be reviewable by the courts "only for reasons that * * * the order is unsupported by competent, material and substantial evidence on the whole record”. Construing §§ 9 and 12 together then, our review must find that the arbitration panel did indeed base its findings, opinion or order upon competent, material and substantial evidence relating to the applicable § 9 factors. Cf. Caso v Coffey, 41 NY2d 153, 158; 359 NE2d 683, 686 (1976). In other words, the order of the panel must reflect the applicable factors and the evidence establishing those factors must be competent, material and substantial evidence on the whole record. It is only through this judicial inquiry into a panel’s adherence to the applicable § 9 factors in fashioning its award that effectuation can be given to the legislative directive that such awards be substantiated by evidence of, and emanate from consideration of, the applicable § 9 factors.65
B. Relation of Economic and Non-Economic Issues to §9 Factors
One other matter of statutory interpretation needs to be addressed preliminary to our examination of the panel’s award. The city seems to argue that the act must be considered unconstitutional if the panel has the freedom to determine which of the § 9 factors are most applicable to a certain case. The apparent foundation for this argument is some perceived repugnance between the concept of assessing a statute’s constitutionality on the sufficiency of its standards to guide delegated author*484ity, while simultaneously allowing the recipient of this delegated authority the discretion to weight these standards within the context of a particular case.
We disagree with the city’s contention. The fact that an arbitral majority may not be persuaded by a party’s evidence and argument as to certain items does not mean that those arbitrators failed to give the statutory factors that consideration required by law. The Legislature has neither expressly nor implicitly evinced any intention in Act 312 that each factor in § 9 be accorded equal weight. Instead, the Legislature has made their treatment, where applicable, mandatory on the panel through the use of the word "shall” in §§ 8 and 9. In effect then, the § 9 factors provide a compulsory checklist to ensure that the arbitrators render an award only after taking into consideration those factors deemed relevant by the Legislature and codified in § 9. Since the § 9 factors are not intrinsically weighted, they cannot of themselves provide the arbitrators with an answer. It is the panel which must make the difficult decision of determining which particular factors are more important in resolving a contested issue under the singular facts of a case, although, of course, all "applicable” factors must be considered. Our comment in Midland Twp v State Boundary Comm, 401 Mich 641, 676; 259 NW2d 326 (1977), is here apposite.
"Merely because some criteria were factually inapplicable or were found by the commission to be of less importance than other criteria does not mean that the commission 'ignored’ relevant criteria. The commission may regard a particular criterion to be of decisive importance outweighing all other criteria.”
*485 C. The Economic Award is Supported by Competent, Material and Substantial Evidence on the Whole Record
At this juncture, our initial observation respecting our limited scope of review deserves quick reiteration. If a panel’s award is supported by competent, material and substantial evidence on the whole record, we are mandated to uphold it. As we noted in the analogous context of appellate review of a MERC finding:
"Such review must be undertaken with considerable sensitivity in order that the courts accord due deference to administrative expertise and not invade the province of exclusive administrative fact-finding by displacing an agency’s choice between two reasonably differing views. Cognizant of these concerns, the courts must walk the tightrope of duty which requires judges to provide the prescribed meaningful review.” Michigan Employment Relations Comm v Detroit Symphony Orchestra, Inc, 393 Mich 116, 124; 223 NW2d 283 (1974).
After having made a painstaking examination of the voluminous arbitration hearing record as well as the opinions (original and supplemental) and orders of the arbitration panel, the trial court and the Court of Appeals, we are satisfied that the instant arbitration award on the economic issues of COLA and wages is supported by competent, material and substantial evidence on the whole record.
The arbitration panel conducted some 15 hearings not including final arguments by the parties and wrote a 44-page opinion setting forth the basis of its award. In its original opinion on COLA and wages the panel carefully delineated specific evidence relating to each of the factors of § 9. Indeed, this opinion included a specific section devoted to *486an analysis of the § 9 factors with respect to the two contested economic items. As the trial court noted in its opinion pendente lite, which reasons were later adopted in its final order of enforcement, "[t]he Panel’s opinion is replete with specific findings related to the criteria of § 9 of the act and related, also, to the evidence in the case”.
1. A Review of the Panel’s Application of the § 9 Factors in Rendering Its Economic Award
However, in recognition of the importance of this case, and at the risk of being considered tedious, we have decided to briefly summarize on these pages the weightier evidence pertaining to the § 9 factors which was heard by the panel and formed the basis of its award. It is this evidence which compels our conclusion that the arbitration award respecting the economic issues of COLA and wages must be upheld.
As a framework to our consideration of the evidence in support of the panel’s disputed economic awards, some general observations merit voicing: We stress again that § 8 of the act requires the panel to choose one of the parties’ "last offer of settlement”. Thus while the panel is precluded from fashioning what it might consider a more equitable award or a compromise award, it is also prevented from independently shooting too high or too low. Further, it should be recognized that § 8 gives the arbitrators a not insignificant measure of discretion in adopting a particular last offer of settlement vis-á-vis the § 9 factors by providing that the last offer chosen by the panel shall be the one that "in the opinion of the arbitration panel, more nearly complies” with the "applicable” factors prescribed in § 9. We would also note that the economic issues of COLA and wages were inextricably related in this case, COLA being the *487item of paramount significance to both parties. Thus, because the city advocated the abolishment, or severe diminution,66 of the COLA arrangement won by the DPOA in its previous contract, its wage proposal was understandably higher than that of the DPOA. Conversely, because the DPOA requested the maintenance of the previous COLA provision, its wage proposal was more modest than that of the city. In recognition of this nexus, the panel discussed together the relationship of the COLA and wage proposals to the § 9 factors. Finally, it must also be recognized that evidence relating to the eight factors of § 9 is not completely segregable; evidence relevant to one factor will often be relevant to others, causing some measure of interdependence among the factors. However, each factor, if applicable, must still be given separate consideration by the panel.
Factor 1: The lawful authority of the employer.
Evidence on this factor centered on the city’s taxing powers. The panel acknowledged the city’s uncontradicted evidence that it was at the legal limit of its taxing powers. Although the panel explicitly recognized these limits on the lawful authority of the employer to tax in rendering its economic award, this factor was not considered conclusive in and of itself by the panel; rather it *488was simply a facet of the city’s basic contention that its ability to pay was limited.
Factor 2: Stipulations of the parties.
To this point, the panel expressly acknowledged its appreciation to the parties for stipulations on economic and non-economic matters which helped simplify or dispose of issues.
Factor 3: The interests and welfare of the public and the financial ability of the unit of government to meet those costs.
Respecting its financial capabilities, although the city specifically failed to present its budget or other evidence as to how the city spent its money, the city introduced evidence of a "limited” ability to pay any arbitral award. The city also introduced considerable evidence concerning the various strains on the city’s fiscal abilities due inter alia to a reduction in city population and the dependency of the city budget on state and federal revenues.
While recognizing such limitations on the city’s finances, the panel was acutely aware of the city’s explicit statement that it did not have an inability to pay an award. As an attorney for the city stated, "The city does not assert an inability to pay any additional sum as may be determined, but that its ability to pay has limits”.
The third factor juxtaposes the city’s ability to pay and the interests and welfare of the public. Respecting the public interest and welfare, the panel considered of major consequence the fact that the Detroit Police Lieutenants and Sergeants Association ("LSA”) had recently been awarded,67 *489in another Act 312 arbitration, a continuation of its previous COLA provision which was substantially the same as the DPOA’s last COLA offer in the instant case.68 In light of the fact that the DPOA and LSA enjoyed a strong historic relationship, a majority of the panel believed that a denial of COLA to the DPOA would imperil police morale and the effective performance of their services to the detriment of the public.
Factor 4: Comparison of the wages, hours and conditions of employment of the employees involved in the arbitration proceeding with the wages, hours and conditions of employment of other employees performing similar services and with other employees generally:
(i) In public employment in comparable communities.
(ii) In private employment in comparable communities.
With respect to this factor, the panel reviewed evidence comparing Detroit police officers’ salaries and fringe benefits to those of Detroit metropolitan area communities, as well as to large, out-of-state cities. The panel found the former the more appropriate, since not only is there a lack of comparability of conditions in other major cities, but it is *490against these nearby communities that Detroit must compete for police officers. The panel also relied on the recent LSA award for comparison since the LSA was the only other group of Detroit employees performing services similar to those of the DPOA. In short, the panel found the more apt and persuasive comparisons for purposes of this factor to be with other city security personnel, and not with other city employees in general. The panel did not consider comparisons with private employment persuasive and therefore did not base any of its conclusions upon such comparisons.
Factor 5: The average consumer prices for goods and services, commonly known as the cost of living.
The panel regarded as of importance testimony concerning the need for and use of a COLA provision as a not unusual means, in the public sector, of providing some protection to the real wage position, as well as the standard of living, of both wage and salary workers during inflationary periods. Thus the panel determined that with an expected increase in the cost of living from 6% to 8% a year during the three years of the new contract, the COLA requested by the DPOA would only afford 50% to 80% protection.
Factor 6: The overall compensation presently received by the employees, including direct wage compensation, vacations, holidays and other excused time, insurance and pensions, medical and hospitalization beneñts, the continuity and stability of employment, and all other beneñts received.
It was very significant to the panel that the DPOA’s last offer respecting COLA merely represented a continuation of the COLA provision that had been won by the DPOA in the collective bargaining agreement which expired at the end of *491June, 1977. In adopting the DPOA’s COLA proposal, the panel simply opted for a maintenance of the status quo regarding that provision.
Factor 7: Changes in any of the foregoing circumstances during the pendency of the arbitration proceedings.
The development of primary importance to the panel was the award in the LSA arbitration case handed down October 18, 1978 by the Howlett panel. As noted earlier, in relevant part this award granted the LSA a COLA provision essentially the same as that put forth in the DPOA’s last offer. The LSA award was of considerable importance to the instant panel in fashioning its own award since the panel was intent on maintaining the historic relationship between the compensation of police officers below the rank of sergeant and those above.
Factor 8: Such other factors, not conñned to the foregoing, which are normally or traditionally taken into consideration in the determination of wages, hours and conditions of employment through voluntary collective bargaining, mediation, fact-ñnding, arbitration or otherwise between the parties, in the public service or in private employment.
