<?xml version="1.0" encoding="iso-8859-1" ?>
<doc callnum="HE554.L8 P67 1982">
<metadata>
	<titleStmt>
		<mainTitle nfc="0"><title>Port development study</title>/<respStmt>prepared for the Ludington Harbor Commisssion, the City of Ludington, Pere Marquette Charter Township and Mason County in cooperation with MNDR, Coastal Management Program.</respStmt></mainTitle>
	</titleStmt>
	<authorStmt>
		<corpAuthor><name>Michican Coastal Management Program.</name></corpAuthor>
		<corpAuthor><name>Williams &amp; Works.</name></corpAuthor>
	</authorStmt>
	<imprint><pubPlace>Grand Rapids, Mich.</pubPlace>:<pubName>Williams &amp; Works</pubName>,[<pubDate>1982?</pubDate>]</imprint>
	<classStmt>
		<locClass>
			<subject cat="top">Urban renewal</subject>
			<subject cat="geo">Michigan.</subject>
		</locClass>
		<locClass>
			<subject cat="top">Harbors</subject>
			<subject cat="geo">Michigan</subject>
			<subject cat="gen">Planning.</subject>
		</locClass>
		<locClass>
			<subject cat="top">Regional planning</subject>
			<subject cat="geo">Michigan.</subject>
		</locClass>
		<locClass>
			<subject cat="top">Land use</subject>
			<subject cat="geo">Michigan</subject>
			<subject cat="gen">Planning.</subject>
		</locClass>
	</classStmt>
</metadata>

<text xml:space="preserve">
<pb n="1" />

                                                                                                     I q
                                                                                                                    MICHIGAN
                                                                                                   OCZM GRANT #NA-80-AA-H-CZ151
                                                                                                              SUBTASK

           Port Development Study
           Prepared for the ...
           Ludington Harbor Commission
           The City of Ludington
           Pere Marquette Charter Township and
           Mason County
           In cooperation vAth ...
           MDNR, Coastal Management Program

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                                                                                                     WUJUAMS                  VvKXtKS

                                                                                          GRAND RAPIDS, MICHIGAN
                                                                                                Engineers, Architects, Planners
                                                                                                    Surveyors, Geologists, Ch
<pb n="2" />

                                              TABLE OF CONTENTS

                                     LUDINGTON PORT DEVELOPMENT STUDY

                                                                                               Page

           CHAPTER I - GENERAL DATA BASE

           INTRODUCTION                                                                        I-1

           A.    GENERAL INFORMATION                                                           I-1
                 1.    Regional Location                                                       I-1
                 2.    Local Setting                                                           I-2
                 3.    Topography/Hydrography                                                  I-2
                       a.  Topography                                                          I-2
                       b.  Lake Hydrology                                                      I-2
                       c.  Currents                                                            I-3
                       d.  Erosion and Sedimentation Patterns                                  I-3
                       e.  Harbor Maintenance Depths                                           I-4
                       f.  Flood Hazard Areas                                                  I-5
                 4.    Geology/Soils                                                           I-5
                       a.  Geology                                                             I-5
                       b. Soils                                                                I-6
                       c.  Groundwater                                                         I-7
                 5.    Climate/Weather   Conditions                                            I-7
                       a. Climate                                                              I-7
                       b. Winds and Wave Heights                                               I-8
                       c.  Ice Conditions                                                      I-8
                 6.    Zoning                                                                  I-9
                 7.    Existing Land Use                                                       I-9
                 8.    Utilities and Infrastructure                                            I-10
                 9.    Demographics                                                            I-10
                       a. Historic Profile                                                     I-10
                       b. Population Projections                                               I-12
                 10.   Transportation                                                          I-12
                       a.  Roads and Regional Highways                                         I-12
                       b. Waterborne Transportation                                            I-13
                       c.  Railroads                                                           I-13
                       d.  Air Transportation                                                  I-14

                 11.   Cultural/Historic Elements                                              I-14
                 12.   Recreation/Tourism                                                      I-14

           B.    ECONOMIC CONDITIONS                                                           I-15
                 1.    Regional and Local    Markets                                           I-15
                       a. Overview                                                             I-15
                       b. Market Areas                                                         I-15
                       c. Specific Market    Sectors                                           I-16
                 2.    Employment and Salaries                                                 I-20
                       a. Regional Employment                                                  I-20
                       b. Local Employment                                                     I-20
                 3.    Industry                                                                I-21
                 4.    Labor Market                                                            I-23
<pb n="3" />

                                              TABLE OF CONTENTS
                                                   (Cont'd.)

                                                                                             Page

           C.    WATERBORNE COMMERCE                                                          I-24
                 1.    Commodity Flows                                                        I-24
                       a.  General                                                            I-24
                       b.  Regional Flow of Foreign Imports and Exports                      I-25
                       c.  Major Commodity Flow Patterns                                      I-25
                       d.  Volume of Commodity Flows Through Ports on the Great Lakes         I-28
                       e.  Commodity Flows Through Ludington                                  I-31
                       f.  Cross-Lake Passengers                                              I-32

           CHAPTER II -   EXISTING HARBOR FACILITIES

           INTRODUCTION                                                                       II-1

           A.    EXISTING HARBOR FACILITIES                                                   I-1

           B.    ON-SITE REVIEW OF EXISTING    COMMERCIAL FACILITIES                          II-2
                 1.    Chesapeake &amp; Ohio Railroad Car Ferry                                   II-2
                       a.  Car Ferry Slip 2                                                   II-2
                       b.  Car Ferry Slip 1                                                   II-4
                       c.  Car Ferry Slip 3                                                   II-5
                       d.  Sheet Pile Dock 1-1/2                                              II-5
                       e.  Sheet Pile Docks 2-1/2 and 3-1/2                                   II-6
                       f.  Site Considerations                                                II-6
                       g.  Functional Viability                                               II-6
                 2.    The Dow Chemical Company                                               II-7
                       a.  Area East of the East Dock Face                                    11-7
                       b.  East Dock Face                                                     II-8
                       c.  Area Between East and West Dock     Face                           II-8
                       d.  West Dock Face                                                     II-8
                 3.    Mohawk Transportation                                                  II-8
                       a. Facilities and Conditions                                           II-8
                       b. Functional Viability                                                II-9
                 4.    Western Concrete Products                                              II-9
                       a. Facilities and Conditions                                           II-9
                       b. Functional Viability                                                II-10
                 5.    Sand Products                                                          II-10
                       a. Facilities and Conditions                                           II-10
                       b. Functional Viability                                                II-11

           CHAPTER III - LAND USE ANALYSIS

           INTRODUCTION                                                                      III-1

           A.    RESIDENTIAL                                                                 III-1

           B.    COMMERCIAL                                                                  III-2

           C.    PUBLIC FACILITIES                                                           III-3

	     D.    CONCLUSIONS											   III-4
<pb n="4" />

                                            TABLE OF CONTENTS
                                                (Cont'd.)

                                                                                           Page

           CHAPTER V - FEASIBILITY DETERMINATION

           INTRODUCTION                                                                     V-1
           SCOPE                                                                            V-1
           KEY ISSUES                                                                       V-1
           A.   PERSPECTIVE ON FEASIBILITY                                                  V-2
                1.   Industrial Location Theory                                             V-2
                2.   Traffic Management - Shipping Operations                               V-3
                     a. Functions of Traffic Management                                     V-3
                     b. Major Shipping Operations                                           V-3
           B.   METHODOLOGY                                                                 V-4
                1.   Criteria for Defining Case Parameters                                  V-4
                     a. Local Plant Development                                             V-4
                     b. Regional Shipping Terminal Development                              V-4
                     c. Inter-Regional Shipping Operations                                  V-5
                2.   Data Source                                                            V-5
                3.   Judgments                                                              V-5
                4.   Equations                                                              V-5
                     a. Local   Plant Development                                           V-5
                     b. Regional Terminal                                                   V-6
                     c. Inter-Regional Shipping                                             V-7
           5.   Cases Investigated                                                          V-7
           C.   RESULTS                                                                     V-8
                1.   Local Plant Development                                                V-8
                     a.   Cement Manufacturing                                              V-8
                     b.   Pulp/Paper Production                                             V-11
                     c.   Fertilizer Production                                             V-12
                     d.   Steel Fabrication                                                 V-13
                     e.   Ship Building and Repair                                          V-14
                     f.   Power Generation with Wood Fuels                                  V-15
                2.   Regional Distribution                                                  V-16
                     a. General Cargo Terminal                                              V-16
                     b. Dry Bulk Terminal                                                   V-17
                     c.   Bulk Petroleum Terminal                                           V-18
                3.   Inter-Regional                                                         V-19
                     a. Railroad Traffic                                                    V-19
                     b. Truck, Trailer, Container Traffic                                   V-20
                     c.   Passengers                                                        V-21

           CHAPTER VI - DRAFT LAND USE ALTERNATIVES

           FUNCTION AND PURPOSE                                                            VI-1

           ALTERNATIVE LAND  USE OPPORTUNITIES                                             VI-3
                Alternative  A-1                                                           VI-4
                Alternative  A-2                                                           VI-5
                Alternative  A-3                                                           VI-6
                .Alternative B-1                                                           VI-7
                Alternative  B-2                                                           VI-8
<pb n="5" />

                                            TABLE OF CONTENTS
                                                (Cont'd.)

