The State Boundary Commission was created to consider petitions for the incorporation and consolidation of cities and villages. Its powers were subsequently enlarged to include petitions for annexation of territory to a city.
In these actions, consolidated on appeal, town-, ships from which the commission ordered territory detached and annexed to adjoining cities and persons residing in those townships challenge the constitutionality of the enabling legislation.
Court of Appeals panels, affirming judgments of the circuit courts, held the enabling legislation to be violative of the Title-Object and Reenact-Publish Clauses of the Constitution, but disallowed the other constitutional, procedural and substantive challenges of the townships. We reverse.
The enabling legislation is constitutional.1 We agree with the Court of Appeals that the other *650challenges should be denied except that the commission’s adoption of an erroneous principle in the Novi annexation requires remand to it of the petition in that case.
After the circuit court had set aside the Midland annexation ordered by the commission, the annexation procedures of prior law were invoked. Midland Township then challenged annexation under those procedures; the circuit court rejected that challenge and the Court of Appeals affirmed. The issues raised in that challenge need not be further considered because the enabling legislation (here held to be constitutional) by its terms supersedes the procedures of prior law.
I
Before creation of the State Boundary Commission, the procedures for the incorporation, consolidation or alteration of boundaries of cities were set forth in the home rule cities act.2 By enactment separate from that act, the commission was created in 1968 with authority limited to incorporation and consolidation of cities and villages.3 The powers of the commission were extended to annexations by a 1970 amendment of the annexation procedures of the home rule cities act.4
The 1970 amendment is entitled: "AN ACT to amend section 9 of [the home rule cities act], entitled, as amended 'An act to provide for the incorporation of cities and for revising and amending their charters’ ”.
In holding the 1970 amendment violative of the Title-Object Clause, the Court of Appeals reasoned *651that while the title of the home rule cities act "is sufficient to encompass the annexation authority of cities” it was not "sufficient to encompass the subject of the annexation jurisdiction of an entirely separate state agency”.5
A
The Title-Object Clause provides:
"No law shall embrace more than one object, which shall be expressed in its title. No bill shall be altered or amended on its passage through either house so as to change its original purpose as determined by its total content and not alone by its title.” Const 1963, art 4, §24.
The question whether the title of the home rule cities act is sufficient to encompass annexation procedures was resolved in Village of Kingsford v Cudlip, 258 Mich 144; 241 NW 893 (1932), where this Court considered the question in the context of annexation of township territory to a village under a village governance act.6 The Court observed that the title of the home rule cities act *652and the village act were identical — except that one speaks of the incorporation of "cities” and the other of "villages” — and declared:
"Both of these acts have been many times before this court, and, so far as we have been able to discover, this is the first time the sufficiency of the present titles has been assailed. Both the legislature and the courts have treated these titles as sufficient to sustain the provisions for change of boundaries. The necessity of such changes from time to time is apparent, and in our opinion the power conferred upon the legislature by the Constitution 'to provide by a general law for the incorporation’ may fairly be said to include the change of boundaries when needed.” Id, 151-152.7
Village of Kingsford was followed in Hall v Calhoun County Board of Supervisors, 373 Mich 642, 647; 130 NW2d 414 (1964), approving annexation pursuant to the procedures of the home rule cities act of one city by another against a contention that "this would amount to a disincorporation of the annexed city, and the title of the [home rule cities act] has reference to the incorporation only”:
"We have said that the act’s title is broad enough to encompass annexation, Village of Kingsford v Cudlip, 258 Mich 144, 151, 152, and this being so we are not prepared to say that it is not broad enough to encompass annexation of a city. We are committed to a liberal interpretation of the constitutional provision concerning titles of legislative enactments.” Id, p 648.
*653Acknowledging that Village of Kingsford and Hall establish that the title of the home rule cities act is sufficient to encompass annexation procedures, the townships contend that those cases have been superseded by Alan v Wayne County, 388 Mich 210; 200 NW2d 628; 67 ALR3d 1079 (1972), where this Court declared that if it were intended by the building authority act,8 as amended, "as defendants claim, to permit taxation without limitation to pay fixed rentals, then [the body of that act] exceeds the scope of the title”, because the title of that act limits the body to "the issuance of revenue bonds by such authorities”. Id, pp 257, 358.
The Title-Object issue in Alan was different from the issue here presented of the sufficiency of the title. The issue in Alan was whether the body of the act exceeded the scope of the title, "speaking,” as expressed in People v Stanton, 400 Mich 192, 195; 253 NW2d 650 (1977), "more broadly than its restrictively-speaking title”. Similarly, see Maki v East Tawas, 385 Mich 151; 188 NW2d 593 (1971).