The panel noted that the parties had not specifically delineated in their presentations any "other factors”. Therefore, the only "other factor” which the panel relied on was morale. As noted under our discussion of the third factor, the panel believed that the maintenance of high police morale was an important factor to be considered in rendering its award.
Briefly summarizing the panel’s application of § 9 in rendering its award on the economic issues in dispute, the panel determined that the interests *492of the public in high police morale could more effectively be insured by a preservation of the previous COLA arrangements. Since the panel had adopted the city’s proposal that the contract run for three years, as opposed to the DPOA’s proposal of a two-year contract, the panel was persuaded of the necessity of such a COLA provision to maintain some partial shield against the unforeseeable erosion of an officer’s wage position by inflation that could occur over such an extended period. Also of concern to the panel in the maintenance of the COLA provision was the recognition of the DPOA’s relationship to the LSA. Central to this award was the city’s failure to plead or establish a position of inability to pay or to introduce its budget69 indicating what curtailment of services would be necessitated by the DPOA’s last COLA offer.
Given the fact that the wage issue was inextricably related to that of COLA, the panel, having opted for the COLA proposal of the DPOA, then chose the lower of the two wage proposals; it chose the DPOA’s proposed 4-1/2%, 4% and 3-1/2% wage increase in each of the three years of the contract as compared to the city’s proposed 4.8%, 4% and 4%70 wage increase in each of those same three years. While we recognize that the city’s *493wage proposal was higher than that of the DPOA due to the city’s lack of (or, in the case of its Plan II, a minor) COLA proposal, the fact remains that having accepted the DPOA COLA proposal, the panel then awarded the lower of the two wage proposals.
In light of the foregoing analysis, we find the panel’s award of the DPOA’s last offers on the contested economic items to have been supported by competent, material and substantial evidence on the whole record.
One final argument of the city remains to be discussed with respect to the arbitration panel’s economic award. The city asserts that the panel’s award should be vacated due to the panel’s refusal to admit into evidence City’s Exhibit 30. This exhibit was intended to show the cost impact of any award made by the instant panel on COLA and wages, relative to the DFFA and the LSA. In short, the city argued that such an award would affect the DFFA since the city had already agreed in another Act 312 arbitration proceeding to a parity agreement, respecting certain economic benefits, between the police officer and the fire fighter, the police sergeant and the fire lieutenant, and the police lieutenant and the fire captain. The effect on the lieutenant’s and sergeant’s bargaining unit inhered in the fact that the previous contract between the city and the LSA, as well as the proposed one before an Act 312 arbitration panel at the time Exhibit 30 was offered, provided that the lieutenant’s and sergeant’s pay would be a percentage of that of a police officer. The city’s argument, then, was that Exhibit 30 was relevant, as one piece of evidence under the third factor of § 9, to the extent that it illustrated the ramification of any COLA or wage award of the instant *494panel on total cost to the city on the total budget, and the ability of the city to pay.
At the time Exhibit 30 was offered, the chairman of the panel, per the parties’ pre-hearing statement, exercised his responsibility for ruling on evidentiary and procedural matters and declined to receive the exhibit. He did so on the grounds that its admission was premature since the Act 312 arbitration proceedings involving the fire fighters and the lieutenants and sergeants had not then been concluded.
Preliminarily, we stress that this Court is not constituted some "super-arbitrator” to oversee and redirect the arbitral process when our opinion may differ with a panel’s on such an evidentiary/procedural matter as this. Section 6 of the act explicitly accords a wide degree of latitude to the panel in the introduction of evidence. It is true that the "[technical rules of evidence” do not apply to the hearings; however, the panel "may” receive into evidence any oral or documentary evidence and other data "deemed relevant” by it. In view of such discretion reposed in the panel on this matter, our review is limited to the determination of whether, in this instance, the exclusion of City’s Exhibit 30 was so egregious as to cause the award of the panel on the contested economic issues to be unsupported by competent, material and substantial evidence on the whole record.
The arbitration panel was well-informed on the cost of its award to the city. In making the disputed evidentiary ruling, the panel chairman observed:
"[Y]our panel is composed of persons who are knowledgeable and sophisticated as far as public affairs gener*495ally, and indeed about labor relations matters. And, what everybody else knows, we are charged with knowing.”
"I know the cost, and everyone on the panel, everyone sitting out there is very conscious of the fact cost is of consideration. We’re not naive, and we’re not unmindful of costs.”
More specifically, we find the following in the majority panel’s decision:
"The panel cannot escape the history of the city in its relations with its unions, not only as evidenced by contractual undertakings but by actions of the electorate from time to time. For years there has been a correlation between benefits of police and fire personnel, commonly referred to as security personnel. * * * After years of debate, both the general electorate and in collective bargaining, the principle of parity was established between police and fire. Even more interestingly, there is a correlation to a degree between certain positions in the Fire Department and positions among the Lieutenants and Sergeants.”
"As indicated earlier, the chairman is of the opinion that this panel cannot remake or change history nor can it escape the history the parties themselves have made, that is, of certain internal relationships in comparisons between and among Lieutenants and Sergeants and DPOA members as well as between and among these groups or bargaining units and the fire fighters.”
In light of the foregoing, the exclusion of City’s Exhibit 30 from evidence cannot be said to have caused the economic award to be unsupported by competent, material and substantial evidence on the whole record. Accordingly, we reaffirm our holding as to the validity of the economic award.
*496 D. The Non-Economic Award is Not Supported by Competent, Material and Substantial Evidence on the Whole Record
We cannot find that the hardship exemption to the residency requirement is supported by competent, material and substantial evidence on the whole record. The panel, in its August 8, 1979 opinion on remand on the residency issues, did not consider all the applicable § 9 factors in making its award, as Act 312 mandates.
As we emphasized under Part V, B, supra, the Legislature, through the language of §§ 8 and 9, has unequivocally directed that the panel, in making an award, treat the § 9 factors where applicable. Such language is not precatory and therefore the panel does not have the discretion to ignore any applicable § 9 factors. Moreover, this legislative directive is no less obligatory on the panel when the parties themselves have failed to introduce evidence on an applicable factor. In such a case the panel, in order to comply with the intention of Act 312 that arbitral decisions be substantiated by evidence of, and emanate from consideration of, the applicable § 9 factors, must direct the parties to introduce evidence relating to the applicable factors.71 By so doing, the panel will be able, per the dictates of §§ 8 and 9, to make findings based upon the applicable factors enumerated in § 9 from the evidence of record before it.
In rendering the present award on the non-economic issue of a hardship exemption to the residency requirement, the panel did not consider all applicable factors. The panel only considered the first, third and last factors of § 9 in its August 8, *4971979 opinion on remand from the trial court. As to the other factors, the panel merely stated:
"So far as the other § 9 criteria, neither party offered comparisons and except in the enforcement sense, as noted, money factors are not in issue.”
Such pro forma deference to the requirements of §§ 8 and 9 of the act will not do. These sections, by their terms, require rigid adherence. Thus, for example, it was error for the panel, in making an award of a residency hardship exemption, to refuse to consider, however convincing the evidence on other factors, the applicable fourth factor involving a comparison of the residency requirement for DPOA members (a condition of employment) with the residency requirements for other employees performing similar services and for other employees generally in both public and private employment in comparable communities, as well as any other factors if applicable. The parties’ omission of evidence on this factor did not excuse the panel’s inattention to the factor.72
We note that the residency requirement requested by the city and affirmed in the earlier Platt panel award was left intact and unchanged by the panel’s award except for the hardship exemption. Since we find the hardship exemption *498award by the panel to have been unsupported by competent, material and substantial evidence on the whole record, the residency requirement, in its entirety, must be reaffirmed. It is now up to the parties to either introduce evidence on the applicable factors before a reconvened panel or to return to collective bargaining.73
The rationale of this holding provides the resolution of the city’s last argument. The city asserts that it was error for the trial court as well as the arbitration panel to ignore its request to amend the "residency” portion of the present collective bargaining agreement so that the word "resident” would be defined in terms of a 1978 City of Detroit ordinance which provides that "residence” is to be construed as the "actual domicile” of the individual, with an individual being capable of having only one "domicile”. Detroit City Code, § 2-1-1.2; Detroit Ordinance No. 245-H. The predecessor 1968 ordinance had defined residency in terms of where an individual normally ate, slept and maintained his normal personal and household effects. Detroit Ordinance No. 327-G. This former ordinance, the city contends, created difficulties in enforcement.
Initially, we disagree with the city’s complaint that the arbitration panel ignored the city’s requested amendment. In its opinion on remand on the residency issue, the following appears:
"In the interest of completeness, it must be stated that the unanimous action of the panel as noted above, *499under its December 20, 1978, opinion, when it was reduced to formal award, brought a dissent from the city delegate, who asserted that it had been his understanding that the panel was adopting the definition change proposed by the city. The majority of the panel, the chairman with the labor delegate concurring, however, made clear that no changes were contemplated by the panel except a change that would provide a hardship exemption, and the award so provided.”
More importantly, however, we, as a reviewing court, cannot amend the language of the contract to include the new Detroit ordinance. The panel has not made specific findings of fact and an award relating such a non-economic issue to the applicable § 9 factors and the evidence of record. It is not our job to fill this void by acting as de novo arbitrators in this matter. The proper course is for the parties to seek a resolution of this issue via collective bargaining, and failing that, through the invocation of Act 312.
VI. Interest on an Act 312 Economic Award?
Both the DPOA and the DFFA have appealed the trial court’s denial of interest on the arbitration panel’s economic award. Since Act 312 itself is silent on the subject of interest, the DPOA and the DFFA base their appeal on MCL 438.7; MSA 19.4, as well as MCL 600.6013; MSA 27A.6013.
We find MCL 600.6013 to be inapposite to the situation at bar. In relevant part, this statute provides:
"Interest shall be allowed on any money judgment recovered in a civil action, such interest to be calculated from the date of filing the complaint at the rate of 6% per year * * (Emphasis supplied.)