                                                                                          Page-

           CHAPTER VII - HARBOR LAND USE PLAN

           INTRODUCTION                                                                 VII-1

           A.   GENERAL PLAN CONCEPTS                                                   VII-1
           B.   THE CITY OF LUDINGTON: PLAN ELEMENTS                                    VII-2
                1.    Residential                                                       VII-2
                2.    Commercial                                                        VII-@
                3.    Mixed Commercial                                                  VII-3
                4.    Industrial                                                        VII-4
                5.    Marine Transportation/Terminal                                    VII-4
                6.    Public Uses                                                       VII-5
                7.    Transportation                                                    VII-5
           C.   PERE  MARQUETTE TOWNSHIP: PLAN ELEMENTS                                 VII-5
                1.    Residential                                                       VII-5
                2.    Commercial                                                        VII-6
                3.    Industrial                                                        VII-6
                4.    Public Use                                                        VII-7

           D.   PORT  PLAN FEATURES                                                     VII-7
                1.    Regional Terminals                                                VII-7
                2.    Inter-Regional Terminal                                           VII-8
                3.    Harbor Improvements                                               VII-9
           E.   IMPLEMENTATION                                                          VII-9
                1.    Port and Terminal Management Options                              VII-9
                      a.  Ludington Harbor Commission                                   VII-9
                      b.  Port Authority                                                V11-10
                      c.  Independent Public Action/Private Development                 VII-11
                      d.  Pere Marquette Lake-Council                                   VII-12
                      e.  Economic Development Authority/Economic Development
                          Corporation                                                   VII-13
                2.    Agency Responsibilities                                           VII-14
                      a. Local Agencies                                                 VII-14
                      b. State Agencies                                                 VII-15
                      c.  Federal Agencies                                              VII-16
                3.    Funding Sources, Land Acquisition Methods, and
                      Development Incentives                                            VII-17
                      a. Funding Sources                                                VII-17
                      b. Land Acquisition Methods                                       VII-20
                      c.  Development Incentives                                        VII-21
                4.    Zoning Ordinance and Map Review                                   VII-23
                      a. City of Ludington                                              VII-23
                      b. Pere Marquette                                                 VII-24
                5.    Implementation Program                                            VII-25
                      a. Overall Strategy                                               VII-25
                      b. Lead Agency                                                    VII-26
                      c. Development Coordinator                                        VII-27
                      d. Marketing Strategy                                             VII-28
           F.   RECOMMENDATIONS                                                         VII-29
<pb n="6" />

                                           TABLE OF CONTENTS
                                               (Cont-d.)

                                                                                       Page

          CHAPTER VIII - DEVELOPMENT OPPORTUNITIES

          INTRODUCTION                                                                VIII-1

          A PROSPECTUS  FOR THE DEVELOPMENT OF A MAJOR HOTEL IN THE CITY OF
          LUDINGTON, MICHIGAN                                                         VIII-2

          A PROSPECTUS FOR CONDOMINIUMS AND RECREATION ORIENTED COMMERCIAL
          DEVELOPMENT IN THE CITY OF LUDINGTON, MICHIGAN                              VIII-6

          A PROSPECTUS FOR THE DEVELOPMENT OF A MAJOR OFFICE COMPLEX IN
          THE CITY OF LUDINGTON, MICHIGAN                                             VIII-10

          A PROSPECTUS FOR THE DEVELOPMENT OF A MANUFACTURING FACILITY IN
          THE CITY OF LUDINGTON, MICHIGAN                                             VIII-14

          A PROSPECTUS FOR THE DEVELOPMENT OF A MARINE PETROLEUM BULK
          TERMINAL IN THE CITY OF LUDINGTON, MICHIGAN                                 VIII-18

          A PROSPECTUS FOR THE DEVELOPMENT OF A (PHASE I OPERATION)
          MARINE DRY BULK TERMINAL IN THE CITY OF LUDINGTON, MICHIGAN                 VIII-23

          A PROSPECTUS FOR THE DEVELOPMENT OF A (PHASE II OPERATION)
          MARINE DRY BULK TERMINAL IN THE CITY OF LUDINGTON, MICHIGAN                 VIII-27

                                           LIST OF APPENDIX

                               A - Ludington Commodity Flow Survey
                               B - Feasibility Data &amp; Calculations
<pb n="7" />

                                               LIST OF FIGURES

                                                                                           Follows
            Figure                                                                            Page

                       Regional Location                                                      I-1
                2      Topography                                                             1-2
                3      Soils Interpretation                                                   1-6
                4      Existing Zoning                                                        1-9
                5      Generalized Land Use                                                   1-9
                6      Transportation Facilities                                              1-13
                7      Distances to Regional Market Areas                                     1-15
                8      Total Commodity Movement by Water                                      1-24
                9      Coal Movement                                                          1-26
              10       Crude Petroleum Movement                                               1-26
              11       Refined Petroleum Products Movement                                    1-26
              12       Iron Ore Movement                                                      1-26
              13       Iron and Steel Products Movement                                       1-27
              14       Grain Movement                                                         1-27
              15       Industrial and  Agricultural Chemicals Movement                        1-27
              16       Harbor Structures and Channel Dimensions                             11-2
              17       C&amp;O Site Plan                                                        11-2
              18       Cross-Section View of Long-Wing Fender
                       (Car Ferry Slip No. 2)                                               11-2
              19       Cross-Section View of Turning Pile Cluster
                       (Car Ferry Slip No. 2)                                               11-3
              20       Auto Ramp Support Piling at Slip 2                                   11-3
              21       Lining Cluster Pile and Opposite Pile at Slip 2                      11-4
              22       Slip 3 - Long-Wing Fender                                            11-5
              23       Dow ChemicalCo. Site Plan                                            11-7
              24       Photo from East of East Dock at Dow Chemical Co.                     11-8
              25       Mohawk Transportation Site Plan                                      11-8
              26       Mohawk Transportation Existing Pilings                               11-9
              27       Western Concrete Products Site Plan                                  11-9
              28       Sand Products Co. Terminal Site Plan                                 II-10
              29       Alternate Land Use Opportunities                                    III-1
              30       Michigan Bulk  Petroleum Terminals                                     V-18
              31       Alternate A-1                                                        VI-4
              32       Alternate A-2                                                        VI-5
              33       Alternate A-3                                                        VI-6
              34       Alternate B-1                                                        VI-7
              35       Alternate B-2                                                        VI-8
              36       Harbor Land Use Plan                                                VII-1
              37       Implementation Strategy                                             VII-25
              38       Location of Development   Opportunities                             VIII-1
<pb n="8" />

                                 Chapter I
                        General Data Base
I -
<pb n="9" />

                                              CHAPTER I
                                          GENERAL DATA BASE

          INTRODUCTION,

          The Data Base for the Ludington Area Port Development Study is organized into
          three parts:

          A.   General Information

          B.   Economic Conditions
          C.   Waterborne Commerce

          The Data Base is assembled from reliable, published sources, and focuses pri-
          marily on transportation facilities and economics.     Secondary emphasis is on
          harbor area land use, especially unused and under-utilized land.

          A. GENERAL INFORMATION

          1. Regional Location

          The City of Ludington  is located on the eastern shore of Lake Michigan in Mason
          County, Michigan.   Figure 1 shows the regional location of Ludington.      It is
          approximately 200 miles northeast of Chicago, Illinois; 240 miles northwest of
          Detroit, Michigan; and 250 miles southwest of Sault Ste. Marie, Michigan. The
          closest neighboring deep draft harbors are in Manistee (30 miles north) and in
          Muskegon (60 miles south).

          2. Local Setting

          Ludington, the largest city in Mason County and the county seat, had a popula-
          tion of 8,937 in 1980.    This was approximately 34% of the total 1980 Mason
          County population of 26,365.

          Ludington and its harbor are located on Pere Marquette Lake.       Pere Marquette
          Lake is approximately two miles long and drains the Pere Marquette River. Its
          outlet to Lake Michigan is protected by the harbor.

                                                 I-1
<pb n="10" />

                                            LAKE sup Pion
                                                         e                              CANADA

                                      ..3-41     MAROUETTE
                          .......         . ........... .                                SAULT STE. MARIE
                                                              M.2
                                                                                  .1
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                                                                           CREEK.-`
                                                                                            1-94
                                                                   1-94  i .....       .... ..........      DETROIT
                                                                    .........                 ARBOR' ......
                              ILLINOIS                                    KALAMAZOO
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                                                 CHICAGO

                                                                   SOUTH                         TOLEDO
                                                                   BEND
                                                  OGARY      INDIANA                             OHIO

                                                                                                  Figure I
                                                                                          REGIONAL LOCATION
                                                                                          CITY OF LUDINGTON
                                                                                       PORT DEVELOPMENT STUDY
                                                                                                      11Q@ll
                                                                                                0 10 20 30 40 50
                'WILLIAMS Ek WORKS                                                              _MILES___
<pb n="11" />

          3.    Topography/Hydrography

          a.    Topography

                Picturesque sand dunes occupy much of the Lake Michigan shoreline in Mason
                County.   Elevations vary from approximately 850 in the southern portions
                of the county to approximately 580 at Lake Michigan.          A combination of
                gently rolling moraines and fairly level, poorly drained lands comprise
                much of Mason County. In addition to the larger lakes near the shoreline,
                numerous smaller lakes are located inland.

                South of Ludington to a distance of six or seven miles, moraine hills and
                ridges extend westward to Lake Michigan from approximately six miles
                inland.   North of Ludington, sandy lake bottom lowlands extend inland
                several miles.     The characteristically gentle slopes are interrupted
                occasionally by abrupt moraine hills.