Where the issue is the sufficiency of the notice provided by the title, it is "established that the title need not serve as an index of all that the act contains”. People v Milton, 393 Mich 234, 246-247; 224 NW2d 266 (1974).
"An abridgment of all those sections is not essential to a sufficient title. While it contains various related provisions not directly indicated or enumerated in the title, under the construction of this constitutional requirement, as many times reviewed by this court, if the act centers to one main general object or purpose which the title comprehensively declares, though in general terms, and if provisions in the body of the act not *654directly mentioned in the title are germane, auxiliary, or incidental to that general purpose, the constitutional requirement is met.” Loomis v Rogers, 197 Mich 265, 271; 163 NW 1018 (1917) (emphasis supplied).
As with codifications,9 an act providing for the functioning of a city covers many subjects which might have been dealt with in separate acts. The object of such an act is necessarily broad-ranging and comprehensive. "The home rule act and other acts providing for the incorporation of cities and other units of local government have been interpreted as having as their object anything germane to their functioning.” Detroit Board of Street Railway Commissioners v Wayne County, 18 Mich App 614, 623; 171 NW2d 669 (1969).
B
Whether a provision is germane depends on its relationship to the object of the act, not who is charged with implementing the provision. Although an act centers on the functioning of city government and its title so indicates, it is not consequential for purposes of the Title-Object Clause whether a city, county or state official or agency is charged by the act with participation in implementation of a provision of the act as long as the provision to be implemented is germane to the functioning of city government.
Nor is it of any importance that city annexation procedures, before and after the 1970 amendment set forth in the home rule cities act, might have been located in the enabling act creating the com*655mission. Paraphrasing People v Milton, supra, p 248, the correct question is not whether the Legislature might have included provisions concerning city annexation procedures in the 1968 act but whether such provisions and procedures are germane to the purpose of the home rule cities act. There is " 'no constitutional requirement that the legislature do a tidy job in legislating. * * * The constitutional requirement is satisfied if the bits and pieces so enacted are embraced in the object expressed in the title of the amendatory act and the act being amended’ ”. Id, p 242.
The further contention of the townships that the title of the 1970 amendment should have indicated that it was "effectually amending” the 1968 enabling act and that the title of that act should similarly have been amended is predicated on the erroneous premise that the 1970 amendment of the home rule cities act amended the 1968 act. Although the powers and duties of the commission were enlarged by the 1970 amendment, that was accomplished by amendment of the home rule cities act without amendment of the 1968 act which created the commission.
The Constitution does not require that the title of an act which amends another act by implication or the title of the act so amended reflect the amendment so implied; manifestly the concept of implied amendment would be nullified if express amendment of the body or title of an impliedly amended statute were required.
Perusal of the contents of the home rule cities act indicates that a narrow construction of this constitutional limitation and of the title of that act might render a number of its provisions unconstitutional.
It is, similarly, apparent on examination of the *656statutes generally10 that additional powers and duties are often conferred on public officials and agencies who derive their principal responsibility from other statutory provisions or from the Constitution without specific reference in the entitlement of the statute conferring such additional powers and duties that the body of the statute provides.
The Court of Appeals erred in holding that the title of an act concerning the governance of a city must directly indicate that the body of the act confers authority on a state agency.
On the authority of Village of Kingsford and Hall, we hold that procedures for the annexation of territory to a city are germane to the functioning of a city and that the procedures provided for in the 1970 amendment are embraced in the object expressed in the titles of the 1970 amendment and of the home rule cities act.
II
The townships contend that the "failure of the Legislature to reenact and publish at length §§ 6, 8, 8a and 14 of the Home Rule Cities Act * * * which were amended by implication” and to re*657enact and republish the "portions of the state boundary commission act amended by implication” by the 1970 amendment is violative of the Reenact-Publish Clause, which provides:
"No law shall be revised, altered or amended by reference to its title only. The section or sections of the act altered or amended shall be re-enacted and published at length.” Const 1963, art 4, § 25.