*500The Act 312 arbitration award is not a "money judgment recovered in a civil action”. MCL 600.6013, as part of the Revised Judicature Act of 1961, does not apply to compulsory interest arbitration in the public sector. The preamble to the Revised Judicature Act states its concern, instead, to be with such matters as the "organization and jurisdiction of the courts” and the "forms and attributes of civil claims and actions”. Our reasoning in the analogous context of disallowing an interest claim on a workers’ compensation award made under MCL 600.6013 is here valid. Cf. Solakis v Roberts, 395 Mich 13; 233 NW2d 1 (1975). An Act 312 arbitration panel is not "a court”, "is not possessed of judicial power” and the concept of a money judgment is "totally alien to the policy and philosophy” of Act 312 which looks to the expeditious and effective resolution of critical-service public sector labor disputes. 395 Mich 21-22.
We also find MCL 438.7 to be an inappropriate vehicle for the granting of interest. That statute, in pertinent part, states:
"In all actions founded on contracts express or implied, whenever in the execution thereof any amount in money shall be liquidated or ascertained in favor of either party, by verdict, report of referees, award of arbitrators, or by assessment made by the clerk of the court, or by any other mode of assessment according to law, it shall be lawful, unless such verdict, report, award, or assessment shall be set aside, to allow and receive interest upon such amount so ascertained or liquidated, until payment thereof or until judgment shall be thereupon rendered; * * (Emphasis supplied.)
As the trial court noted, an Act 312 arbitration *501proceeding is not "founded” on a contract, but instead has as its very purpose the making of a contract. Thus we find the rationale of Solakis, supra, ill-suited to the concerns of Act 312. Solakis, in construing our earlier decision of Wilson v Doehler-Jarvis Division of National Lead Co, 358 Mich 510; 100 NW2d 226 (1960), held that MCL 438.7 was the appropriate statute under which to grant interest on a workers’ compensation award. The Solakis Court satisfied the "contract” requirement of MCL 438.7 by finding that the right to a workers’ compensation award was contractual since it arose out of the contractual relationship between employer and employee. Here, conversely, Act 312 is not dependent on an already existing contractual relationship between employer and employee for its existence. Indeed, § 9 of the act expressly provides in its introductory phrase that it must be considered even "[w]here there is no agreement between the parties”. Furthermore, as in the present case, an Act 312 award often will not be issued by an arbitration panel until the parties’ previous collective bargaining agreement (or statutorily imposed Act 312 contract) has already expired.
Nor do we find entirely persuasive the argument that the statutorily imposed Act 312 contract can itself serve as the "contract” contemplated by the terms of MCL 438.7. The Act 312 contract, as issued by a panel, is not, as required by MCL 438.7, one that has been executed to the extent that an amount of money is liquidated or ascertained. Further, an Act 312 proceeding cannot be "founded” on a contract since its very purpose is to make a contract.
In sum, we can find no statutory provision under *502which to grant interest on the economic portion of the panel’s award.74
VII. Conclusion
As to the two major issues posed at the outset of this opinion, we conclude: (1) amended Act 312 does not include an unconstitutional delegation of power; and (2) considering the disputed award in accordance with our ruling that judicial review under the act requires § 12 to be read in conjunction with §§ 8 and 9, we find that — with the exception of the residency hardship exemption — the award complies with the requisite factors and is supported by competent, material and substantial evidence on the whole record. As to the issue of interest, we conclude that statutory support for the grant of interest on Act 312 arbitration awards is absent; interest is therefore denied. With respect to the home rule and equal protection claims discussed in footnotes 14 and 15 supra, we conclude that these subjects have been resolved by precedent adverse to the city.
No costs, a public question being involved.
Ryan and Blair Moody, Jr., JJ., concurred with Williams, J.As originally enacted in 1969 and considered by Justices Levin, T. G. Kavanagh, Coleman and Williams in the 1975 Dearborn opinion, 1969 PA 312 provided the following § 5 mechanism for the selection of arbitration panel members:
"Within 5 days thereafter [after the employer’s and employees’ § 4 delegates have been selected to represent their interests on the three-member panel], or within such further additional periods to which they may agree, the delegates shall designate an impartial, competent and reputable person to act as an arbitrator, hereafter called the arbitrator or chairman of the panel of arbitration, and with them to constitute an arbitration panel to further consider and order a settlement of all matters. Upon their failure to agree upon and appoint the arbitrator within such time, or mutually extended time, either of them may request the chairman of the state labor mediation board to appoint the arbitrator, and the chairman of the state mediation board shall appoint, in not more than 7 days, an impartial, competent and reputable citizen as the arbitrator.” MCL 423.235; MSA 17.455(35).
Subsequent to the Dearborn decision, § 5 was significantly amended by 1976 PA 84, to provide the following:
"(1) Within 7 days of a request from 1 or both parties [§ 4 delegate^)], the employment relations commission shall select from its panel of arbitrators, as provided in subsection (2), 3 persons as nominees for impartial arbitrator or chairman of the arbitration panel. Within 5 days after the selection each party may peremptorily strike the name of 1 of the nominees. Within 7 days after this 5-day period, the commission shall designate 1 of the remaining nominees as the impartial arbitrator or chairman of the arbitration panel.
"(2) The employment relations commission shall establish and appoint a panel of arbitrators, who shall be known as the Michigan employment relations commission panel of arbitrators. The commission shall appoint members for indefinite terms. Members shall be impartial, competent, and reputable citizens of the United States and residents of the state, and shall qualify by taking and subscribing the constitutional oath or affirmation of office. The commission may at any time appoint additional members to the panel of. arbitrators, and may remove existing members without cause.” MCL 423.235; MSA 17.455(35).
Other minor amendments to Act 312 as originally enacted and considered in Dearborn are detailed in Part III, B, infra.
At the time of the 1975 Dearborn decision, 13 jurisdictions had enacted similar interest arbitration schemes, Dearborn, supra, 298, fn 9 (opinion of Williams, J.); none of these acts have been repealed although some have been amended. Today, at least 20 jurisdictions *436including Michigan have enacted legislation providing for binding interest arbitration for public employees, or specifically for police and fire fighters. Those jurisdictions which have enacted similar legislation since the Dearborn decision include: Conn Gen Stat Ann, §§ 7-472 et seq., 10-153Í; Hawaii Rev Stat, § 89-11; Iowa Code Ann, § 20.22; Mass Ann Laws, ch 150E, § 9; Mont Code Ann, §§ 39-34-101 et seq.; NJ Stat Ann, §§ 34:13A-16 et seq.; NY Civil Service Law (McKinney), §§ 205, 209; Or Rev Stat, §§ 243.742 et seq.; Wash Rev Code Ann, §§ 41.56.100, 41.56.125, 41.56.430 et seq.
See Grodin, Political Aspects of Public Sector Interest Arbitration, 64 Cal L Rev 678, 678-683 (1976). See, e.g., Newman, Interest Arbitration — Practice and Procedures, in Knapp, ed, Labor Relations Law in the Public Sector (Chicago: ABA, 1977), pp 54-61.
See, e.g., Amsterdam v Helsby, 37 NY2d 19; 371 NYS2d 404; 332 NE2d 290 (1975); Arlington v Board of Conciliation & Arbitration, 370 Mass 769; 352 NE2d 914 (1976); Biddeford v Biddeford Teachers Ass’n, 304 A2d 387 (Me, 1973); Division 540, Amalgamated Transit Union v Mercer County Improvement Authority, 76 NJ 245; 386 A2d 1290 (1978); Harney v Russo, 435 Pa 183; 255 A2d 560 (1969); Medford Fire Fighters Ass’n v Medford, 40 Or App 519; 595 P2d 1268 (1979); In the Matter of New Jersey Bell Telephone Co v Communications Workers of America, 5 NJ 354; 75 A2d 721 (1950); Richfield v Local No 1215, International Ass’n of Fire Fighters, 276 NW2d 42 (Minn, 1979); School Dist of Seward Education Ass’n v School Dist, 188 Neb 772; 199 NW2d 752 (1972); Spokane v Spokane Police Guild, 87 Wash 2d 457; 553 P2d 1316 (1976); State ex rel Fire Fighters Local No 946 v Laramie 437 P2d 295 (Wyo, 1968) (equally split decision); City of Warwick v Warwick Regular Firemen’s Ass’n, 106 RI 109; 256 A2d 206 (1969). See generally Anno: Validity and construction of statutes or ordinances providing for arbitration of labor disputes involving public employees, 68 ALR3d 885, 891-892 ("The validity of statutory provisions for arbitration of labor disputes involving public employees has generally been upheld against attacks on a variety of grounds. * * * The modern trend definitely appears to be in favor of finding a valid delegation.”) But compare the distinguishable cases discussed in fn 56, infra. See also Fire Fighters Union, Local 1186 v Vallejo, 12 Cal 3d 608; 526 P2d 971; 116 Cal Rptr 507 (1974).
Indeed, in a report of the Michigan Departments of Labor and Management & Budget, "Review of Michigan’s Compulsory Arbitration Act & Public Act 312 of 1979”, May 21, 1979 (mimeo), it was stated that only one strike relating to bargaining has followed adoption of Act 312. Id., 8. This statement is to be compared with the following 1979 statement of Arvid Anderson, Chairperson of the New York City Office of Collective Bargaining, to the Association of Labor Relations Agencies:
"[Tjhere have been an increasing number of bitter strikes by police *437and firefighters causing real hardship to communities where there are no orderly procedures for resolving contract disputes. These occurred in Dayton, Cleveland, and Toledo, Ohio; New Orleans, La.; Louisville, Ky.; Anderson, Ind.; and Wichita, Kan.” Government Employee Relations Report (Washington, DC: BNA, August 13, 1979), 823:54.
See generally Anderson, MacDonald & O’Reilly, Impasse Resolution in Public Sector Collective Bargaining — An Examination of Compulsory Interest Arbitration in New York, 51 St John’s L Rev 453 (1977); Benjamin, Final Offer Arbitration Awards in Michigan, 1973-1977 (Institute of Labor and Industrial Relations, University of Michigan & Wayne State University, 1978); Howlett, Contract Negotiation Arbitration in the Public Sector, 42 Cincinnati L Rev 47, 63-65 (1973); Kaye, Impasse Resolution Mechanisms and Teacher Strikes, 7 U of Mich J of L Reform 575 (1974), cited in Dearborn, supra, 293, fn 2 (opinion of Williams, J.); Rehmus, Legislated Interest Arbitration, Proceedings of the 27th Annual Winter Meeting of the Industrial Relations Research Association (December 28-29, 1974), pp 307, 308-309.