                Topographic characteristics in the immediate vicinity of Ludington Harbor
                are shown in Figure 2.       Directly east of the harbor,      the land slopes
                fairly uniformly toward Pere Marquette Lake.         Lowlands  and marshes are
                located at the south end of Pere Marquette Lake and            along the lower
                reaches of the Pere Marquette River.

          b.    Lake Hydrology

                Water levels across Pere Marquette Lake are predominately controlled by
                Lake Michigan levels and to some extent in the southern reaches by inflow
                from the Pere Marquette River.     The river at its mouth drains a watershed
                area of 740 square miles covering portions of four Michigan counties. The
                river's average springtime flow varies from approximately 700 to 900 cubic
                feet per second, as recorded at the USGS gauging station in Scottville
                (ten miles upstream from Ludington)

                As part of the Great Lakes system, Lake Michigan levels fluctuate in three
                ways:   long-term, seasonal, and short-rise.       Long-term fluctuations are
                caused by the varying response to changing conditions of water input

                                                    1-2
<pb n="12" />

                                                                         . .. .......

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                                                                                              Figure 2
                                          K E
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                                                                                                    60(&gt;

                                                                                           TOPOGRAPHY
                                                                                      CITY OF LUDINGTON
          SOURCE: US GS LUDINGTON QUADRANGLE                                       PORT DEVELOPMENT STUDY
                   to MINUTE SERIES
                                            CONTOUR INTERVAL - 50 FEET
                WILLIAMS a WORKS                                                                 MILas
<pb n="13" />

               (principally from precipitation within the lake's basin) and to water
               output due to evaporation and outflow. A net surplus in this water supply
               balance resulted in the highest recorded monthly mean lake level of 581.1
               (International Great Lakes Datum - IGLD) in July, 1974. Seasonal fluctua-
               tions produce high levels in summer and low levels in winter.              These
               changes are the direct result of natural seasonal patterns.         Spring run-
               off from snow melt and low evapotranspiration (the loss of water from land
               areas through plant growth and soil evaporation) produce higher lake
               levels.   In late summer, the opposite is true and lake levels begin to
               fall. Short-rise fluctuations of lake levels are c     aused by differeinces in
               atmospheric pressure and winds blowing over the lake surfaces. The result
               of these forces is a rise of the water surface in one area of the lake
               with a 'concurrent drop in level in another area.

               Generally, Lake Michigan levels have an average seasonal variation of
               about 1.2 feet, from 577.7 in February to 578.9 in July.         Over the past
               two years, the lake levels have been approximately one foot above long-
               term average levels and are gradually declining.

          C.   Currents

               There are no known studies or documentation of significant currents in
               Pere Marquette Lake or the harbor area.         The most likely producer of
               currents is the Pere Marquette River, which causes a net flow of water
               through Pere Marquette Lake to Lake Michigan.        However, the features of
               Pere Marquette Lake are not supportive of strong currents.

               Occasionally, wind drift currents may be generated within Pere Marquette
               Lake and storms over Lake Michigan will produce currents of short dura-
               tion.

          d.   Erosion and Sedimentation Patterns

               The Lake Michigan shoreline in the vicinity of Ludington is erosional.
               Steep slopes without significant beach zones typify the shoreline several
               miles to the south of Ludington and indicate encroachment and land remov-
               al. Lowlands surrounding the lakes north of Ludington are less obviously

                                                   1-3
<pb n="14" />

                 marked by erosion because of their original low elevation and low relief.
                 Longshore transport of sand occurs in the zone of swash and backwash where
                 waves interact with the shore most energetically. The dominant direction
                 of transport of sand along the Lake Michigan shoreline near Ludington is
                 southward, as determined by the U.S. Army Corps of Engineers.

                 Identification of high-risk shore erosion sites was made in 1970 under the
                 supervision of the Mi   chigan DNR under contract with a private organiza-
                 tion.   The method used was one of comparing aerial photographs of 1970
                 with those of 1938.      Follow-up by the Bureau of Water Management was
                 undertaken in 1971 and 1972 with field studies to determine more recent
                 trends.   Results of the study in the Ludington area indicated a general
                 pattern of considerable erosion with some sedimentation occurring in
                 isolated areas.

                 Michigan's Demonstration Erosion Control Program has three projects in the
                 vicinity of Ludington for the purpose of monitoring and evaluating low
                 cost shore protection measures. These projects are a seawall at Big Sable
                 Point (seven miles north of Ludington), two steel groins at Ludington
                 State Park (just south of Big Sable Point), and a pre-cast concrete break-
                 water system in Pere Marquette Township (one mile south of the harbor
                 entrance).   Only the steel groins at Ludington State Park have remained
                 stable and provide protection against erosion.

                 As mentioned previously, Lake Michigan levels are gradually declining at
                 present.   Reduced lake levels tend to result in reduced erosion since
                 adjacent lands are less likely to be inundated or subject to wave attack.

           e.    Harbor Maintenance Depths

                 Project depths are maintained at 29 feet at the harbor mouth, 27 to 29
                 feet within the breakwaters, and 27 feet through the entrance channel.
                 The average depths along the northern central portion of Pere Marquette
                 Lake vary from 33 to 43 feet.      Southern portions of the lake become in-
                 creasingly shallow and-swampy. Most recreational anchorage is at 5 to 15
                 feet, While commercial docking facilities maintain depths of 20 to 25
                 feet.   Figure 16, "Harbor Structures", also shows the authorized harbor
                 depths.

                                                     1 4
<pb n="15" />

              Flood Hazard Areas

              Lake Michigan flood levels have been determined by the U.S. Army Corps of
              Engineers in a 1977 study.     The 10-year and 100-year flood levels at
              Ludington are 581.3 and 582.5 (IGLD), respectively.

              The City of Ludington, built almost entirely on land with an elevation of
              600 or above, has no special flood hazard areas, as identified by the
              National Flood Insurance Program, and does not have a history of signifi-
              cant flooding.

         4.   Geology/Soils

         a.   Geology

              The City of Ludington lies- on the east/west axis of Lake Michigan proper,
              midway between the north and south ends of the lake. The recent geologi-
              cal history of the Ludington area has involved events common to other
              regions on the west shore of Lake Michigan.      The Pere Marquette River
              Valley and its evolution are convenient points of focus for descriptions
              relevant to the Ludington Harbor area.

              The Ice Ages, especially the latest one which terminated 9,500 years ago
              in Michigan, and post-glacial times until 2,000 to 3,000 years ago were
              the times of establishment of the present day prominent features of the
              area, especially topography, land forms, and the extent of surface water.

              Following the final disappearance of ice from the Lake Michigan shore
              region, the Pere Marquette River was larger and swifter and flowed in a
              narrower valley than exists today.    Neither Pere Marquette Lake nor the
              Buttersville bar, which separates Pere Marquette Lake from Lake Michigan,
              existed. The Pere Marquette Lake site could have been a narrow embayment
              at that time.

              A period of rising Lake Michigan water level culminated approximately
              4,000 years ago.   That period saw flooding of the Pere Marquette River

                                                1-5
<pb n="16" />

                 Valley floor and channel.    A long and narrow embayment may have extended
                 eastward to Scottville and even further inland during this period.         Lake
                 Michigan covered the site of the City of Ludington.

                 Falling Lake Michigan levels followed and levels were generally stabilized
                 by 2,500 years ago.     During that interval (4,000 to 2,500 years ago),
                 Ludington was uncovered as the Lake Michigan shoreline receded.             The
                 Buttersville bar was uncovered to form Pere Marquette Lake.

                 These glacial actions have resulted in the Ludington area being underlain
                 by glacial drift material up to several hundred feet deep with no outcrop-
                 pings of bedrock.   The morainal areas south of Ludington are hilly with
                 bold detached ridges.   Outwash areas to the north and east are relatively
                 flat, undulating plains, except where cut by stream channels.

           b.    Soils

                 A detailed soil survey has been conducted in Mason County by the U.S.
                 Department of Agriculture in 1939. The soils were found to range from dry
                 sands of the lake dunes to dark-colored, poorly drained silt loams, mucks,
                 and peats. Over the greater part of the county, the association of areas
                 of soils with different textures and colors is complex and the areas are
                 of irregular shapes.    Sands and loamy sands predominate in total area,
                 occupying about 58% of the land surface of the county; organic soils
                 occupy about 9%; and the remaining 33% is divided among sandy loams,
                 loams, and silt loams, which are the important agricultural soils.

                 Soils in the Ludington area are shown on Figure 3, "Soils Interpreta-
                 tions".  The Lake Michigan shoreline in the immediate area of the harbor
                 is composed of'dune and coastal beach sands. Areas along the north shore
                 of Pere Marquette Lake have been filled with sand and other material to
                 form building sites and are thus classified as manmade land. Rubicon sand
                 underlies most of the City of Ludington with Weare fine sand in the sur-
                 rounding area.

                                                    1-6
<pb n="17" />

                                               9@          2

                                                        1 5                 2
                                             5                   5  5  6
                                5                         9                 2

                                                           10                      2

                                                  10             5       10                5
                     AMLI             10                         7       r            2
                   LAK                           5                                          7
                                                                     FOUNTAIN
                           3       15         10 3                        10                     2
                        1-         I                     - -    5                           9
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                                     5                  L-i 1           10
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                             9       10            10

                                                                         7      4
                                     5

                                        5 3                10                      4
                                   L                                    7                    4

              I  DUNE SANDS

              2  RUBICON - GRAYLING

              3  KALKASKA - RUBICON

              4  RUBICON- GRAYCAJ_M

              5  ROSCOMMON - AU GRES -CROSWELL

              6  ALLUVIAL SOILS

              7  CARLISLE -CARBONDALE -RIFLE
              a  NESTER -KAWKAWLIN -SIMS                                               Figure 3
                                                                             SOILS INTERPRETATIONS
              9  MONTCALM - MC BRIDE -KALKASKA                                  CITY OF LUDINGTON
              10 KENT -SELKIRK - BERGLAND                                    PORT DEVELOPMENT STUDY

              SOURCE: USDA SOIL CONSERVATION SERVICE                                  0    1 a    3
              Wil I IAMS Ba WORKS                                                          MILK*
<pb n="18" />

                In the harbor area, soil borings were taken in connection with the harbor
                and channel modification project in 1966, and off-shore north of the
                harbor in conjunction with the Ludington water intake project in 1967.
                These data reveal that soils in the inner harbor turning area are dominant-
                ly fine sands of ve ry loose to dense consistency. Sand with gravel admix-
                tures is subordinant in amount, and no clay is present.          Soils in the
                inner channel area are composed     primarily of fine to coarse sands with
                subordinate admixed gravel.     The degree of density is mostly medium to
                dense.  Hard, sandy clay appears    at depths of 17 feet below the bottom in
                the north side of the channel.      Soils from off-shore locations north of
                the harbor consist in the upper    levels of medium to fine sand.     The sand
                is underlain with blue, sandy clay.