The Court of Appeals, agreeing with the townships, ruled that the Legislature had unconstitutionally attempted to amend the 1968 act by putting in the home rule cities act specific words to amend the 1968 act without reenacting and republishing the 1968 act "contrary to Mok [v Detroit Building & Savings Ass’n No 4, 30 Mich 511 (1875)] and Alan”. 11
A
In Mok, this Court held unconstitutional an 1869 act providing for the incorporation of building and savings associations by reference to an 1855 act (consisting of 12 lines including its title) for the formation of corporations for building and leasing houses and other tenements which in turn referred for its substance to an 1853 act authorizing the formation pf corppratipns for mining, smelting or manufacturing purposes. The Court declared that the 1869 act incorporated the 1853 act by reference and expressly changed the provisions so incorporated: Section 4 of the 1853 act required that the articles of association state the *658amount of capital stock actually paid in;12 the 1869 act provided that the articles required by § 3 of that act "need not state the amount of capital stock actually paid in”.13
The 1869 act added to the requirements of §§ 4 and 5 of the 1853 act by express reference to those sections.14
The Court declared that those provisions and references were express amendments of provisions of the act incorporated by reference and were violative of the constitutional limitation:
"Amendments of statutes by implication, we have held, are not forbidden by [the constitution]: People [ex rel Drake] v Mahaney, 13 Mich 481 [1865]; Underwood v McDuffee, 15 Mich 361 [1867]. But this is not a case of that nature, as all the alterations we have reason to suppose the legislature designed to make in the act of 1853, to adapt it to the purposes of the act of 1869, are made in express terms.
"While the act of 1853 is left untouched as to the organizations contemplated by its provisions, it is, for the purposes of building and savings associations, altered in most important particulars in disregard of the constitutional requirement. The fourth and fifth sections are expressly amended without re-enacting them in full, and perhaps the same should be said of the eleventh, while the others are capable of being made available only by treating the act as revised to meet the exigencies of the case.” Mok v Detroit Building & Savings Ass’n No 4, supra, pp 522, 529 (emphasis supplied).
*659In Alan v Wayne County, supra, this Court considered a provision of the building authority act15 authorizing an authority to issue self-liquidating bonds in accordance with and subject to the provisions of the Revenue Bond Act.16 The Court declared that an act that amended the building authority act, "if it purported to substitute full faith and credit for the normal revenue from the property as the source of payment for the authorized bonds,” would offend the Reenact-Publish Clause because it did not reenact and publish at length any part of the Revenue Bond Act as well as the building authority act so amended. "This is because [the building authority act] incorporates [a provision of the Revenue Bond Act] by reference * * * and therefore under Mok, supra, anything [in the building authority act] or any act to amend [the building authority act] that purports 'to dispense with something required by that Act [the Revenue Bond Act], and to make some changes’17 offends Const 1963, art 4, § 25.” Alan, supra, pp 265-266.
The Reenact-Publish question in Alan arose from the incorporation of a provision of the Revenue Bond Act into the building authority act and amending the provision so incorporated which had not been reenacted and republished.
In the instant cases, the 1970 amendment of the home rule cities act, while incorporating by reference provisions of the 1968 act, does not "dispense with” or "change” any provision of the 1968 act. *660The 1970 amendment provides that the commission, in acting on petitions for annexation, has "the same powers and duties” and is to proceed "in accordance with and subject to” the 1968 act.18 Further, the 1970 amendment provides that in the event of a "conflict between the provisions of this act” and the 1968 act, the provisions of the 1968 act "shall govern”. 19 By its terms, the 1970 amendment makes no change or dispensation of any requirement of the 1968 act.
While the 1970 amendment provides for resolution of conflicts between it and the 1968 act — the incorporated act, the 1968 act, "shall govern” — the procedures to be followed appear to be straightforward and uncomplicated. The commission, established under the 1968 act, is to process petitions *661for annexation in accordance with the provisions of the 1968 act "relating to petitions which propose incorporations”. The 1970 amendment, additionally, supplements the provisions relating to incorporations of the 1968 act with provisions peculiar to annexation. The 1970 amendment does not, expressly or otherwise, dispense with or change the provisions of the 1968 act incorporated into the home rule cities act; in contrast with Mok, there is no express amendment of the 1968 act.