In addition to our ruling on the focal issue of this opinion that Act 312, as amended, does not unconstitutionally delegate "legislative and political responsibility to politically unaccountable arbitrators”, we also hold that the act does not impermissibly usurp constitutionally vested home rule powers and does not unconstitutionally deny the right to cast effective ballots in municipal elections. These claims of the city are summarily rejected in fns 14, 15, infra, and accompanying text for the reasons that the home rule issue was unanimously disapproved of in Dearborn and the equal protection argument is without merit.
The DPOA delegate concurred in the panel’s decision on all issues except its rejection of the DPOA’s dental plan, to which the DPOA delegate expressly dissented. The city delegate dissented from the panel’s opinion on the issues of wages, COLA, and the hardship exemption from the residency requirement.
As provided in § 8 of the act, MCL 423.238; MSA 17.455(38), which has been significantly amended by 1972 PA 127, the panel is required to adopt "the last offer of settlement which, in the opinion of the arbitration panel, more nearly complies with the applicable factors prescribed in section 9 [MCL 423.239; MSA 17.455(39)]”. See fn 17, infra, and accompanying text. As will be developed in Part III, B, infra, this requirement significantly differs from that effective at the time of the Dearborn decision in 1975.
As to the economic issue of how much sick time would be charged to an employee unable to finish his or her shift because of illness, although the DPOA’s last offer of a continuation of the present practice was accepted by the panel, the panel additionally recommended that the parties effect a system of computerized hour-by-hour computation.
Reproduced below is a comparison of the three-year costs of the DPOA and city last best offers on an individual benefit basis. This comparison was included in the opinion of the arbitration panel dated December 20, 1978:
*439’’Benefit Cost of DPOA Last Best Offer Cost of City Last Best Offer
Wages $32,810,000 $34,711,0002
COLA 28.130.000
Shift Premium 669,000
Dental Care 1.003.000
Longevity 4.280.000
Holidays 1.506.0001 1,456,000
Pension 18.027.000
Sick Leave Payoff 1,685,000
Total Cost $88,110,000 $36,167,000
"!This is the direct cost of the union proposal. In addition to this the city would lose 22 man years of service in 1978-79 and 66 man years of service in 1979-80. If the city hires additional employees to cover this lost time it would cost $600,000 in 1978-79 and $1,900,000 in 1979-80.
"2 This is the cost of the 4.8%-4.0%-4.0% wage proposal. The 4%-2%-2%-2%-2% plus limited COLA proposal would cost $33,000,000.”
For an explanation of the city’s two wage proposals, see fn 66, infra.
In reviewing this data, it is significant that the arbitration panel’s actual award rejected the DPOA’s last best offer on the economic issues of shift premium, dental care, longevity, holidays, pension and sick leave payoff in favor of the city’s last best offer to continue the existing policy as to all those items, except holiday pay where the city’s offer to raise holiday pay from an additional 150% to an additional 200% of daily pay was accepted.
Some non-economic issues were finally resolved by the panel itself. On the disputed issue of furlough allocation, the panel awarded the city’s requested contract language limiting the number of police officers in a given precinct, section or unit who could be on furlough at the same time to 10% of the total number of police officers.
The DPOA, on the other hand, won contract language on the issue of police reserves which explicitly provided that the city could not use police reserves to do the normal work of bargaining unit members or to circumvent the holiday, overtime or other provisions of the agreement. The DPOA was also awarded its proposed continuation of the previous contract’s sick leave language. Under this provision, an officer could be absent from home while sick without the permission of a superior officer.
Even though the arbitration award was announced on December 20, 1978, for purposes of its order and to facilitate accounting thereunder, the Court of Appeals assumed that the arbitration award was announced January 1, 1979.
This issue has been more specially framed by the city in the following terms:
"1969 PA 312, insofar as it provides for compulsory arbitration, violates the United States Constitution and the Constitution of the *445State of Michigan by improperly delegating legislative and political responsibility to politically unaccountable arbitrators.”
We perceive the city’s issue as incorporating two distinct questions: (1)whether Act 312, as amended, is violative of the Michigan delegation doctrine in general as framed by the "standards test” of Osius v St Clair Shores, 344 Mich 693, 698; 75 NW2d 25 (1956); and (2) whether Act 312, as amended, is violative of general notions of public accountability or political responsibility. These distinct questions are specifically addressed in Part IV, A and B, infra.
This geperal issue represents a summary of the four issues which the city framed in its brief relating to the validity of the rendered award with respect to wages, COLA and the hardship exemption from the residency requirement.
Verbatim, these four issues were framed as follows:
(1) "Whether the scope of judicial review under 1969 PA 312 is broader than that defined by the lower court, such review being governed by article 6 § 28 of the Constitution of the State of Michigan.”
(2) "Whether the lower court erred in holding that the panel’s award on a hardship exemption to the residency requirement of the contract met the standards required by the act and any failure to comply with the act had been corrected by the panel on remand.”
(3) "Whether the lower court erred in holding that the panel’s award denying the city’s request to amend the collective bargaining agreement to conform to the amendments made to the city charter of the City of Detroit was supported on the record as a whole.”
(4) "Whether the 1969 [PA] 312 panel, through its chairman, violated § 6 of 1969 [PA] 312 (MCL 423.236) by refusing to admit evidence relevant to economic demands of the union.”
Although the city contends in its first issue that the applicable scope of judicial review of the arbitration award is that found in Const 1963, art 6, § 28, we find the review prescribed in § 12 of Act 312, MCL 423.242; MSA 17.455(42), for all relevant intents and purposes, to be identical with the constitutional standard, i.e., was the award supported by competent, material and substantial evidence on the whole record. Cf. Midland Twp v State Boundary Comm, 401 Mich 641, 671-672; 259 NW2d 326 (1977).
The city contends that the Act 312 compulsory arbitration scheme unconstitutionally divests home-rule cities of their powers granted by Const 1963, art 7, §§ 22 and 34. This contention was rejected by Justices Levin, T. G. Kavanagh, and Coleman and implicitly by Justice Williams in the 1975 Dearborn opinion. Dearborn, supra, 243-246 (opinion of Levin, J.), 273 (opinion of T. G. Kavanagh, C.J., concurring with Levin, J.), 281-283 (opinion of Coleman, J.). Since the city’s contention substantially follows that set forth in Dearborn, we will not consider the home rule argument further. See Amsterdam v Helsby, 37 NY2d 19, 26-27; 371 NYS2d 404; 332 NE2d 290, 292-293 (1975); Arlington v Board of Conciliation & Arbitration, 370 Mass 769, 773-774; 352 NE2d 914, 918 (1976).
The city here contends that Act 312, because of the alleged delegation of authority to politically insensitive persons, violates equal protection by depriving city constituents of the right to cast effective ballots in local elections. The city’s argument is a non sequitur; the equal protection principle of "one-man, one-vote” here invoked guarantees that legislative districts embrace substantially equal numbers of citizens in order to preclude debasement of the vote. Baker v Carr, 369 US 186; 82 S Ct 691; 7 L Ed 2d 663 (1962). Moreover, arguments similar to that made here against other binding arbitration schemes have likewise been rejected as lacking merit in those three jurisdictions expressly considering the claim. Amsterdam v Helsby, 37 NY2d 19, 28; 371 NYS2d 404; 332 NE2d 290, 293 (1975); Arlington v Board of Conciliation & Arbitration, 370 Mass 769, 777-778; 352 NE2d 914, 920-921 (1976); Harney v Russo, 435 Pa 183, 190-192; 255 A2d 560, 563-564 (1969).
Const 1908, art 16, § 7 provided that "The legislature may establish courts of conciliation with such powers and duties as shall be prescribed by law”. Delegates to the Constitutional Convention of 1961 criticized this provision as ineffectual, stating:
"Mr. Hoxie: * * * First I would like to state that neither agencies, cities, anyone hiring public employees, nor labor subscribe to the theory of courts in the way of settling disputes. * * * They have never been used even though the provisions of the constitution so provided, because employers of public employees as well as organized labor did not want to resort to that particular provision.
"Mr. Murphy: * * * Since 1850 the legislatures have had the right to establish courts of conciliation. After many long hours of public hearings and debate within the committee on legislative powers, the committee properly recognized the importance of giving the legislature the flexibility it needs to set up the necessary and appropriate machinery to solve legal problems in public employment without freezing into the constitution a particular agency which might be outmoded before we finish this constitution.” 2 Official Record, Constitutional Convention 1961, p 2340.
Responsive to these criticisms, the Const 1908 provision was repealed and replaced by Const 1963, art 4, § 48, a significant departure from *448the prior call for courts of conciliation and more consistent with modern conditions. 2 Official Record, Constitutional Convention 1961, p 2340.
As originally enacted, Act 312 was scheduled to expire on June 30, 1972, MCL 423.245; MSA 17.455(45). This limitation was extended and later repealed by 1975 PA 3 "in view of the record of success of procedures under the act”. Dearborn, supra, 295.
The first significant amendment to the act occurred in 1972 relative to the § 8 last offer provision, MCL 423.238; MSA 17.455(38). This amendment is discussed in greater detail in fn 26, infra, and accompanying text.
1976 PA 84, significantly amended the § 5 mechanism considered in Dearborn for the selection of particular dispute arbitration panel *449members. This amendment is discussed in fn 1, supra, and accompanying text.
Dearborn, supra, 244-246 (opinion of Levin, J.), 273 (opinion of T. G. Kavanagh, C.J., concurring with Levin, J.), 277 (opinion of Coleman, J.), 294 (opinion of Williams, J.).
Escanaba v Labor Mediation Board, 19 Mich App 273, 281-282; 172 NW2d 836 (1969). Prior to the institution of Const 1963, art 4, § 48, such schemes were constitutionally sanctioned under the police and general welfare powers of the state. See, e.g., Local Union No 876 International Brotherhood of Electrical Workers v State Labor Mediation Board, 294 Mich 629, 635-636; 293 NW 809 (1940); Grosse Pointe Park Fire Fighters Ass’n v Village of Grosse Pointe Park, 303 Mich 405, 409; 6 NW2d 725 (1942); Detroit v Division 26 of the Amalgamated Ass’n of Street, Electric Railway & Motor Coach Employees of America, 332 Mich 237; 51 NW2d 228 (1952).