          C.    Groundwater

                Because of the glacial history of the Ludington area, the hydrological
                conditions of the area are not uniform. This non-uniformity is due to the
                thick bands of glacial drift.interwoven with deposits of clay. The actual
                drift material varies from sand to silty sand to silt.       Water is normally
                found lying between the clay deposits in the glacial drift.         Because of
                the non-uniformity of the drift, groundwater in the Ludington area is
                unpredictable, and supply capabilities within short distances may vary
                from as much as 50 to 1,000 gallons per minute.

          5.    Climate/Weather Conditions

          a.    Climate

                The Lake Michigan region is moderate in temperature and precipitation, due
                to westerly winds across Lake Michigan.      Average temperatures on a year-
                round basis are close to 50'F. Average temperatures in the Ludington area
                are close to 470F. The winters are long; the summers are short and warm.
                The difference between the average summer and winter temperatures is
                approximately 40'. Rainfall averages just under 30 inches per year, with
                about 20 inches occurring from April to October. Snowfall is a bit higher
                than inland areas, with about 70 inches per year.

                                                   1-7 .
<pb n="19" />

            b.   Winds and Wave Heights

                 The Great Lakes Region lies in a-path of frequent high and low atmospheric
                 pressure 'cells which move west to east across the North American continent
                 at more or less regular intervals of about three to five days.                 Wind
                 storms over Lake Michigan are normally caused by frontal passage of low
                 pressure centers along with the movement of extensive areas of high pres-
                 sure.   The more severe wind storms normally occur where these features
                 meet.   The general direction of low and high pressure movements across
                 Lake Michigan is southwest to northeast.

                 The more sustained and vigorous wind storms generally occur during the
                 winter-spring seasons when the air mass contrasts are the greatest and
                 pressure fields most intense.       The summer months are the calmest periods
                 of the year, although short duration storms such as those associated with
                 squall lines or thunderstorms do occur.

                 The minimum wind speed theoretically effective in promoting fully devel-
                 oped sea conditions on Lake Michigan is 40 mph or*less. Maximum recorded
                 wave heights in the   Ludington Harbor prior to construction of navigational
                 improvements in 1977 were 10.0 feet inside the harbor entrance, 6.2 feet
                 at the entrance to the inner channel, 5.0 feet at the inner channel turn
                 into Pere Marquette Lake, and 1-3 feet along the northern reaches of the
                 lake.    Construction of the harbor improvements have not significantly
                 affected wave heights.

           C.    Ice Conditions

                 Winter conditions usually produce only minor ice problems for commercial
                 navigation interests. The harbor between the breakwater entrance and the
                 inner channel piers is usually free of ice, but westerly winds occasion-
                 ally cause ice to drift into the outer harbor and then between the inner
                 channel piers.    Car ferries and commercial vessels break through the ice
                 masses, pushing them aside. With time, the ice piled laterally along the
                 channel margins becomes too heavy to push aside.

                                                      1-8
<pb n="20" />

               The City boat launching facility, midway between the north breakwater and
               the north pier, is frequently in need of repair due to erosion.       Some of
               the damage to the facility may be attributed to ice jamming.

          6.   Zoning

          Figure 4 shows the existing zoning districts in the harbor and Pere Marquette
          Lake area. The City of Ludington's zoning ordinance has been in effect since
          1966.   This zoning ordinance provides for five classes of residential zoning,
          four classes of commercial zoning, two classes of industrial zoning, and four
          classes of special zoning (parking, river valley, motel resort and government
          service).

          Pere Marquette Township adopted its current zoning ordinance in         1977.    The
          ordinance provides for two classes of agricultural zoning, two          classes of
          residential zoning, one class of commercial zoning, one class of industrial
          zoning, and three classes of special zoning (airport, conservation, and harbor
          industry).

          Generally, lands adjacent to the harbor are zoned commercial and industrial
          districts, while outlying areas are zoned residential districts. An exception
          is the Buttersville Bar which separates Pere Marquette Lake from Lake Michigan,
          and which is a zoned residential district.

          7.   Existing Land Use

          The pattern of existing land use, shown in Figure 5, fits well with zoning of
          the area.   There is very little room for industrial expansion along the north-
          east shore of Pere Marquette Lake.     Conversely, the southwest shore (Butters-
          ville Bar) consists of fairly low density residential development.        The low-
          lands at the southernmost shores of Pere Marquette Lake in Pere Marquette
          Township are zoned the "Harbor Industry District" to provide areas for loading,
          unloading, shipping, receiving and storage of materials as a water port
          facility. Currently, these areas are undeveloped.

                                                  1-9
<pb n="21" />

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<pb n="23" />

          8.    Utilities and Infrastructure

          Properties within the City of Ludington enjoy the availability. of utilities
          including water, sewer, electricity, gas, and telephone service.                Michigan
          Consolidated Gas Company and Consumers Power Company are the largest suppliers
          of natural gas and electricity, respectively, in the Ludington area. Water and
          sewer services are provided by the Ludington water plant and wastewater treat-
          ment plant.     With few exceptions, areas outside the city limits have-only
          electricity and telephone service readily available.

          9.    Demographics

          a.    Historic Profile

                The permanent population of an area supports the primary labor force and
                requires goods and services on a year-round basis.            The population of
                Mason County has been increasing steadily since 1930, and has seen an
                increase of 16.6% over the past tenyears. The population of the City             of
                Ludington, meanwhile, has fluctuated between a 1      ow of'8,810 in 1920 to a
                high of 9,506 in 1950.      Over the past ten years, Ludington"s population
                has decreased 0.9%.     Table 1 shows the population of Ludington and Mason
                County from 1890 to the present.

                                                   TABLE 1
                                                POPULATION
                                       MASON COUNTY AND LUDINGTON

                                               Mason County              Ludington

                          1890                     16,385
                          1900                     18,885                    -
                          1910                     21,832                  9,132
                          1920                     1-9,831                 8,810
                          1930                     18,756                  8,898
                          1940                     19,378                    -
                          1950                     20,474                  9,506
                          1960                     21,929                  9,421
                          1970                     22,612                  9,021
                          1980                     26,365                  8,937

                          Source: U.S.    Census of Population

                                                      I-10
<pb n="24" />

                 Ludington has an average density of 2,700 people per square mile and 2.3
                 people per dwelling unit.

                 Age, years of schooling, and family income for Mason County are shown in
                 Table 2, "Population Characteristics". This information is not yet avail-
                 able for the 1980 census. Table 3 shows the age distribution for the City
                 of Ludington in 1970.

                                                   TABLE 2
                                        POPULATION CHARACTERISTICS
                                               MASON COUNTY

                    Age by Percent of   Total Population              1960            1970

                              Under 15  years                         31.3            28.5
                              15 to 24  years                         12.1            14.8
                              25 to 39 years                          16.6            15.3
                              40 to 65  years                         27.3            28.3
                              65 + years                              12.7            13.1

               Years of School Completed by Persons Over
                  25 Years by Percent of Total Persons

                              8 or under                              42.7            27.4
                              1 to 3 high school                      17.0            20.1
                              4 high school                           27.9            36.0
                              I to 3 college                           7.5              9.5
                              4 college                                4.9              7.0

                              Median years completed                  10.3            12.1

              Family Income   by Percent of Total Families

                              Less than $3,000                        25.2            10.9
                              $3,000 to $5,000                        25.0            10.6
                              $5,000 to $7,000                        27.4            14.5
                              $7,000 to $10,000                       14.9            26.4
                              $10,000 to $15,000                       6.0            25.7
                              $15,000 +                                1.5            11.9

                              Median income                          $6,270         $8,476

                                Census of Population
<pb n="25" />

                                                   TABLE 3
                                             AGE DISTRIBUTION
                                              LUDINGTON, 1970

                           0 to 4 years   . . . . . . . . . . . . .        661
                           5 to 14 years    . . . . . . . . . . . .     1,715
                           15 to 24 years   . . . . . . . . . . . .     1,348
                           25 to 44 years   . . . . . . . . . . . .     1,854
                           45 to 64 years   . . . . . . .               2,068
                           65 + years   . . . . . . . . .               1,375

                           ----------
                           Source: U.S. Census of Population

           b.   Population Projections

                Population projections through the year 1997 are given in Table             4 for
                Ludington and Mason County.         These trends predict an average         yearly
                increase of approximately 1% for Mason County and 0.9% for the City of
                Ludington.