B
The 1970 amendment provides that the provisions of §§ 8 and 8a of the home rule cities act "shall not be applicable” to petitions or resolutions filed with the commission, that the provisions of § 14 of the home rule cities act "shall not be applicable” to certain annexations approved by the commission except as in the 1970 amendment provided, and that from the effective date of the 1970 amendment and so long as the 1968 act is in effect "annexation of territory from a township or village to a home rule city shall be as provided in this section and no other means of annexation shall be effective”.20
In People ex rel Drake v Mahaney, 13 Mich 481, 496 (1865), the act before this Court had "an amendatory effect by implication, and by its last section repeals all inconsistent acts”.21 The act repealed specific sections of certain acts and "all acts and parts of acts inconsistent with the provisions of this act”. Rejecting the contention that the act violated the Reenact-Publish Clause, this Court said:
*662"We are unable to see how this conflicts with the provision referred to. If, whenever a new statute is passed, it is necessary that all prior statutes, modified by it by implication should be re-enacted and published at length as modified, then a large portion of the whole code of laws of the state would require to be republished at every session, and parts of it several times over, until, from mere immensity of material, it would be impossible to tell what the law was. If, because an act establishing a police government modifies the powers and duties of sheriffs, constables, water and sewer commissioners, marshals, mayors and justices, and imposes new duties upon the executive and the citizen, it has thereby become necessary to re-enact and republish the0various laws relating to them all as now modified, we shall find, before the act is completed, that it not only embraces a large portion of the general laws of the state, but also that it has become obnoxious to the other provisions referred to, because embracing a large number of objects, only one of which can be covered by its title.” Id, pp 496-497.
Sections 6, 8, 8a, 9 and 14 appear seriatim in the home rule cities act. It is not uncommon for one section of an act to modify, expressly or by implication, another section of the same act. Any amendment of a section of an act may affect other sections of the same act (or indeed of another act) which are not amended, but it has never been thought necessary on that account to reenact the entire act (or other act).
On the same principle that makes it unnecessary to enumerate "all acts and parts of acts inconsistent” (Mahaney, supra) with the provision of a superseding act, there was no need to excise the portions of §§ 6, 8, 8a and 14 superseded by the 1970 amendment of § 9.
The Constitution does not require, nor would a useful purpose be served by reenacting and republishing the defunct portions of §§ 6, 8, 8a and 14; *663the Constitution does not require a useless gesture. Nor does it require that the defunct portions be excised from those sections and the viable portions reenacted and republished. People ex rel Drake v Mahaney, supra; Mok v Detroit Building & Savings Ass’n No 4, supra; Alan v Wayne County, supra.
While this non-express method of legislating may be "confusing” to some and appear to be "lazy”, legislation cannot on that ground be invalidated.22
The townships further assert that there are a number of ambiguities and constructional issues posed by the failure of the Legislature to repeal all the laws concerning incorporation, consolidation and annexation and to start afresh with a comprehensive enactment covering the entire subject matter. Experience teaches that ambiguities and constructional difficulties are inevitable however carefully the Legislature proceeds. Those difficulties do not rise to constitutional dimensions affecting the validity of legislation because they are posed in terms of asserted conflict between the provisions of different acts or sections of the same act as a result of an amending act. If legislation could so easily be overturned, the claims of confusion, lazy legislation and conflict between sections and acts would be an increasing source of litigation, burden and embarrassment to the courts, the Legislature and the public.
Ill
The townships and individual plaintiffs additionally contend:
A. The 1968 act denies equal protection of the *664laws to persons residing in an area containing 100 persons or fewer, who are denied a referendum on a commission order although a referendum is required where more than 100 persons reside in the area;
B. The 1968 act does not provide adequate standards;
C. Proceedings before the commission are a "contested case” within the meaning of the Administrative Procedures Act, and the provisions of that act were not followed;
D. The cities gerrymandered the boundaries to avoid a referendum, and a review of the record in light of the statutory criteria demonstrates that the evidence does not "substantially” support the commission’s rulings or its determinations that the annexations were reasonable and should be approved.23
These contentions ignore the unique nature of annexation proceedings. No city, village, township or person has any vested right or legally protected interest in the boundaries of such governmental units. The Legislature is free to change city, village and township boundaries at will. This was settled for Federal constitutional purposes in Hunter v Pittsburgh, 207 US 161, 178-179; 28 S Ct 40; 52 L Ed 151 (1907), and the principles there established have been observed in subsequent litigation in the courts of this and other states. See Village of Kingsford v Cudlip, supra, p 148. Similarly, see Lansing School District v State Board of Education, 367 Mich 591; 116 NW2d 866 (1962); *665 The Detroit Edison Co v East China Twp School Dist No 3, 247 F Supp 296 (ED Mich, 1965), aff'd 378 F2d 225 (CA 6, 1967); 56 Am Jur 2d, Municipal Corporations, § 50, p 108 and § 57, p 113.