See fn 1, supra, and accompanying text which discusses the 1976 PA 84, amendment to § 5 as originally enacted.
See fn 26, infra, which discusses the 1972 PA 127, amendment to § 8 which was not effective at the time of the Dearborn litigation although considered by the Justices in that decision.
After the Dearborn decision, § 3 was amended in minor part by 1977 PA 303, to expressly except from Act 312 those disputes "concerning the interpretation or application of an existing agreement (a 'grievance’ dispute)”. This amendment makes clear that the 'scope of Act 312 is restricted to interest arbitration alone.
While this amendment to § 3 expressly restricted the act’s subject matter, two amendments to § 2, MCL 423.232; MSA 17.455(32), expanded its scope to include both emergency medical service personnel employed by a police or fire department, 1976 PA 203, and emergency telephone operators employed by a police or fire department, 1977 PA 303. Additionally, the award of retroactive benefits was simplified by the 1977 PA 303, amendment to § 10, MCL 423.240; MSA 17.455(40), by eliminating the former requirement that arbitration proceedings be initiated prior to the commencement of the relevant fiscal year.
See fn 1, supra, for a discussion of the significant amendments wrought by 1976 PA 84.
This section was added to the act by 1972 PA 127, effective May 4, 1972 and was, therefore, not before the Dearborn Court. This remand provision insures that the arbitration panel will be presented with sharpened issues necessitating resolution.
Prior to the 1972 PA 127, amendments to § 8, effective May 4, 1972, this section merely required the rendition of a written opinion and order upon the record, which shall be "just and reasonable and based upon the factors prescribed in sections 9 and 10”; it did not differentiate between economic or non-economic issues:
"Sec. 8. The arbitration panel, within 30 days after the conclusion of the hearing, or such further additional periods to which the parties may agree, shall make written findings of fact and promulgate a written opinion and order upon the issues presented to it and upon the record made before it, and shall mail or otherwise deliver a true copy thereof to the governing body of the public employer and to the attorney or other designated representatives of the employees of the public employer. The findings, opinions and order shall be just and reasonable and based upon the factors prescribed in sections 9 and 10.”
Comparison of § 8 as enacted and amended reveals significant modification. Prior to 1972 PA 127, the panel was required by § 9 alone to consider and resolve all issues ("wage rates or other conditions of employment”) based upon the applicable § 9 factors. Pursuant to the 1972 amendments, however, the panel is restricted by § 8 to the adoption of that last offer of settlement as to each economic issue which, in the panel’s opinion, more nearly complies with the applicable § 9 factors; resolution of all other issues is to be based upon the applicable § 9 factors. Thus, not only is the panel’s authority to resolve economic issues strictly circumscribed by the parties’ sharpened last best offer but that authority is further bounded by the necessity of considering the applicable § 9 factors.
Although these amendments were not applicable to the litigation concerned in the 1975 Dearborn decision because that litigation preceded their effective date, Justices Levin, Coleman and Williams directly addressed their significance. Dearborn, supra, 270 (opinion of Levin, J. "Last-offer arbitration does not, however, address the constitutional deficiency we find in this act: the power of the decision maker, who does not have continuing responsibility, to make critical choices on economic and non-economic issues without political accountability.”), 281, fn 6 (opinion of Coleman, J. "Indeed, the 1972 amendments to Act 312 have made the arbitrator’s duty even more circumscribed.”), 297 (opinion of Williams, J. "A subsequent amendment provides a further constraint on the authority of the panel in the requirement to consider only the last offer of settlement made by each party for each economic issue. This also encourages good-faith bargaining by the parties, as it prevents submission of an offer so outlandish as to effectively require acceptance of the other’s position. Not only is the panel restricted to accepting or rejecting the last proposal, it must base its determinations on [the § 9] standards,
As indicated in fn 13, supra, the § 12 standard of judicial review is, for all relevant intents and purposes, identical to the constitutional standard of review of administrative decisions found in Const 1963, art 6, § 28, which provides in pertinent part:
"All final decisions, findings, rulings and orders of any administrative officer or agency existing under the constitution or by law, which are judicial or quasi-judicial and affect private rights or licenses, shall be subject to direct review by the courts as provided by law. This review shall include, as a minimum, the determination whether such final decisions, findings, rulings and orders are authorized by law; and, in cases in which a hearing is required, whether the same are supported by competent, material and substantial evidence on the whole record.” (Emphasis supplied.) See MCL 24.301, 24.302, 24.306; MSA 3.560(201), 3.560(202), 3.560(206).
See fns 60-64, infra, and accompanying text.
This section resembles the Const 1963, art 6, § 28 provision for judicial review which is patently more expansive than the restrictive court rule provision for the review of arbitral awards in general, GCR 1963, 769.9(1):
*457".9 Vacating an [Arbitration] Award.
“(1) Upon application of a party, the court shall vacate an award whiere:
"(a) The award was procured by corruption, fraud or other undue means;
"(b) There was evident partiality by an arbitrator appointed as a neutral or corruption in any of the arbitrators or misconduct prejudicing the rights of any party;
"(c) The arbitrators exceeded their powers; or
"(d) The arbitrators refused to postpone the hearing upon sufficient cause being shown therefor or refused to hear evidence material to the controversy or otherwise so conducted the hearing as to prejudice substantially the rights of a party.
"But the fact that the relief was such that it could not or would not be granted by a court of law or equity is not ground for vacating or refusing to confirm the award.”
As such, § 12 significantly incorporates all appropriate bases for review without either permitting expansive de novo litigation as some jurisdictions have provided, McAvoy, Binding Arbitration of Contract Terms: A New Approach to the Resolution of Disputes in the Public Sector, 72 Colum L Rev 1192, 1204, fn 73 (1972) — which would likely frustrate the binding and expeditious nature of the Act 312 concept— or, as in the case of GCR 1963, 769.9(1), so narrowly restricting the judiciary’s basis for review as to arguably shelter such significant arbitral decisions from judicial inquiry. See fns 60-64, infra, and accompanying text.
Perhaps the most concise description of the delegation doctrine was enunciated in the seminal case of Locke’s Appeal, 72 Pa 491, 498-499 (1873):
"The legislature cannot delegate its power to make a law; but it can make a law to delegate a power to determine some fact or state of things upon which the law makes, or intends to make, its own action depend. To deny this would be to stop the wheels of government.”
As in Plato’s allegory of the cave, since 1854 in People v Collins, 3 Mich 343 (1854), this Court has intermittently struggled to distinguish the shadows from the light surrounding the question posed in Locke’s Appeal whether the Legislature may delegate authority to a subordinate body of non-elected individuals. Although this Court initially adopted "true” and "proper” tests to distinguish valid from invalid delegations, judicial focus has sharpened to an inquiry "whether the limits [on the exercise of discretion conferred on the non-legislator] are sufficiently defined to avoid delegation of legislative powers”. Argo Oil Corp v Atwood, 274 Mich 47, 52; 264 NW 285 (1935). See People v Soule, 238 Mich 130, 139; 213 NW 195 (1927); Hoyt Brothers, Inc v Grand Rapids, 260 Mich 447, 451-452; 245 NW 509 (1932).
Despite certain criticism, 1 Davis, Administrative Law Treatise (2d ed), § 3:3, p 152, the test of delegation has come to be framed in terms of "standards” as developed in Osius. The standards test has been recently recognized as a valid measure of a delegation scheme’s constitutionality in the context of both administrative agency action, Westervelt v Natural Resources Comm, 402 Mich 412; 263 NW2d 564 (1978); Dukesherer Farms, Inc v Director of the Dep’t of Agriculture (After Remand), 405 Mich 1; 273 NW2d 877 (1979); Dep’t of Natural Resources v Seaman, 396 Mich 299; 240 NW2d 206 (1976), as well as action by otherwise appointed groups or persons, see Dearborn, supra, 259, 269-270 (opinion of Levin, J.), 273 (opinion of T. G. Kavanagh, C.J., concurring with Levin, J.), 288 (opinion of Coleman, J.), 303-304 (opinion of Williams, J.); Westervelt, supra, 443-444, fn 21.
Construing the general principle enunciated in Osius that such standards must be "as reasonably precise as the subject matter requires or permits”, it has been recognized that "[t]he preciseness of the standard will vary with the complexity and/or the degree to which [the] subject regulated will require constantly changing regulation”. Dep’t of Natural Resources v Seaman, 396 Mich 299, 309; 240 NW2d 206 (1976).
Neither exhaustive nor excessively detailed standards must be found to uphold a delegation scheme. As stated by the United States Supreme Court in American Power & Light Co v Securities & Exchange Comm, 329 US 90, 105; 67 S Ct 133; 91 L Ed 103 (1946):
"The legislative process would frequently bog down if Congress were constitutionally required to appraise beforehand the myriad situations to which it wishes a particular policy to be applied and to formulate specific rules for each situation. Necessity therefore fixes a point beyond which it is unreasonable and impracticable to compel Congress to prescribe detailed rules; it then becomes constitutionally sufficient if Congress clearly delineates the general policy, the public agency which is to apply it, and the boundaries of this delegated authority.”
See Ray v Mason County Drain Comm’r, 393 Mich 294, 306-307; 224 NW2d 883 (1975); State Highway Comm v Vanderkloot, 392 Mich 159, 172-173; 220 NW2d 416 (1974) (opinion of Williams, J.); Pleasant Ridge v Governor, 382 Mich 225, 243-248; 169 NW2d 625 (1969). This sentiment was likewise urged by this Court in GF Redmond & Co v Michigan Securities Comm, 222 Mich 1, 5; 192 NW 688 (1923):
"The power to carry out a legislative policy enacted into law under the police power may be delegated to an administrative board under quite general language, so long as the exact policy is clearly made apparent, * * *. This marks the line between arbitrary officiousness and the exercise of delegated power to carry out a designated policy under the police power.” (Emphasis supplied.)
What is required to satisfy the Osius inquiry is the inclusion of either explicit or derivative standards, Pleasant Ridge v Governor, supra, 243-248; Vanderkloot, supra, commensurate with the complexity of the regulated area:
"In making this determination whether the statute contains sufficient limits or standards we must be mindful of the fact that such standards must be sufficiently broad to permit efficient administration in order to properly carry out the policy of the Legislature but not so broad as to leave the people unprotected from uncontrolled, arbitrary power in the hands of administrative officials.” Seaman, supra, 308-309.