                                                   TABLE 4
                                          POPULATION PROJECTIONS
                                       MASON COUNTY AND LUDINGTON

                                               Mason County               Ludington

                           1982                    27,050                  10,850
                           1987                    28,440                  11,350
                           1992                    29,800                  11,850
                           1997                    319230                  12,350

                           ------------
                           Source: 208 Study for Mason    County

           10.  Transportation

           a.   Roads and Regional Highways

                The Ludington area is served by US-31 (north-south) and US-10 (east-west).
                M-116 connects Ludington to Hamlin Lake and the Ludington State Park, five
                miles north. US-31 is an arterial of statewide importance. The Michigan

                                                      1-12
<pb n="26" />

                portion begins at the Indiana border and continues through to the Mackinac
                Bridge. In the procels, it provides access to every major community along
                the eastern shore of Lake Michigan.       At present, US-31 is 4-lanes from
                Muskegon (where it connects with 1-96) to a few miles south of,Ludington.
                Transportation plans call for US-31 to be 4-lanes to Ludington in the
                future.

           b.   Waterborne Transportation

                The Ludington Harbor is a natural deep-draft, year-round harbor serving
                both commercial and recreational needs.      Waterborne commerce has averaged
                about 3,000,000 tons annually ove'r the past ten years. Roughly two thirds
                of this is, car ferry traffic to and from the Chesapeake &amp; Ohio Railroad
                docks.   Most of the balance of commerce consists of limestone receipts by
                The Dow Chemical Company, moved in self-unloading bulk carriers.

                Detailed information on commodity flows and types is discussed in Part C,
                "Waterborne Commerce", page 1-24.

           C.   Railroads

                Ludington is served by the Chesapeake &amp; Ohio Railroad, with through trains
                daily to the principal cities of Saginaw, Bay City, Port Huron, and
                Detroit.

                The railroad also operates a car ferry which transports train cargo across
                Lake Michigan to the Wisconsin port of Kewaunee.           Figure 6 shows the
                railroad locations in the Ludington area.

                Numerous railroad spurs extend to the northeast shores of Pere Marquette
                Lake, primarily to the Chesapeake &amp; Ohio Railroad's car ferry docks and to
                The Dow Chemical Company. M   ain tracks are also located in close proximity
                to other commercial docks on the northeast shores of Pere Marquette Lake.
                Additional spurs could be constructed in these locations if necessary.

                                                    1-13
<pb n="27" />

                              LAKE

                        /N

                                                   MASON
                       CITY    No, Rr              COUNTY
                                                   AIRPORT

                      LUDINGTON

                            U. S. 10                      slo

                                                          CHESAPEAKE 8k OHVO R. R.

                          1-p "I
                           Oak0

             L A K E                                   PER@E; Af.4

         MICHIGAN

                                               HOPKINS
                                                LAKE

                                                                         Figure 6
                                                                    TRANSPORTATION
                                                                       FACILITIES
                                                                   CITY OF LUDINGTON
                                                                 PORTDEVELOPMENT STUDY
                                                                           1114@
                                                                       0    1/2    1
            'WILLIAMS Ek WORKS                                             MIL98
<pb n="28" />

          d.   Air Transportation

               Mason County has a general utility airport located 1.7 miles east of the
               City of Ludington.   The present northeast/ sou thwes t main runway is 5,000
               feet by 75 feet and is paved. Plans have been made to increase its length
               to 5,400 feet. Figure 6 shows the location of the Mason County Airport.-

               The nearest airport with commercial service is Manistee County Blacker
               Airport, 25 miles northeast of Ludington.

          11.  Cultural/Historic Elements

          The earliest history of Mason County was recorded in the 17th and 18th cen-
          turies by the French, who explored the Lake Michigan shoreline and blazed
          trails through the forest of western Michigan, seeking fur pelts for trade. An
          explorer of this period was Pere Jacques Marquette, a French Jesuit missionary.
          The Pere Marquette Shrine, located near the mouth of the Pere Marquette River,
          marks the location of his death in 1675.     The shrine is on the State Register
          of Historic Plates.

          White Pine Village, located in Pere Marquette Township on the shore of Lake
          Michigan just south of the Buttersville Bar, is operated by Mason County. The
          village consists of original and reconstructed buildings and a museum.

          Because of its many outstanding natural values, the Pere Marquette River has
          been included under the State of Michigan Natural River Act of 1970 (PA 231 of
          1970) and the National Wild and Scenic Rive'rs Act (PL 90-542).     This designa-
          tion serves to protect the natural qualities of the river's mainstream and its
          significant tributaries upstream of US-31.

          12. Recreation/Tourism

          The climate and location of Ludington provide a year-round multitude of rec-
          reational activities.   The Ludington Municipal Marina, completed in 1981, has
          150 berths to provide for recreational boating on a large scale.      4,156 acres
          of natural wooded and dune areas are located five miles north at the Ludington
          State Park.'

                                                  1-14
<pb n="29" />

           Recreational\ fishing is very popular in the Ludington area.         Between April 1
           and mid-November, both the north and south breakwaters are used extensively by
           fishermen and sightseers.      Coho and chinook salmon enter Pere Marquette Lake
           from Lake Michigan.     Panfish, walleye, and northern pike also populate both
           lakes.   Since 1972, Ludington has sponsored an annual coho fishing derby, an
           event which spans two weeks and is well received.

           The high quality of sport fishing in the Ludington area is a strong attraction
           for both tourists and seasonal residents.      A substantial portion of the area's
           economy can be directly or indirectly related to the sport fishing activities.

           Winter sports are also very popular, and local activities include winter festi-
           vals, cross country Wing, and dog-sled and snowmobile races.

           Because of the recreational and historic elements of the Ludington area, tour-
           ism brings a significant increase in activity and business volume in the area.
           The peak tourist season is between Memorial Day and Labor Day.

           B.    ECONOMIC CONDITIONS

           1.    Regional and Local Markets

           a.    Overview

                 Michigan  has three major assets for economic development.          Its central
                 location on the Great Lakes and in the Midwest provides transportation and
                 trade advantages. Its diverse natural resources include iron ore, petro-
                 leum, natural gas, fertile soil, abundant water, and forests. Most impor-
                 tantly, its heterogenous population with comparatively high level of
                 education and trade skills provide the labor supply and managerial ability
                 for the state's variety of industries.

           b.    Market Areas

                 Major metropolitan areas provide the largest markets for consumption of
                 goods, distribution points for shipment to smaller markets, and the pro-
                 duction points for goods for shipment to other areas.        As Figure 7 indi-
                 cates, Michigan and the Ludington area are near the center of the distri-
                 bution network of major midwest metropolitan areas. Large cities such as
                 Cleveland, Pittsburgh, Cincinnati, Indianapolis, and St. Louis are within

                                                     1-15
<pb n="30" />

                                                                                                  500

                                                                                            400

                                                                                                       CANADA
                                      Dulut                                          300

                                                                               200

                                Minneapolis                               00
                                                       Gre 8                                                           Albany
                                                                        LUDINGTON                 Buffalo
                                                        Milwau *,ee      Lansing
                                                                               Detroit

                                                           Chicago              Toledo Clev an
                                 DesMoines                            Ft. -Wav-ne
                                                                                        71    Pittsburgh  Washington D. C.
                                                  Springf ield    Indianapolis
                                                                           Cir@cinnati

                             Kansas City        St. Louis
                                                                       Louisville

                                                                                                             Figure 7
                                                                                                        DISTANCES TO
                                                                                               REGIONAL MARKET AREAS
                                                                                                             (MILES)

                                                                                                     CITY OF UJOINGTON
                 WILLIAMS EN WORKS                                                              PORT DEVELOPMENT STUDY
<pb n="31" />

              a day's drive of north central Michigan, and are easily accessible by
              truck and rail transportation.    Basic raw materials such as iron ore,
              coal, petroleum and limestone are economically moved on the Great Lakes to
              major industrial centers such as Chicago, Toledo, Detroit and Buffalo.

              Since the opening of the St. Lawrence Seaway in 1959, the region has
              direct waterborne access to all foreign ports and markets of the world,
              although the seaway has some functional limitations due to the draft
              requirements of modern ocean-going vessels.

         C.   Specific Market Sectors

              The major market sectors presented herein roughly equate with the major
              classes of port traffic.

              (1)  Agriculture - Grains and Fertilizers

                   The midwest is, by far, the major producer of U.S. grain, with
                   Illinois, Iowa, Indiana, Nebraska, and Kansas the leading states.
                   Minnesota and North Dakota are also large producers, selling over 10
                   million short tons each in 1976. While much of this grain is shipped
                   overseas, a large portion is moved to markets in the eastern seaboard
                   and sunbelt states. Table 5 shows the production of major crops for
                   midwestern states in 1974.

                   Dairying, with corn, grain, and hay as crops, is the dominant farming
                   type in Michigan. It is most developed in the interior parts of the
                   southern lower peninsula, but is found throughout the state. Fruit -
                   particularly cherries, peaches, apples, plums and blueberries - is
                   grown just inland from Lake Michigan from Berrien County to Grand
                   Traverse Bay.

                   Michigan is a major supplier of dry edible beans for the U.S., grown
                   on the   fertile, flat lake-bottom soils of the Saginaw Valley.
                   Michigan also exports beets.    Most other agricultural products are
                   imported to Michigan, including soybeans, wheat, corn@ and potatoes.

                   Table 6 shows cash receipts from Michigan's farm markets.