In Hunter the City of Pittsburgh had annexed the City of Allegheny. The statute provided for a referendum with the votes of both cities being aggregated. Pittsburgh, larger than Allegheny, voted in favor of annexation and Allegheny voted against it. Allegheny residents claimed that the procedures violated the Due Process Clause. The Court responded that the Legislature could have constitutionally changed the boundaries without an election:
"Municipal corporations are political subdivisions of the state, created as convenient agencies for exercising such of the governmental powers of the State as may be entrusted to them. For the purpose of executing these powers properly and efficiently they usually are given the power to acquire, hold, and manage personal and real property. The number, nature, and duration of the powers conferred upon these corporations and the territory over which they shall be exercised rests in the absolute discretion of the State. Neither their charters, nor any law conferring governmental powers, or vesting in them property to be used for governmental purposes, or authorizing them to hold or manage such property, or exempting them from taxation upon it, constitutes a contract with the State within the meaning of the Federal Constitution. The State, therefore, at its pleasure, may modify or withdraw all such powers, may take without compensation such property, hold it itself, or vest it in other agencies, expand or contract the territorial area, unite the whole or a part of it with another municipality, repeal the charter and destroy the corporation. All this may be done, conditionally or unconditionally, with or without the consent of the citizens, or even against their protest. In all these respects the State is supreme, and its legislative body, conforming its action to the state constitution, may do *666as it will, unrestrained by any provision of the Constitution of the United States. Although the inhabitants and property owners may by such changes suffer inconvenience, and their property may be lessened in value by the burden of increased taxation, or for any other reason, they have no right by contract or otherwise in the unaltered or continued existence of the corporation or its powers, and there is nothing in the Federal Constitution which protects them from these injurious consequences. The power is in the State and those who legislate for the State are alone responsible for any unjust or oppressive exercise of it.” Id, pp 178-179.
A. Equal Protection
In the instant annexations fewer than 100 persons resided in the territories to be annexed.
The townships and individual plaintiffs, acknowledging the principles enunciated in Hunter, assert that while the Legislature may provide for annexation without an election it is violative of the Equal Protection Clause to provide for a referendum where more than 100 persons reside in the territory to be annexed and deny a referendum where 100 persons or fewer reside in the territory.
In Detroit Edison Co v East China Twp School Dist No 3, supra, where it was contended that a school district should have proceeded by consolidation (subject to referendum in the annexing and annexed districts) rather than annexation (not subject to referendum in the annexing district), the district court rejected an equal protection challenge. The Court of Appeals affirmed based on the abstention doctrine, adding that the district court was correct on the merits. Similarly see Lansing School Dist v State Board of Education, supra, p 599.
We are of the opinion that the challenged classi*667fication bears a substantial relation to the object of the legislation:24 providing a means appropriate to the resolution of disagreements concerning annexation of territory to a city.25
Some territory annexed will be sparsely populated or unpopulated while other territory will be more heavily populated. The challenged classification, responsive to that factual difference, tends to prevent venal abuses which there is reason to believe may occur if few persons (or a small group of persons) have absolute power to prevent an annexation economically advantageous to other persons or the community at large.26 See Weber v Thousand Oaks City Council, 9 Cal 3d 950; 109 Cal Rptr 553; 513 P2d 601 (1973), sustaining against an equal protection challenge a classification providing for a referendum if the area has more than 12 resident registered votes but dispensing with a referendum where there are fewer voters. It was not violative of the Equal Protection Clause to draw a line, and the line drawn (at 100) was not unreasonable.
*668B. Standards
The 1968 act, as incorporated in the home rule cities act by the 1970 amendment,27 provides for a public hearing at which the Commission shall consider the "reasonableness” of the proposed annexation based upon the "criteria” set forth in § 9 of the 1968 act:
"Criteria to be considered by the commission in arriving at a determination shall be:
"(a) Population; population density; land area and land uses; assessed valuation; topography, natural boundaries and drainage basins; the past and probable future urban growth, including population increase and business, commercial and industrial development in the area. Comparative data for the incorporating municipality, and the remaining portion of the unit from which the area will be detached shall be considered.
"(b) Need for organized community services; the present cost and adequacy of governmental services in the area to be incorporated; the probable future needs for services; the practicability of supplying such services in the area to be incorporated; the probable eifect of the proposed incorporation and of alternative courses of action on the cost and adequacy of services in the area to be incorporated and on the remaining portion of the unit from which the area will be detached; the probable increase in taxes in the area to be incorporated in relation to the benefits expected to accrue from incorporation; and the financial ability of the incorporating municipality to maintain urban type services in the area.