When standards as reasonably precise as the subject matter requires or permits are found, the principle that the Legislature may not delegate or dedicate "law-making” or "legislative” power, but only "administrative” power, becomes merely a principle of description or convenience, not substance. See Argo Oil Corp v Atwood, 274 Mich 47, 53; 264 NW 285 (1935). This tenet was analyzed with respect to administrative rule-making in Westervelt, supra, 440-441:
*460"[T]he making of rules by an administrative agency pursuant to legislatively delegated rule-making power differs from 'legislation’ or 'law-making’ in two essential aspects. First, the source of the power to make the rule is in the Legislature. Second, the concept of 'legislation’, in its essential sense, is the power to speak on any subject without any speciñed limitations.
''However, constitutionally, 'standards * * * as reasonably precise as the subject matter requires or permits’ do specify limitations on agency rule-making. Thus, when such standards exist, agency rule-making is not an unconstitutional action because the Legislature has (1) authorized and (2) limited such action. Also, agency rule-making is not a usurpation of the 'legislative’ law-making function because the Legislature has (1) directed the agency to so act and (2) limited the scope within which it may act. Finally, agency rule-making is not 'legislating’ in the essential sense of the word, because the agency is acting within specified limitations ('standards’) established by the Legislature and is not acting in accordance with its own will.”
See generally Barr, The Public Arbitration Panel as an Administrative Agency: Can Compulsory Interest Arbitration Be an Acceptable Dispute Resolution Method in the Public Sector?, 39 Albany L Rev 377 (1975); Grodin, Political Aspects of Public Sector Interest Arbitration, 64 Cal L Rev 678 (1976); Howlett, Contract Negotiation Arbitration in the Public Sector, 42 Cincinnati L Rev 47 (1973); McAvoy, Binding Arbitration of Contract Terms: A New Approach to the Resolution of Disputes in the Public Sector, 72 Colum L Rev 1192 (1972); Case Note, The Uncertain Status of Public Sector Labor Arbitration. in Colorado, 48 Colo L Rev 451 (1977); Comment, Salt Lake City v International Ass’n of Firefighters, 1977 Utah L Rev 457; Summers, Public Employee Bargaining: A Political Perspective, 83 Yale L J 1156 (1974).
The express and detailed standards of § 9, MCL 423.239; MSA 17.455(39), applicable to both §§ 8 and 9 economic as well as non-economic issues, are set out in Part III, B, supra. The instant panel’s consideration of those § 9 factors with relation to the issues before it is analyzed in Part V, C and D, infra.
The precision of these standards appears to have been tacitly conceded by the city as it merely attacks the relative weight to be given the § 9 factors rather than their sufficiency. The city’s argument in this respect is discussed and rejected in Part V, B, infra.
Justice Williams’ opinion began with the premise that "[t]his Court straight-forwardly requires 'sufficient standards so as to obviate any delegation of legislative power’ ”, Dearborn, supra, 303 (opinion of Williams, J.), and concluded that the pre-amendment scheme provided "legal accountability through sufficient standards of delegation”. Id., 323.
Justice Coleman, also upholding the pre-amendatory scheme, similarly found the act’s standards sufficient to sanction the delegation: "The final decision of the arbitrator is made pursuant to the adequate guidelines of § 9.” Id., 280 (opinion of Coleman, J.).
Justice Levin’s opinion likewise found sufficient the adequacy of the act’s standards:
"Generally, when legislation is challenged as an invalid delegation of legislative power, the controversy revolves around the adequacy of the standards * * *.
"The challenged act provides * * * generalized standards to guide the exercise of this delegated power are stated [§ 9 reprinted in footnote]; and the decision is subject to judicial review. All that is generally required has been done.” Id., 259 (opinion of Levin, J.). Justice Kavanagh, concurring separately with Justice Levin, implicitly agreed with this observation of Justice Levin, "satisfied that he has correctly stated the law”. Id., 273 (opinion of T. G. Kavanagh, C.J., concurring with Levin, J.).
See the comments of Justices Coleman, Williams and Levin reprinted in fn 26, supra. It should be emphasized that Justice Levin did not consider this amendment in terms of the standards inquiry.
As discussed in footnote 26, supra, as originally enacted, Act 312 did not provide for last-offer settlement of economic issues. Rather, economic as well as non-economic issues were to be assessed by the § 9 standards alike. The last offer provision of § 8 was introduced into the act by 1972 PA 127. Although that provision was therefore not before this Court in its 1975 consideration of the act, both Justices Coleman and Williams commented favorably on this amendment in dicta, respectively as follows:
"The final decision of the arbitrator is made pursuant to the
*464adequate guidelines of § 9. The arbitrator resolves the dispute by selecting a bargaining position proposed by a party or by fashioning a compromise position. The arbitrator, acting as an adjunct to the PERA bargaining process, is not at liberty to impose his own solutions or to go beyond the boundaries established by the parties’ bargaining positions. The arbitrator’s singular duty is to fashion a workable resolution for the dispute in keeping with the limits set by the parties and the dynamics of the particular bargaining situation.6 Even this limited decision may be appealed to the courts.” Dearborn, supra, 280-281 (opinion of Coleman, J.).
"6 Indeed, the 1972 amendments to Act 312 have made the arbitrator’s duty even more circumscribed. When resolving a disputed economic matter the arbitrator must select the 'last best offer’ that more closely reflects the guidelines found in § 9 * *
"A subsequent amendment provides a further constraint on the authority of the panel in the requirement to consider only the last offer of settlement made by each party for each economic issue. This also encourages good-faith bargaining by the parties, as it prevents submission of an offer so outlandish as to effectively require acceptance of the other’s position. Not only is the panel restricted to accepting or rejecting the last proposal, it must base its determinations on these standards, [§ 9].” Id., 297 (opinion of Williams, J.).
See New Jersey State Policemen’s Benevolent Ass’n v Town of Irvington, 80 NJ 271; 403 A2d 473; 102 LRRM 2169 (1979); Arlington v Board of Conciliation & Arbitration, 370 Mass 769; 352 NE2d 914 (1976).
See fn 30, supra.
Amsterdam v Helsby, 37 NY2d 19, 27, 37 fn 4; 371 NYS2d 404; 332 NE2d 290, 293, 299 fn 4 (1975) ("[The Legislature] has also established specific standards which must be followed by such a panel [NY Civil Service Law (McKinney), § 209, subd 4, par (c), cl (v).] [The four §209 standards to be “take(n) into consideration” are enumerated in the concurring opinion, p 37, fn 4.]”); Harney v Russo, 435 Pa 183, 189; 255 A2d 560, 563 (1969) (Despite the lack of other precise standards, the. constitutional mandate that arbitrators act "in accordance with law” was sufficient in view of the legislative policy to protect the public from strikes by municipal police and fire fighters: "To require a more explicit statement of legislative policy in a statute calling for labor arbitration would be sheer folly.”); Spokane v Spokane Police Guild, 87 Wash 2d 457, 463; 553 P2d 1316, 1320 (1976); City of Warwick v Warwick Regular Firemen’s Ass’n, 106 RI 109, 117-118; 256 A2d 206, 211 (1969) ("The legislature in [RI Gen Laws] § 28-9.1-10 sets out specifically a number of comprehensive limitations on the actions of a board of arbitration when exercising the power delegated. They require that certain factors ’* * * be given weight by the arbitrators in arriving at a decision * * V ’•’). See East Providence v Local 850, International Ass’n of Fire Fighters, 117 RI 329, 333-336; 366 A2d 1151, 1153-1155 (1976); In the Matter of New Jersey Bell Telephone Co v Communications Workers of America, 5 NJ 354, 370-372; 75 A2d 721, 728-730 (1950); New Jersey State Policemen’s Benevolent Ass’n v Town of Irvington, 80 NJ 271, 291-292; 403 A2d 473, 480-481; 102 LRRM 2169, 2174-2175 (1979). See generally Anno, 68 ALR3d 885, 902-908.
Division 540, Amalgamated Transit Union v Mercer County Improvement Authority, 76 NJ 245, 252; 386 A2d 1290, 1294 (1978) (The Court implied the "inherent” standards that the arbitrators must: act within the scope of statutory authority; consider the public interest as well as the decision’s impact; act fairly and reasonably to stabilize and promote labor peace; and, make adequate and sufficient findings.); Richfield v Local No 1215, International Ass’n of Fire Fighters, 276 NW2d 42, 46-47 (Minn, 1979) (Sufficient standards provided although the only specific guideline was found in the act’s provision that arbitration panel must give "due consideration to the statutory rights and obligations of public employers to officially manage and conduct its operations within the legal limitations surrounding the financing of such operations”.) See Biddeford v Biddeford Teachers Ass’n, 304 A2d 387, 402, 412 (Me, 1973). Fire Fighters Union, Local 1186 v Vallejo, 12 Cal 3d 608, 613, fn 3; 526 P2d 971, 974, fn 3; 116 Cal Rptr 507 (1974). See generally Anno: 68 ALR3d 885.
Medford Fire Fighters Ass’n v Medford, 40 Or App 519, — fn 9; 595 P2d 1268, 1272 fn 9 (1979); Arlington v Board of Conciliation & Arbitration, 370 Mass 769, 775 fn 5; 352 NE2d 914, 919 fn 5 (1976). *466See City of Warwick v Warwick Regular Firemen’s Ass’n, 106 RI 109, 117-118; 256 A2d 206, 211 (1969).
Although the Connecticut Superior Court in Town of Berlin v Santaguida, 98 LRRM 3259, 3265 (Conn Superior Court, 1978), ruled the state’s act unconstitutional on the grounds that it failed to provide either sufficient standards or judicial review and evidenced insufficient political accountability, the court had this to say with respect to the standards issue:
"The standards contained in the act, which are too imprecise to properly guide an arbitration panel in its decision-making, give arbitrators unbridled flexibility and will facilitate, rather than guard against arbitrary action by arbitration panels. When the standards set forth in the act are compared to the more precise standards included in similar arbitration statutes in other jurisdictions, the inadequacy of the act’s standards is even more striking. See [Mass Ann Laws, ch 150E, § 9, note; MCL 423.239; MSA 17.455(39); NY Civil Service Law (McKinney), § 209, subd 4, par (c), cl (v); RI Gen Laws, § 28-9.1-10].”