                                               1-16
<pb n="32" />

                                                                    TABLE 5
                                             1974 PRODUCTION OF SELECTED CROPS IN THE MIDWEST
                                                                  (by state)

                                                                                         Irish
                                                                                        Potatoes          Sweet
                                         Corn         Soybeans           Wheat          (hundred         Potatoes       Hay Crops
           State                        (acres)       (bushels)-       (bushels)        wei ht)         (bushels)       (dry tons)

           Illinois                    9,550,090      205,382,348      50,,646,729         289,310        10,364         2,821,607

           Indiana                     5,311,243      94,724,611       44,246,255       1,481,941          7,964         1,831,874

           Iowa                       12,706,571      190,916,604        1,794,494         453,734         4,570         5,896,261

           Kansas                      1,975,682      18,634,381       299,416,699          93,847        33,621         4,032,977

           Michigan                    2,378,301      12,080,412       81,891,280       8,500,560         63,474         2,956,963

           Minnesota                   6,050,574      73,735,439       74,728,537      17,190,968          3,432         6,512,436

           Missouri                    2,817,492      87,981,623       34,764,459           96,966        51,377         5,080,402

           Nebraska                    6,436,708      25,528,000       90,599,286       2,347,664              561       5,805,323

           North Dakota                   495,926       2,509,507      209,162,432     20,932,659               85      @4,567,783

           Ohio                        3,421,942      81,392,887       56,715,928       3,078,651          4,003         2,744,427

           South Dakota                3,634,336        6,876,227      55,621,567          375,341               0       5,284,209

           Wisconsin                   3,451,232        3,813,422        2,871,897     13,778,777          4,680        10,168,458

           ----------
           Source: Regional Environmental Energy Data Book,        1978
<pb n="33" />

                                                   TABLE 6
                                 MICHIGAN CASH RECEIPTS FROM FARM MARKETS
                                          (in thousands of dollars)

                              item                  1974           1976           1978

                     Livestock and products     $ 687,857      $ 812,249      $ 997,659
                     Field crops                    963,932       908,828       1,129,132

                     TOTAL                       $1,651,789    $1,721,077      $2,126,791

                     Source: Michigan Statistical Abstract,   1980.

                     In 1969, almost 600,000 tons of commercial fertilizers were used in
                     Michigan at a cost of over $53 million.         These fertilizers were
                     applied on roughly 40% of the state's 8.5 million acres of cropland,
                     and averaged more than 400 pounds per acre. The amounts applied per
                     acre were highest in the Upper Peninsula and northwest part of the
                     Lower Peninsula to offset poor soils.        In 1978 in Mason County,
                     commercial fertilizers were applied to 40% of the farmland (35,300
                     acres), herbicides were applied on 28% (24,800 acres), and pesticides
                     on 15% (12,900 ac'res).   The current trend in agriculture.of a sharp
                     increase in yields, yet less overall land in farms, is causing an
                     increasing demand for commercial fertilizers.

               (2)   Manufactu-ring - General Cargo and Bulk.Chemicals

                     The Great Lakes Region is characteristic of a broadly diversified
                     manufacturing base, but one dominated numerically by heavy industry.
                     These tend to be relatively well paying industries, but are very
                     susceptible to adverse trends in the national economy.

                     Transport equipment, primarily automobiles and trucks, produce        more
                     than half of the value of Michigan manufactured products.        The  next
                     most important manufacturing category is the production of machinery,
                     including electric machinery, which accounts for about one-fifth of
                     the goods produced in Michigan.     The third category in importance,
                     primary and fabricated metal industries, is closely related to the
                     first two and is often found in association with the automotive
                     industry.

                                                  1-18
<pb n="34" />

                      Production of chemicals and allied products, located in salt- and
                      br ine-producing areas such as Midland-Saginaw-Bay City, Muskegon, and
                      around Detroit, accounts for about 5 percent of the manufactured
                      goods in Michigan.       Manistee and Mason counties are also major
                      producers of brine in Michigan.      Three other categories account for
                      about 1.5 to 2 percent each of the value of products by industry
                      groups; namely, food and kindred products, apparel and related
                      products, and lumber and wood products.          The locations of these
                      industries are widespread but have some relation to the distribution
                      of the raw material sources or market areas.          Some industries are
                      concentrated in one regional center, such as furniture in Grand
                      Rapids, paper in Kalamazoo, breakfast cereals in Battle Creek, and
                      baby food in Fremont.,

                 (3)  Construction - Sand, Stone and Cement

                      The Midwest   is a major producer and consumer of construction mater-
                      ials, including stone and clay products, sand, gravel and cement.
                      Table 7 shows the value of t   hese products sold in 1975 in the Midwest
                      states.

                                                        TABLE 7
                         VALUE ADDED* BY MANUFACTURE FOR STONE, CLAY AND GLASS PRODUCTS
                                                1975  (MIDWEST STATES)          Value Added
                        State                                              (millions of dollars)

                      Illinois                                                     910.5
                      Indiana                                                      563.7
                      Iowa                                                         203.3
                      Kansas                                                       231.6
                      Michigan                                                     551.9
                      Minnesota                                                    232.7
                      Missouri                                                     302.5
                      Nebraska                                                       85.1
                      North Dakota                                                    11.9
                      Ohio                                                        1,439.4
                      South Dakota                                                    23.4
                      Wisconsin                                                    214.0

                      ------------
                      *The value of goods sold, less cost of necessary materials and power,
                       expressed in 1958 dollars to account for inflation.

                                                     1-19
<pb n="35" />

                   Construction in Mason County displayed very substantial increases,
                   both net and competitive, during the 1970's, compared to both the
                   state and the region.- Much of the gains in construction can be
                   attributed to the building of summer homes and retirement homes and
                   could fluctuate substantially during downturns in the business cycle.

              (4)  Energy - Coal and Petroleum Fuels

                   There has been increased activity in petroleum industries in Michigan
                   in recent months.    A number of petroleum companies are purchasing
                   mineral rights from area residents, and natural gas and oil have been
                   found southeast of Mason County in Newaygo County near Hesperia.
                   Continued price increases in petroleum products are forecasted for
                   the future (despite recent short-term declines') and are expected to
                   further stimulate local energy production.

         2.   Employment and Salaries

         a.   Regional Employment

              On a Great Lakes regional basis, employment is predominantly in the agri-
              cultural and heavy industry areas.   While Michigan ranks first among the
              states in production of motor vehicles and parts, employment is also
              predominant in other manufacturing and processing lines, including pre-
              pared cereals, machine tools, airplane parts, refrigerators, hardware,
              steel springs, and furniture.

         b.   Local Employment

              Local employment in the western half of    Michigan and the Ludington area
              has become substantially more stable in    the past ten years in terms of
              employment, when compared to the rest of the state.       This indicates a
              somewhat stronger and more stable economy than that seen state-wide.

                                                1-20
<pb n="36" />

           3.   Industry

           Ludington has a solid and diversified industrial base.       It is the dominant
           industrial center in Mason County and the area.

           The Ludington area supports a variety of industries and employers, including:

           Company                                     Main Business/Product

           Atkinson Manufacturing Company              Tool &amp; Security Boxes, Closet
           502 S. James Street                         Accessories

           Anna Bach Candies, Inc.                     Candies
           413 S. James Street

           Brill Manufacturing Company                 Pine Furniture
           713 S. James Street

           Chadwick Memorials, Inc.                    Cemetery Memorials, Building Stone,
           401 W. Ludington Avenue                     Structural Marble, Concrete Urns,
                                                       Patio Slabs

           CDR Industrial, Inc.                        Screen Printing - Meta'l Fiberglass
           236-1/2 Dowland Street

           Custom Foam of Castle Industries            Styrofoam
           1001 N. Rowe Street

           Dow Chemical U.S.A.                         Chemical Manufacturing, Liquid
           S. Madison Street                           Calcite

           Foliage Company of America                  Fabrications
           N. Rowe Street

           Great Lakes Casting Corporation             Gray Iron Castings
           800 N. Washington Avenue

           Harbison-Walker Refractories Company        Deadburned Magnesite
           US-31

           Handy Things Manufacturing Company          Christmas Tree Holders and
           814 N. Rowe Street                          Housewares

           Harrington Tool Company                     Special Metal Cutting Tools
           200 W. Ludington Avenue

           Industrial Tool Engineering                 Machine Products
           1176-1/2 N. Jebavy Drive

           Jackson Vibrators, Inc.                     Railroad Maintenance &amp; Industrial
           200 S. Jackson Road                         Handling Equipment

                                                 1-21
<pb n="37" />

          Company                                     Main Business/Product

          Kaines Manufacturing Company                Wire Products
          130 F. Dowlan d Street

          Ludington Concrete Products, Inc.           Redi-Mix, Concrete &amp; Light Weight
          280 S. Pere Marquette Street                Block, Face Brick

          Ludington Plastics, Inc.                    Plastics
          S. Jebavy Drive

          Ludington Industrial &amp; Mfg Co.              Electro Plating
          901 N. Harrison Street

          Mason County Cold Storage, Inc.             Fresh Fruits
          Route #1

          Merdel Game Mfg Co.                         Wood Action Games
          218 F. Dowland Street

          Mitchell Corporation                        Automotive Interior
          185 S. Jebavy Drive

          Motyka Metal Products                       Tubing
          E. Ludington Avenue

          Nelson Packing Company                      Meat Packing Plant
          5251 E. First Street

          Olmstead Orchards                           Wholesale Fruit Packing &amp; Storage
          Route #1

          Petersen's Furniture Specialties            Custom Furniture
          922 N. Washington Avenue

          Outstate Tool &amp; Die, Inc.                   Progressive Dies, Tooling, Stampings,
          526 S. James Street                         &amp; Die Tryouts

          Savage Manufacturing Company, Inc.          Fabricated Metal Products
          211 E. Dowland Street

          Star Watch Case Company                     Watch Cases
          S. Rath Avenue

          Straits Steel &amp; Wire Corporation            Wire Products - Fabricated
          N. Rowe Street

          Thompson Cabinet Company                    Wood &amp; Steel Equipment for Printing
          E. Lake-Street                              Trade

          Western Concrete - Ludington Division       Concrete Products
          802 S. Washington Avenue

          Whitehall Industries                        Precision Metal Machining
          800 S. Madison

                                                 1-22
<pb n="38" />

          The occupational structure of Mason       County is mainly blue collar (48.1%),
          followed by white collar-(36.1%).      The,1970 occupational structure, by profes-
          sion, for Mason County and Michigan is shown in Table 8.