*669"(c) The general effect upon the entire community of the proposed action; and the relationship of the proposed action to any established city, village, township, county or regional land use plan.” 1968 PA 191; MCLA 123.1009; MSA 5.2242(9).
In State Highway Commission v Vanderkloot, 392 Mich 159, 166; 220 NW2d 416 (1974), this Court held "that the standard 'necessity’ in the context of the highway condemnation act is a sufficient standard and a constitutional delegation of authority”. We similarly conclude that "reasonableness,” determined based on the statutorily enumerated criteria, is a sufficient guideline for the exercise of commission discretion.28
In this context it is again relevant that the power here delegated does not involve any vested right or legally protected interest. We judge the adequacy of the criteria and standard with that in mind.29 The annexation question is essentially political, and political considerations cannot be avoided whether the power is exercised by the Legislature itself or by an authority to which the power is delegated. The ultimate decision will be a value judgment based on the particular facts and circumstances of the annexation under consideration. It would unduly inhibit both the exercise of the Legislature’s prerogative to delegate the power to decide on annexations and the function of the commission to require greater particularity in the explication of criteria or standards.
*670C. Contested Case
The townships contend that the procedures for contested cases of the Administrative Procedures Act of 1969 apply to commission proceedings and that those procedures were not followed in these annexation proceedings.30 That act provides:
" 'Contested case’ means a proceeding, including but not limited to rate-making, price-fixing and licensing, in which a determination of the legal rights, duties or privileges of a named party is required by law to be made by an agency after an opportunity for an evidentiary hearing. When a hearing is held before an agency and an appeal from its decision is taken to another agency, the hearing and the appeal are deemed to be a continuous proceeding as though before a single agency.” 1969 PA 306; MCLA 24.203(3); MSA 3.560(103)(3) (emphasis supplied).31
We have already expressed our conclusion, based on the Hunter principle, that no governmental *671authority or person has any legal right in the boundaries of a city, village or township. An annexation proceeding is not a "contested case” even though the commission must hold a public hearing and representatives of a city, village or township and other persons have a right to be heard at such a hearing before the commission makes its determination. That procedural right does not create any substantive legal right in a "named party” and, hence, the "legal rights” of a "named party” are not required by the 1968 act and the 1970 amendment to be determined after an opportunity for an evidentiary hearing within the meaning of the Administrative Procedures Act.
The Administrative Procedures Act was designed to provide procedural protection where a personal right, duty or privilege is at stake. Affording the public at large an opportunity to be heard does not create a personal right in the decision; certain decisions are so largely legislative in character, affecting the populace at large without differentiation and not fundamentally a particular person or persons, that no substantive personal right is to be implied from the opportunity to be heard.32
D. Judicial Review
The 1968 act provides for judicial review pursu*672ant to the Administrative Procedures Act.33 The townships additionally rely on the constitutional provision for judicial review of administrative action.34
The Administrative Procedures Act provides for judicial review of errors of law and, paralleling the constitutional provision, for a determination whether the administrative action is supported by "competent, material and substantial evidence on the whole record”. MCLA 24.306(d); MSA 3.560(206)(d).
The key phrase "substantial evidence” has been construed by this Court to require
"a thorough judicial review of administrative deci*673sion, a review which considers the whole record — that is, both sides of the record — not just those portions of the record supporting the findings of the administrative agency. Although such a review does not attain the status of de novo review, it necessarily entails a degree of qualitative and quantitative evaluation of evidence considered by an agency. 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 Commission v Detroit Symphony Orchestra, Inc, 393 Mich 116, 124; 223 NW2d 283 (1974).
The townships contend that to avoid a referendum the cities gerrymandered the boundary of the territory to be annexed so that the number of residents would not exceed 100, and that a review of the record in light of the statutory criteria demonstrates that the evidence does not "substantially” support the commission’s rulings or its determinations that the annexations were reasonable and should be approved.
It is again pertinent that there are no "private rights” (see footnote 34) in the boundaries of cities, villages or townships; accordingly, the constitutional provision concerning judicial review of administrative action does not limit commission proceedings.
Resolution of a controverted annexation unavoidably involves political considerations and the exercise of a large measure of discretion. Evaluation of the record and of the commission’s balancing of the criteria and determination of reasonableness implicates the merits of the proposed an*674nexation and poses considerable risk of drawing the judiciary into the resolution of what continues to be — despite the adoption of the administrative format — essentially a political question.35
No vested right or legally protected interest being involved, the judiciary ought to be especially circumspect in reviewing commission rulings and determinations.