Justice Levin concentrated his efforts on whether the scheme violated "[t]he constitutional principle restricting the delegation of legislative power * * * to resolve a labor dispute to persons other than government officials or tribunals” enlisted as members of an arbitral panel pursuant to the procedures of pre-amendment § 4— delegate selection — and § 5 — chairperson selection. Dearborn, supra, 246 (opinion of Levin, J.). Primarily utilizing Professor Davis’ "safeguards” approach to legislative delegation, and after finding the § 9 standards adequate, Justice Levin generally ruled the scheme unconstitutional but appended the following instructive caveat:
"To avoid possible misunderstanding, we add that our holding does not preclude the Legislature from vesting the authority to resolve disputes concerning public employees in a governmental officer or agency with continuing responsibility for the day-to-day exercise of that delegated power. Such a decision-maker (arbitrator) would not be 'expendable’ but, rather, would be responsible through the appointing authority to the electorate for the manner in which the delegated power is exercised.” Id., 272.
Justice Kavanagh concurred with Justice Levin but wrote separately to amplify Justice Levin’s caveat:
"Although the present law’s provision for hit-and-run arbitrators is constitutionally defective, a law providing for a continuing politically responsible arbitrator could meet the constitution’s demands.” Id., 273. (T. G. Kavanagh, C.J., concurring with Levin, J.).
Dearborn, supra, 241-242 (opinion of Levin, J.), 273 (opinion of T. G. Kavanagh, C.J., concurring with Levin, J.).
Dearborn, supra, 325 (opinion of Williams, J.).
Dearborn, supra, 321-323 (opinion of Williams, J.), 287-289 (opinion of Coleman, J.) (The pre-amended act is a "balanced, reasonable and fair implementation of a constitutional directive”, id, 284, in reaction to which "[o]ur legislators balanced the competing interests with admirable skill”, id, 287).
See fn 1, supra, and accompanying text.
Justice Coleman commented on the pre-amendment tenure of panel members in the following terms:
"Although the Legislature could have established another bureaucracy, it chose short-term panels to meet impasses immediately — no matter how many or where they might occur simultaneously. The duties do not require office work outside of th§ immediate arbitration activity, so a permanent staff could prove costly and unnecessary or inadequate. (There could be many or no impasses within a given span of time.) The Legislature also could have believed bias and corruption less likely to settle into these panels.” Dearborn, supra, 285 (opinion of Coleman, J.).
Zemetis, Compulsory Binding Arbitration for Municipal Employees in Connecticut: Constitutional? Town of Berlin v Santaguida, 11 Conn L Rev 583, 592-593 (1979). See Richfield v Local No 1215, International Ass’n of Fire Fighters, 276 NW2d 42, 47 (Minn, 1979).
See fns 31 and 49, supra.
See City of Warwick v Warwick Regular Firemen’s Ass’n, 106 RI 109, 114-115; 256 A2d 206, 209 (1969)..
See fn 49, supra.
MCL 423.3; MSA 17.454(3); MCL 423.4; MSA 17.454(4).
The city contends, in part, that exercise of the § 5 peremptory strike of each § 4 delegate against the MERC nominees is no more than a hollow contrivance aimed at sustaining the impression that the alleged accountability deficiencies of the original scheme have been eradicated without materially altering the chairperson selection mechanism.
Any time MERC submits three names to the delegates, it is representing that it is satisfied that any one of the nominees would be qualified to arbitrate that particular contract dispute. Even if, as the city suggests, in certain instances the delegates will eliminate two of the three nominees, thereby leaving MERC with the Hobson’s choice of selecting the only remaining nominee, the MERC will have nonetheless initially selected who will be on the MERC permanent panel as well as which three of those panelists will be offered as nominees to the delegates. The decision as to which panelist will be enlisted to serve as chairperson, as well as which will be selected as a nominee, will always be made by MERC in the final instance, thereby rendering both MERC and, derivatively, the Governor, accountable for the manner in which the chairperson discharges his or her duties.
Similar mechanisms for the selection of arbitration panel members have been upheld in Richfield v Local No 1215, International Ass’n of Fire Fighters, 276 NW2d 42, 44-45 (Minn, 1979), and Arlington v Board of Conciliation & Arbitration, 370 Mass 769; 352 NE2d 914 (1976) (construing a provision similar to pre-amendment § 5 of Act 312).
The majority of decisions from other jurisdictions have rejected *473the "unaccountability” argument, generally treating such attacks as directed more "to the wisdom rather than the constitutional permissibility of the delegation of authority to an arbitrator to formulate a binding public employment agreement”. Medford Fire Fighters Ass’n v Medford, 40 Or App 519, —; 595 P2d 1268, 1271 (1979).
In Richfield v Local No 1215, International Ass’n of Fire Fighters, 276 NW2d 42, 47 (Minn, 1979), the Minnesota Supreme Court offered the following insightful analysis in finding sufficient accountability:
"It is also insisted that the arbitrators are not accountable to the electorate with respect to decisions that involve fundamental determinations of public policy.
"There is also a pragmatic reason for the legislature’s removal of the arbitrators from the immediate pressures of public opinion. The arbitrators’ position is inherently one of trust; the parties must feel confident that the panel will listen to their positions, weigh the evidence, consider the panel’s statutory obligations, and come to a reasonable decision. The legislature may well have believed that exposing the arbitrators to more direct public input would influence the panels and undermine the effort to prevent work stoppages.”
Likewise, in Medford, supra, —, the Oregon Court of Appeals provided the following treatment to find the act constitutional:
"As to the City’s contention that the arbitrator is neither elected nor otherwise politically responsible, we observe that an arbitrator appointed by ERB to carry out specified statutory functions acts in a public capacity. He is not to have a personal interest in the subject of the arbitration; therefore, this case is not analogous to cases in which the Supreme Court held unconstitutional statutes which delegated price-setting powers to interested private parties. [Citations omitted.] The arbitrator’s decision is governed by the statutory criteria in [Or Rev Stat, § ] 243.746(4), set out above. The delegation of authority to the arbitrator does not create any substantial danger that his decision will be based on private interest.” (Footnotes omitted.)
The Massachusetts Supreme Court in Arlington v Board of Conciliation & Arbitration, 370 Mass 769, 779-780; 352 NE2d 914, 921-922 (1976), stated:
"Furthermore, the town vigorously argues that this particular scheme, in that it imposes a decision of 'politically unaccountable’ arbitrators against the wishes of popularly elected local goverment officials, is not consonant with the proper 'exercise of political power in a representative democracy.’ While we do not question the respectability of the political philosophy articulated or the apparent sincerity with which it, is expressed, the town fails to give this argument constitutional content.”
The New Jersey Supreme Court in Division 540, Amalgamated Transit Union v Mercer County Improvement Authority, 76 NJ 245, 251; 386 A2d 1290, 1293 (1978), reviewed the authorities and concluded that "most of the cases that have dealt with the question [of alleged unlawful delegation of public authority and responsibility to a private person(s)] have sustained the concept as an innovative way to avoid the morass of deadlocked labor disputes in the public sector”.
Although the city relies on case law from other jurisdictions holding compulsory arbitration acts unconstitutional, those decisions are clearly distinguishable from the instant matter.
Sioux Falls v Sioux Falls Fire Fighters, Local 814, 89 SD 455; 234 NW2d 35 (1975), is cited as holding unconstitutional, as an unlawful delegation, a similar compulsory arbitration statute. The Court, however, expressly distinguished its constitutional provisions from Michigan’s as well as from other states’:
"The defendants urge this court to accept the reasoning of either the Michigan or Rhode Island courts upholding binding arbitration. The distinction between those decisions and our own in this case lies not only in the history of our constitutional provision but also on differing constitutional provisions.
"Michigan, as does Pennsylvania, has a speciñc constitutional provision which governs. [Const 1963, art 4, § 48. Dearborn Fire Fighters Union Local No 412 v Dearborn, 42 Mich App 51; 201 NW2d 650 (1972)]. Rhode Island, on the other hand, had no provision in its constitution of like import as our Article III, § 26 to confront the court. City of Warwick v Warwick Regular Firemen’s Ass’n, [106 RI 109; 256 A2d 206 (1969)].” 89 SD 460 (emphasis supplied).
The city also relies on Greeley Police Union v City Council of Greeley, 191 Colo 419; 553 P2d 790 (1976), in which the Colorado Supreme Court disapproved a proposed city charter amendment authorizing binding arbitration. Colorado’s constitution also contained the same non-delegation constitutional provision as did South Dakota’s; the Colorado Court expressly relied on the Sioux Falls decision; the Colorado Court merely extended its policy of disapproving any public-sector arbitration, even grievance arbitration, as contrary to public policy unlike the Michigan policy; and, the disputed charter amendment would have provided for the selection of the arbitrator by the parties alone. The decision in Bagley v Manhattan Beach, 18 Cal 3d 22, 24-25; 553 P2d 1140; 132 Cal Rptr 668; 93 LRRM 2435 (1976), is also clearly distinguishable because that legislation did not permit the city to fix salaries by arbitration.
Although the Utah Supreme Court in Salt Lake City v International Ass’n of Fire Fighters, 563 P2d 786, 789 (Utah, 1977), declared its arbitration statute unconstitutional, the statute provided no standards, procedures or opportunity for judicial review. The Utah scheme clearly differs from Act 312.
Finally, the trial court decision in Town of Berlin v Santaguida, 98 LRRM 3259 (Conn Superior Court, 1978), is equally ofno persuasiveness. There, the court found a similar scheme invalid as providing no standards whatever. In fact, the court expressly contrasted that deficiency with the ample standards of Michigan, Massachusetts and various other states. See fn 42, supra. The Connecticut statute similarly was wanting in any judicial review. The Connecticut legislature has since responded by amending the statute to include provisions similar to those contained in Michigan’s current law.