                                                 TABLE 8
                                        OCCUPATIONAL STRUCTURE
                                            1970 PERCENTAGES

          Occupation                                            Mason County       Michigan

          White Collar                                               36.1            44.9

               Professional, technical, and kindred                  10.5            14.2
               Managers and administration (exc. farm)                7.8             7.0
               Sales workers                                          5.7             6.8
               Clerical and kindred                                  12.1-           16.19

          Blue Collar                                                48.1            40.7

               Craftsmen, foremen, and kindred                       18.2            15.4
               Operatives (exc. transport)                           19.3            17.5
               Transport equipment operatives                         4.6             3.8
               Laborers (exc. farms)                                  6.0             4.0

          Farm                                                        4.0             1.5

               Farmers and farm managers                              2.9             1.0
               Farm -laborers and farm foremen                        1.1             0.5

          Service                                                    11.8            12.9

               Service workers                                       10.9            11.9
               Private household workers                              0.9             1.0

          S55FH77-O.S. Bureau o   f the Census. Census of   Population:  1970.

          4.   Labor Market

          In Mason County,   the number of persons in the working age group has increased
          by 7.5% from 1960 to 1970.     This is slightly greate   r than the overall popula-
          tion increase for  Mason County during the same time period. A partial explana-
          tion for this increase may be that the scenic and environmental quality of the
          region has a positive effect on the labor supply.

          The Mason County labor force (male/female) is given in Table 9, Total Labor
          Force. The percentage of females has increased by over 44% from 1960 to 1970.

                                                   1-23
<pb n="39" />

                                                 TABLE 9
                                            TOTAL LABOR FORCE
                                          (14 years and older)
                                              Mason County

                                                    1960          1970       % Change

                   Total in Labor Force           7,875          8,792        +11.6
                   Male                           5,737          5,700        - 0.6
                      % Male                        75.1          70.9
                   Female                         2,138          3,092        +44.6
                      % Female                      27.5          36.2

                   S55FH7-G.S. Census of Population, 1960 and 1970.

          C.    WATE-RBORNE COMMERCE

          1.    Commodity Flows

          a.    General

                Total U.S. domestic waterborne commerce (internal, coastwise and Great
                Lakes) has shown a generally steady growth from 579 million tons in 1947
                to 994 million tons in 1973, with a slight overall decline through the mid
                1970's.   The major component of this growth in domestic traffic during
                these 30 years has been the traffic on inland waterways designated as
                internal traffic.   Coastwise traffic between ocean ports increased moder-
                ately over this period, while traffic on the Great Lakes shows a slight
                decline.

                Total U.S. waterborne commerce, both foreign and domestic, is dominated by
                the energy commodities of coal, coke and petroleum products which consti-
                tute over 60% of the total.       Patterns of total commodity movement are
                concentrated on the northeast Atlantic Coast, the Gulf Coast, the
                Mississippi River, the Great Lakes, and the Pacific Coast.

                Waterborne commerce on the Great Lakes - St. Lawrence Seaway system
                (Figure 8) is a combination of domestic lakewise trade and foreign trade
                with Canada and overseas areas.         The dominant commodity flow pattern
                through the Great Lakes originates in Minnesota and Michigan's Upper
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                Peninsula, moves through Lake Superior to Lake Huron,       and flows inland
                through ports along lower Lake Huron and western Lake Erie. In 1976, this
                total commodity movement was in. the range of 60 to 80 million short tons
                annually between its origin and destination.

                A secondary pattern of flow across the Great Lakes originates equally from
                two areas -- the Minnesota and Michigan Upper Peninsula area and the Upper
                St. Lawrence Seaway. These two flows combine near the Straits of Mackinac
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                40 million short tons.

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                The entire eastern half of the United States to the Great Lakes is very
                productive- as a producer of exports and as a consumer of imports.          The
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                much transportation costs as general cargo commodities and,        hence, are
                produced or consumed near the port used for export or the port used for
                import.

                Foreign trade is distributed nationally throughout the United States with
                the ports of the U.S. ocean coasts and the Great Lakes serving wide multi-
                state areas, pa'rticularly in the movement of general cargo commodities.

          C.    Major Commodity Flow Patterns

                The commodities which comprise the major portion of U.S. waterborne com-
                merce are discussed below, with particular emphasis on flow patterns
                through the Great Lakes system.

                (1) Coal

                     The Great Lakes has substantial traffic moving from established coal
                     shipping points on Lake Erie and Lake Michigan to U.S. and Canadian

                                                   1-25
<pb n="42" />

                    Great Lakes harbors (Figure 9). A newly emerging pattern is created
                    by the movement of coal from the Western Mountain states and Great
                    Plains states to eastern, southern, and western markets.   One of the
                    new routes developed since 1974 is the movement of western coal from
                    Montana by rail to the port of Duluth/Superior and from there by
                    1,000-foot ships, popularly called superlakers, from Lake Superior to
                    the lower Great Lakes ports, such as Detroit and Chicago. The Great
                    Lakes provide the means of transport for about 38 million tons of
                    coal from ports in the western half of Lake Erie to U.S. destinations
                    on all the Great Lakes, as well as to Canadian destinations in the
                    previous pattern of movement.

               (2)  Crude Petroleum

                    The dominant water movement of crude petroleum in the U.S. (Figure
                    10) is its import into the New York/New Jersey/Delaware River area on
                    the East Coast, and the Texas/Louisiana area on the Gulf Coast.
                    Crude petroleum is not a waterborne commodity of major significance
                    on the Great Lakes, since Michigan and Wisconsin have a well devel-
                    oped pipeline network.

               (3)  Refined Petroleum

                    Refined petroleum commodity flows (Figure 11) show similarities to
                    crude petroleum.    However, pipeline flow is proportionately more
                    significant than  for crude petroleum.    Refined petroleum products
                    move up and down on the Great Lakes.       On Lake Michigan, refined
                    petroleum moves   from Chicago to cities along the Michigan and
                    Wisconsin coasts.

               (4)  Iron Ore

                    The waterborne transport of iron ore dominates the Great Lakes/ St.
                    Lawrence Seaway system (Figure 12).    Iron ore from mines and pel-
                    letizing plants in the Lake Superior region is moved by lakeships to
                    steel mills in the lower lakes region. High volumes of imported iron
                    ore are moved from eastern Canada up the St. Lawrence Seaway to the

                                                1-26
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                    steel mills on and near the lower Great Lakes. Served by Great Lakes
                    ports, this region accounts for about two-thirds of the steel produc-
                    tion in the U.S.

               (5)  Iron and Steel Products

                    Large volume iron and steel movements occur on the St. Lawrence
                    Seaway (Figure 13).    Although movements occur as both imports and
                    exports, imports are the major flow. The Great Lakes area, with its
                    automotive, machinery and metal fabricating industries, is a heavy
                    consumer of iron and steel products, both domestic and foreign. Here
                    also is the largest concentration of steel production in the United
                    States. With the exception of the Baltimore region, where exports of
                    iron and steel products exceed imports, other coastal harbor areas
                    are shown to be net importers of iron and steel products.

               (6)  Grain

                    Grain (Figure 14) moves from Minnesota, Montana, and North Dakota by
                    rail and truck to the port of Duluth/Superior on Lake Superior for
                    export shipment by the St. Lawrence Seaway, or to be shipped through
                    ports such as Buffalo for domestic use.     A secondary flow of grain
                    from farms in  Iowa, Wisconsin, and Illinois moves north from Chicago
                    and Milwaukee  along Lake Michigan to join this export flow.       Grain
                    from Ohio and Indiana moves through to Toledo.

               (7)  Industrial and Agricultural Chemicals

                    The waterborne movement of agricultural and industrial chemicals in
                    the U.S. presents a complex pattern.     Industrial chemicals manufac-
                    tured in the Gulf area and from Texas to Louisiana are shipped up the
                    Mississippi River and tributaries and to export.     There is substan-
                    tial movement of industrial chemicals from the Gulf to both east and
                    west coasts of the U.S.    In the Great Lakes system (Figure 15), the
                    flow patterns for both industrial and agricultural chemicals are
                    similar to those described for grain movement.

                                                 1-27
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          d.   Volume of Commodity Flows Throug   h Major Ports on the Great Lakes

               The total freight carried through Lake Michigan ports in 1976 was
               104,500,000 tons.     Table 10 shows a breakdown of tonnage, by lake, for
               ports in the Great Lakes.       Lake Michigan is seen to have approximately
               30.7% of the total Great Lakes tonnage.       Only Lake Erie carries a larger
               percentage - 38.5% (131,100,000 tons) - through its ports.