On our consideration of whether the commission’s procedures, rulings and determinations in these cases were consistent with constitutional and statutory requirements and whether the record adequately supports the orders of annexation, we conclude that, with the exception of the Novi annexation, there is no error and the orders of annexation shall be implemented in accordance with the statute.
Midland Township
The commission approved a Midland annexation petition for the site of a proposed Consumers Power nuclear power plant. (See drawing attached.) There were no residents of the power plant site. More than 100 persons resided in the area covered by another annexation petition.
The proposed power plant will supply electricity and steam to Dow Chemical Company plants located in the City of Midland. When the nuclear power plant is placed in operation, Dow will close eight power plants located in the city, resulting in the city’s loss of $8.6 to $12.6 million in state equalized valuation.
The township levies 1 mill and the city 11.3 mills. If the plant is in the township it will gener*675ate tax revenues of $275,000 for the township on an estimated equalized value of $275 million. If the plant is in the city, $1,925,000 would be generated for the city at a reduced millage of 7 mills. The difference in the revenue generated, $1,650,000, would, the Commission concluded, not only "be an asset to the city but to the whole region”.
A reduction of the tax rate to 7 mills, said the commission, would enable Dow "to be much more cost competitive than at the present”. Dow is the "economic life-blood of a multi-county area surrounding the city”. Dow operations in the city are comparatively disadvantaged "due to the level of ad valorem ” taxes. Reestablishing the competitiveness of Dow’s Midland operations "is essential for future growth in the area and the maintenance and expansion of the job market in the Greater Midland area”.
The commission acknowledged that the need for services such as water, sewer, fire and police protection were not major factors in its decision as the power plant would provide many of its own internal services and call on the city or township to act only in a backup capacity.
Midland Township contends that when compared with the statutory criteria in subsections (a) and (b) (see part III B, supra, for text), the findings of the commission do not support the commission’s decision; that the subsection (b) criterion, the probable increase in taxes in the area in relation to the benefits expected to accrue "would, if considered, suggest that the annexation should not take place” and that the commission — relying on the criterion set forth in subsection (c): "[t]he general effect upon the entire community of the proposed action” — improperly "based its result fundamentally *676on a decision to award the tax base to the City of Midland,” and that "[t]o maintain that the commission may ignore the other criteria and use this provision in this way would be to say that the commission can act on any basis it deems suitable from a policy standpoint.”
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. The commission’s decision to "award the tax base” to the City of Midland is supported by record evidence, is not arbitrary and is consistent with the statutory criteria and the standard of reasonableness.
Novi Township
The Novi petition covers seven separate parcels which earlier had been detached from the Village of Novi in circuit court proceedings (see part III F, infra). The seven parcels are located in widely separated sectors on the city’s borders. (See attached map.) Fewer than 100 persons reside in the seven parcels combined.
The statute authorizes the commission to "revise the boundaries of the area”36 covered by a petition. Novi Township requested that the area covered by the city’s petition be expanded to include the balance of the township (Brookland Farms Subdivision, also shown on the attached map), where more than 100 persons resided.
The commission ruled that it could not revise the boundaries to include the eighth parcel be*677cause its authority did not include "boundary adjustments or additions of land not contiguous with lands proposed for annexation”.
While it is clear "in the light of the purpose sought to be served and the practical aspects of annexation”37 that territory annexed to a city must adjoin the city,38 just as there is no requirement that land proposed for annexation adjoin any other land included in the petition, a commission revision extending petition boundaries is not limited to land adjoining land proposed for annexation in the petition. The commission, in exercise of its broad-ranging power and discretion, may revise the boundaries set forth in a petition to include any land that might originally have been included in the petition or to exclude land that was included.
The Novi annexation illustrates that the impact of annexation on non-contiguous land may make it appropriate to revise the boundaries to include such land. In approving this annexation the commission proceeded on the assumption that its only options were to approve or disapprove the petition as filed and that it did not have the third option of approving the petition with a revision of the boundaries to include the non-contiguous Brook-land Farms Subdivision. Since we have no way of knowing whether the commission would have included the subdivision if it was aware that it had the authority to do so, it is necessary to remand the Novi petition to the commission for reconsideration.
We do not wish to be understood as intimating that because the commission found that approval *678of annexation with the boundaries sought by the city could pose serious problems for the residents of the subdivision39 that the commission should revise the boundaries to include the subdivision.