*475The decisions on which appellant relies have been roundly criticized. Case Note, The Uncertain Status of Public Sector Labor Arbitration in Colorado: Greeley Police Union v City Council, 48 Colo L Rev 451 (1977); Zemetis, Compulsory Binding Arbitration for Municipal Employees in Connecticut: Constitutional? Town of Berlin v Santaguida, 11 Conn L Rev 583 (1979); Comment, Salt Lake City v International Ass’n of Firelighters: A Responsive Analysis and Proposal for Public Sector Bargaining in Utah, 1977 Utah L Rev 457.
Dearborn, supra, 316, 323 (opinion of Williams, J.):
"If we push through the thicket of language which has grown up around this issue, we find what we are all really concerned about is not what the Legislature can or cannot give away, and what the circumstances of such donations should be, but rather, what the people can or cannot give away. What the people cannot give away seems to be public responsibility and accountability in the management of its business, whatever the managers .are called.”
An authority on public sector collective bargaining and interest arbitration, Arvid Anderson, has written in a thoughtful law review article that the "political process” argument is "faulty”:
"A frequently heard objection to interest arbitration in the public sector is that it removes from elected officials the ultimate power to fix wages and other terms and conditions of employment and thus constitutes a 'threat to the ability of elected officials to continue to set public policy priorities for use of public funds * *
"[T]he decision of the panel is not purely political, for the panel’s award must adhere to the statutory standards, and be within the lawful scope of bargaining and is subject to judicial review. The existence of judicial review does not mean that it will always be utilized, nor that the judges will find themselves compelled to decide *476terms and conditions of employment for public employees. If past experience is taken as a guide, the majority of arbitration awards will be confirmed by the courts, and any awards that are found to be contrary to law will be sent back for a further arbitration proceeding.” Anderson, MacDonald & O’Reilly, Impasse Resolution in Public Sector Collective Bargaining — An Examination of Compulsory Interest Arbitration in New York, 51 St John’s L Rev 453, 512-513 (1977).
A second answer to the general contention that compulsory arbitration procedures in the public sector under laws like Act 312 are inimical to the concepts of representative government is found in the writings of Dr. Charles Rehmus of the University of Michigan, Co-Chairman of the Institute of Labor and Industrial Relations of the University of Michigan and Wayne State University, and currently Chairperson of MERC. In a paper on Legislated Interest Arbitration to the 27th Annual Winter meeting of the Industrial Relations Research Association (1974), Dr. Rehmus stated:
"Answers to such questions must in part be philosophical and in part practical. Rampant disregard of antistrike laws also erodes the foundations of government. If binding arbitration is necessary and sufficient to forestall illegal strikes, it too strengthens our democratic system.
"Secondly, it is not at all clear that binding arbitration awards invariably represent an imposition of terms to which the parties themselves are unalterably opposed. Nearly two-thirds of the arbitration awards rendered by tripartite panels thus far in Michigan have been unanimous, and a national survey of American Arbitration Association cases shows the same. * * * Although some fear that arbitrators will impose unworkable or unreasonable contract terms on bargaining parties, experience to date is proving that arbitration has not resulted in a large number of third-party determinations imposed without regard to the needs or wishes of the parties.” Rehmus, Legislated Interest Arbitration, Proceedings of the 27th Annual Winter Meeting of the Industrial Relations Research Association (December 28-29, 1974), pp 307, 308-309.
As noted by Professor Joseph R. Grodin in Grodin, Political Aspects of Public Sector Interest Arbitration, 64 Cal L Rev 678, 693 (1976):
"An attempt to make arbitrators more politically responsible by electing them, or by having them appointed by elected officials to serve on a continuing basis, poses a difficult dilemma. The problem of political responsibility arises initially from the fact that arbitrators may be called upon to determine policy issues otherwise subject to the local legislative process. But if the arbitrator is made politically responsible to the local electorate, which is in effect a party to the dispute, then arbitration loses its neutral character; and to the extent that the arbitrator’s constituency is the same as that of the legislative body that would otherwise exercise authority over the policy questions posed, the process becomes redundant.”
See City of Warwick v Warwick Regular Firemen’s Ass’n, 106 RI 109, 117-118; 256 A2d 206, 211 (1969).
See fn 27, supra.
See fn 28, supra.
See fn 28, supra.
See Britton, Judicial Review and Enforcement of the Arbitration Award, 16 Trial (No. 3) 22, 24-25 (March, 1980).
Amsterdam v Helsby, 37 NY2d 19, 38-39; 371 NYS2d 404; 332 NE2d 290, 300-301 (1975) (by judicial interpretation); Division 540, Amalgamated Transit Union v Mercer County Improvement Authority, 76 NJ 245, 253-254; 386 A2d 1290, 1294 (1978) (by judicial interpretation); Medford Fire Fighters Ass’n v Medford, 40 Or App 519, — fn 1, —; 595 P2d 1268, 1269-1270 fn 1, 1272 (1979); Richfield v Local No 1215, International Ass’n of Fire Fighters, 276 NW2d 42, 47 (Minn, 1979); Spokane v Spokane Police Guild, 87 Wash 2d 457, 463; 553 P2d 1316, 1319-1320 (1976). Even in those cases where similar *480statutory schemes were ruled unconstitutional, the necessity for judicial review was expressed. Town of Berlin v Santaguida, 98 LRRM 3259, 3265 (Conn Superior Court, 1978) (no provision for judicial review); Salt Lake City v International Ass’n of Firefighters, 563 P2d 786, 789 (Utah, 1977) (no provision for judicial review).
Our review of the interrelationship between Act 312’s sections requires us to overrule that part of Alpena v Alpena Fire Fighters Ass’n, AFL-CIO, 56 Mich App 568, 571-572; 224 NW2d 672 (1974), which held that failure to base an arbitral award on the applicable § 9 factors was not reviewable under § 12 of the act, but rather was reviewable under the constitutional requirement of due process.
The city actually proposed a two-plan alternative in their last offer. In the first plan the city offered no COLA, but offered wage increases of 4.8%, 4% and 4% in each of the three years of the contract. The city’s second plan offered a settlement identical to that reached by the city and the American Federation of State, County, and Municipal Employees (AFSCME) after a short strike. Although the second alternative plan did provide for some COLA, it was less advantageous to the DPOA than the COLA under its prior contract. For example, the city’s COLA offering in plan 2 required a greater increase in the consumer price index to trigger a cost of living allowance, provided no roll-in of COLA payments into base wage rates and provided no benefit from consumer price index increases above the "cap”.
On the city’s petition for judicial review of the October 18, 1978 LSA award as to wages, COLA and sick leave, the circuit court remanded the award to the arbitration panel on December 18, 1978 for supplemental findings of fact on wages and COLA, and directed the panel to adopt the last offer of one of the parties concerning the economic aspect of sick leave. On February 20, 1979 the circuit court *489upheld the arbitration panel’s January 24, 1979 supplemental decision which reaffirmed its earlier decision adopting the LSA’s last offer with respect to wages and COLA. Detroit v Detroit Police Lieutenants & Sergeants Ass’n (Wayne Circuit Court, Docket No. 78-836-638-AV, February 20, 1979) (order of affirmance). The circuit court’s order of enforcement of the award was stayed by the Court of Appeals, until completion of the appeals process, only as to the retroactive period between July 1, 1977 and January 24, 1979. In an unpublished per curiam dated October 19, 1979, the Court of Appeals affirmed the circuit court’s decision upholding the arbitration panel’s award. (Mich App Docket No. 44095, October 19, 1979) (affirmance of trial court). The city appealed this decision to us on November 8, 1979 and we held the case in abeyance by order of February 7, 1980 pending the resolution of the instant case (Docket No. 64065).
The LSA award was placed into evidence as DPOA Exhibit 56.
The city’s brief recognizes that the trial court noted in its opinion that the city failed to provide the budget to show how expenditures were made. The city did introduce a post-award affidavit of the city’s budget director which tends to show, in a general way, that enforcement of the panel’s award would have a detrimental effect on the city’s public services. However, this affidavit is inadmissible for purposes of judicial review of the award since it was not before the arbitration panel at the time it rendered its award. See also the comments of the trial judge on the limited value of this affidavit.
Taking into account all of the terms and conditions of the city’s alternate wage plan set out in fn 66 supra, the total benefits to the DPOA under this alternate plan, including COLA, would also amount, approximately, to wage increases of 4.8%, 4%, and 4% over the three-year life of the labor contract.
Alpena v Alpena Fire Fighters Ass’n, AFL-CIO, 56 Mich App 568; 224 NW2d 672 (1974), is overruled insofar as it held that an Act 312 arbitration panel need not consider a particular factor simply because the parties have failed to present evidence on it. Id., 573.
The failure to introduce comparability evidence on residency is patently different from either the city’s decision not to introduce its budget, discussed supra, p 488, or the chairman’s exclusion of City’s Exhibit 30, discussed supra, p 493. The present situation involves the total failure of either party to introduce any evidence whatsoever on the applicable fourth factor, with the consequences that the panel was unable to consider a factor which the Legislature has deemed relevant in making an Act 312 award. In contradistinction to this total lack of evidence, the city’s budget and Exhibit 30 would merely have been pieces of evidence in addition to others which were introduced relating to its ability to pay under the third factor. These omissions from evidence, therefore, did not serve to deprive the panel of the ability to consider the applicable third factor.
Since we have disallowed the panel’s residency hardship exemption award favorable to the DPOA, there is no need to respond to the city’s contention that the panel’s hardship exemption award, as promulgated on May 21, 1979 in a supplemental opinion and award, is invalid because the panel lacked the jurisdiction to unilaterally alter its original December 20, 1978 award with which the city claims it had complied.
It has long been established that the question of interest in Michigan is purely statutory. Solakis v Roberts, 395 Mich 13, 19, fn 2; 233 NW2d 1 (1975).
The city’s contention that the wages and COLA portions of the award are unsupported rests upon its claims that: (1) no record evidence supports the chairman’s statement that failure to award the DPOA the same COLA awarded police lieutenants and sergeants *508would engender "despair, frustration and indeed, hostility” in day-today police operations; (2) the panel’s failure to give equal consideration to all decisional criteria provided by the legislature violated the act’s design and hence the award was not "authorized by law”, and cannot survive review under Const 1963, art 6, § 28, which the city urges as the applicable standard.
Dearborn Fire Fighters v Dearborn, supra, pp 241-242 (Levin, J.).