Brighton Township
An area contiguous to the City of Brighton, separated from the rest of the township by Interstate 96, had been designated the "Brighton Urban Growth Area”. (See drawing attached.) The city’s annexation petition covered more than half of the BUGA area, including a recently developed shopping center, but fewer than 100 persons resided in the area. More than 100 persons resided in the entire BUGA area.
Brighton Township contends that "the sole purpose of thus dividing the BUGA area was to gerrymander the petition to include less than 100 residents, thus forestalling the possibilities of a referendum”.
The township asked the commission to revise the boundaries to include the entire BUGA area and contends that the commission’s rationale for not revising them is insubstantial.
The claim that the commission should have revised the boundaries is related to the claim that the boundaries described in the petition were gerrymandered to limit the territory included so that there would be fewer than 100 residents and thereby obviate a referendum.
*679 Gerrymandering
In each case the city’s petition covered an area containing fewer than 100 residents, and the townships responded seeking to have the boundaries revised or petitions consolidated so that there would be more than 100 residents and a referendum would be required.40
The Legislature may reasonably determine that territory containing relatively few or no residents should be subject to annexation, and that there is need for a classification based on population to preclude a referendum in such a case and allow it where the territory to be annexed is more populous. (See part III A, supra.) City and township strategies based on such a classification are unavoidable. In general, the city will seek to limit the area proposed for annexation so that there are insufficient residents for a referendum and the township will seek to extend the area to require a referendum.
The motive or purpose of the city or township in drawing the proposed boundaries or in requesting a revision of boundaries is not material. The question is not one of motive or purpose, but whether the boundaries as drawn or revised and the annexation are reasonable. The reasonableness of the boundaries as originally proposed or as revised by the commission and of the proposed annexation does not depend on whether they were drawn or appear to have been drawn to require or preclude a referendum.
It will often be possible to draw the boundaries *680to preclude a referendum and likewise to alter them to require one. The commission need not revise the boundaries because approval of the proposed annexation would have an adverse effect on the township, the boundaries would also be reasonable as proposed to be revised and a referendum may prevent annexation. The adverse effect on the township is but a factor to be considered in deciding whether the petition should be approved with the original boundaries or with revised boundaries or not at all.
The commission’s decisions approving the Midland, Brighton and Novi annexations with boundaries as originally proposed by the cities were not violative of the statutory standard, reasonableness; the Novi annexation petition is being remanded because the commission did not consider whether it might not also be reasonable or preferable to revise the boundaries to include the Brookland Farms Subdivision.
E. Public Meetings Act
The townships further contend that the provisions of the 1968 public meetings act were ignored.41 The act defines "public meeting” as follows:
" 'Public meeting’ means that part of any meeting of a board during which it votes upon any ordinance, resolution, motion or other official action proposed by or to the board dealing with the receipt, borrowing or disbursement of funds or the acquisition, use or disposal of services or of any supplies, materials, equipment or other property or the fixing of personal or property rights, privileges, immunities, duties or obligations of any person or group of persons. The term 'public meeting’ shall not mean any meeting, the publication of the *681facts concerning which would disclose the institution, progress or result of an investigation undertaken by a board in the performance of its official duties.” 1968 PA 261; MCLA 15.251(2); MSA 4.1800(1X2).
The hearing before the commission did not concern the "receipt, borrowing or disbursement of funds or the acquisition, use or disposal of services or of any supplies, materials, equipment or other property”. Nor, for reasons already stated, did it concern "the fixing of personal or property rights, privileges, immunities, duties or obligations of any person or group of persons”.
F. Disconnected Land
Lastly, Novi Township contends that land disconnected from the Village of Novi by court orders entered pursuant to the farmland disconnection act42 was not properly annexed to the City of Novi.
The township acknowledges that disconnection is not necessarily permanent and that new facts might arise which could render a disconnection order obsolete. A disconnection order does not create a vested right or legally protected interest beyond the power of the Legislature to provide for annexation of the land disconnected. Disconnected land is subject to annexation by a city pursuant to the provisions of the 1970 amendment. Exercise by the commission of the power to annex disconnected land does not constitute a collateral attack on the judgment of the circuit court disconnecting the land.
Reversed. The orders of the commission in Midland Township and Brighton Township shall be effected as of the earliest practicable date; those cases are remanded to the circuit courts for the sole purpose of implementing the commission’s *682orders in accordance with the statutes.43 The Novi Township petition is remanded to the commission for further proceedings consistent with this opinion. No costs, a public question.
Kavanagh, C. J., and Williams, Coleman, Fitzgerald, and Ryan, JJ., concurred with Levin, J.