                                                TABLE 10
                                     MAJOR U.S. GREAT LAKES PORTS
                                       WATERBORNE COMMERCE 1976
                                      (in millions of short tons)

                                               Domestic       Foreign          Total
                     Port                      Commerce       Commerce       Commerce

          Lake Michigan                                                        104.5
                                                                                         (30.4%)
            Chicago/Calumet Harbor, IL            33.7          6.9             40.6
            Indiana Harbor, IN                    16.7          2.8             19.5
            Buffington, IN                        NIA           N/A              2.2
            Gary, IN                              N/A           N/A              9.9
            Burns Waterway, IN                    5.1             .4             5.5
            Muskegon, MI                          2.2                            2.2
            Ludington, MI                         2.3                            2.3
            Port Inland, MI                       N/A           N/A              3.4
            Escanaba, MI                          N/A           N/A             11.9
            Green Bay, WI                         2.1              2             2.3
            Port Washington, WI                   1.1                            1.1
            Milwaukee, WI                         23              .9             3.6
          Lake S@perior                                                         71.0     (20.6%)
            Duluth/Superior, MN                   28.6          4.0             32.6
            Two Harbors, MN                       N/A           N/A              8.3
            Silver Bay, MN                        N/A           N/A             11.0
            Taconite, MN                          N/A           N/A             12-'-2
            Presque Isle, MI                      5.7           1.2              6.9

          Lake Huron                                                            36.4
                                                                                         (10.6%)
            Port Dolomite, MI                     N/A           N/A              3.5
            Calcite, MI                           N/A           N/A             11.3
            Drummond Island, MI                   2.1             .5             2.6
            Stone Port, MI                        N/A           N/A              9.8
            Alpena, MI                            2.7             .1             2.8
            St. Clair, MI                         3.1             .2             3.3
            Saginaw River,  MI                    N/A           N/A              3.1

                                                    1-28
<pb n="52" />

                                                 Domestic       Foreign          Total
                         Port                    Commerce       Commerce       Commerce

            Lake Erie                                                            131.1
                                                                                           (38.1%)
              Detroit, MI.                          21.0          5.4            26.4
              Toledo, OH                            16.3          8.7            25.0
              Marblehead, OH                        N/A           N/A             1.4
              Sandusky, OH                          2.3           3.1             5.4
              Huron, OH                             2.4            .5             2.9
              Lorain, OH                            7.0            .5             7.5
              Cleveland,  OH                        13.7          4.5            18.2
              Fairport, OH                          2.3            .4             2.7
              Ashtabula, OH                         6.1           5.6            11.7
              Conneaut, OH                          8.5           7.9            16.4
              Erie, PA                              1.0            .2             1.2
              Buffalo, NY                           8.6           3.7            12.3

            Lake Ontario                                                             .9

              Oswego, NY                            N/A           N/A                .9

            TOTAL - MAJOR PORTS                                                  343.9    (100%)

            ----------

            Source: National Waterways Study, Part 3, The Great Lakes, U.S. Army Corps
                     of Engineers
            N/A      Not available on a domestic/foreign basis
                     Less than 100,000 tons

                 Table 11 shows total Michigan port tonnages for 1978.          This table indi-
                 cates that.activity on the Lake Huron side is concentrated in the areas of
                 Detroit, Port Calcite, Stoneport, Saginaw, and Alpena.        Conversely, acti-
                 vity on Lake Michigan is fairly evenly distributed, with the exception of
                 Chicago being a concentrated area.          Total tonnage for many smaller
                 Michigan ports has decreased since 1971, while medium to larger port
                 activity has remained fairly constant.

                                                     1-29
<pb n="53" />

                                                 TABLE 11
                                    MICHIGAN PORT TONNAGES FOR 1978

                Harbor                              1978 Tonnage         % of State Total

                Detroit (Port of)                     25,881,508               25.5
                Escanaba                              13,207,490               13.0
                Port Calcite                          11,699,229               11.5
                Stoneport                             9,217,883                9.1
                Marquette-Presque Isle                8,043,758                7.9
                Port Dolomite                         3,633,718                3.6
                Port Inland                           3,585,239                3.5
                5t. Clair                             3,319,786                3.3
                Alpena                                3,203,682                3.2
                Saginaw River                         3,173,573                3.1
                Port Drummond                         2,578,354                2.6
                Ludington                             2,397,920                2.4
                Monroe                                2,374,166                2.3
                Muskegon                              1,952,476                1.9
                Grand Haven                              701,717               0.7
                Alabaster                                683,104               0.7
                Port Huron                               647,097               0.6
                Port Gypsum                              631,274               0.6
                Frankfort-Elberta                        542,449               0.5
                Marysville                               529,920               0.5
                Port Penn Dixie                          428,934               0.4
                Traverse City                            426,212               0.4
                Holland                                  419,916               0.4
                Marine City                              324,653               0.3
                St. Joseph-Benton Harbor                 320,635               0.3
                Gladstone                                298,847               0.3
                Harbor Beach                             253,711               0.2
                Manistee                                 183,806               0.2
                Charlevoix                               163,212               0.2
                Menominee-Marinette                      137,417               0.1
                Cheboygan                                134,827               0.1
                Keweenaw Waterway                        131,689               0.1
                Lime Island                               95,301               0.1
                Mackinaw City                             90,251               0.1
                Sault Ste. Marie                          62,349               0.1
                Algonac                                   23,844               0.1
                Mackinac Island                           14,917               0.1
                Harrisville                                 7,104              0.1
                St. James                                   6,898              0.1
                Leland                                        924              0.1

                                                     101,529,788             100.0%

                S55FEK__Aichigan Port Needs Study, 1981.

                                                   1-30
<pb n="54" />

            e.   Commodity Flows Through Ludington

                 The historic pattern of waterborne commerce through the port at Ludington
                 is shown in Table 12.

                                                     TABLE 12
                              HISTORICAL PATTERN OF TOTAL WATERBORNE COMMERCE
                                 Year         LUDINGTON, MICHIGAN       Tonnage

                                 1969                                 3,664,748
                                 1970                                 4,643,609
                                 1971                                 4,258,442
                                 1972                                 3,368,015
                                 1973                                 2,557,086
                                 1974                                 2,178,835
                                 1975                                 2,123,507
                                 1976                                 2,338,774
                                 1977                                 2,448,983
                                 1978                                 2,397,920
                                 1979                                 2,764,880

                                 Mean  Annual                         2,976,799

                 Domestic freight traffic, by commodity for          1979, is shown in Table 13.
                 Due to the overlap in categories, it is not possible to break out tonnages
                 for individual shippers.

                                                   TABLE 13
                                DOMESTIC FREIGHT TRAFFIC BY COMMODITY, 1979
                                              LUDINGTON, MICHIGAN
                                                 (short tons)

                          Commodity                      Receipts       Shipments          Total

                 Barley and Rye                            2,426                             2,426
                 Corn                                          160                             160
                 Wheat                                         60                               60
                 Hay and Fodder                                80                               80
                 Field Crops, NEC                          6,110                             6,110
                 Animals and Products, NEC                     115             --              115
                 Miscellaneous Farm Products               3,255               220           3,475
                 Copper Ore and Concentrates                   --           1,308            1,308
                 Nonferrous Ores, Conc., NEC                   80              853             933
                 Coal and Lignite                          19,453          28,914           48,367
                 Limestone                                924,735              --          924,735
                 Sand, Gravel, Crushed Rock                18,700         375,550          394,250
                 Clay                                          --              510             510
                 Natural Fertilizer Mats, NEC                                  60               60
                 Sulphur, Dry                           1-31                3,710            3,710
<pb n="55" />

                        Commodity                     Receipts      Shipments         Total

                Nonmetallic Minerals, NEC                    74        149,735        149,809
                Meat, Fresh, Chilled, Frozen            2,173                           2,173
                Dairy Products, NEC                     6,716             190           6,906
                Dried Milk and Cream                       370            172              542
                Vegetables and Prep, NEC               12,906           3,372          16,278
                Prep Fruit and Veg Juice, NEC                40           783              623
                Wheat Flour and Semolina               41,301                          41,301
                Prepared Animal Feeds                  23,031                          23,031
                Grain Mill Products, NEC               70,908             100          71,008
                Sugar                                      860                             860
                Alcoholic Beverages                     5,137                           5,137
                Miscellaneous Food.Products             7,745           2,051           9,796
                Timber, Posts, Poles, Piling               200                             200
                Pulpwood, Log                          13,221          23,358          36,579
                Lumber                                 37,402           5,161          42,563
                Veneer, Plywood, Worked Wood           13,876               60         13,936
                Wood Manufactures, NEC                  4,294               50          4,344
                Furniture and Fixtures                     298                             298
                Pulp                                    5,348             980           6,328
                Standard Newsprint Paper                9,966          11,766          21,732
                Paper and Paperboard                   134,286         56,599         190,885
                Pulp and Paper Products, NEC            1,590          32,037          33,627
                Basic Chemicals and Prod, NEC                          331,181        331,181
                Miscellaneous Chemical Prod             7,180          101,873        109,053
                Rubber and Misc Plastic Prod           18,640           4,312          22,952
                Leather and Leather Products                            2,543           2,543
                Glass and Glass Products                                1,188           1,188
                Building Cement                                        11,195          11,195
                Structural Clay   Products                                642              642
                Slag                                   38,160                          38,160
                Iron and Steel Plates, Sheets                           6,173           6,173
                Iron and Steel Pipe and Tube                            4,633           .4,633
                Iron and Steel Products, NEC            2,655             215           2,870
                Aluminum and Alloys, Unworked              190                             190
                Fabricated Metal Products                  465          1,454           1,919
                Machinery, Except Electrical           15,906           1,241          17,147
                Motor Vehicles, Parts, Equip                           27,124          27,124
                Ships and Boats                            175                             175
                Misc Manufactured Products             45,561          59,137         104,698
                Iron and Steel Scrap                   10,460           5,609          16,069
                Paper Waste and Scrap                      275          2,140           2,415
                Waste and Scrap                            106                             106

          f.    Cross-Lake Passengers

                Cross-lake passenger traffic, for the eleven-year period of 1969-1979, is
                given in Table 14 for the Ports of Ludington, Frankfort, and Muskegon.
                The peak year for total cross-lake passenger traffic was 1970, and the
                peak year for Ludington's passenger traffic was 1971.           Total passenger

                                                     1-32
<pb n="56" />

                  traffic has averaged 204,569 people per year and has been generally declin-
                  ing. Ludington passenger traffic has averaged 165,469 people per year and
                  has also been generally declining.

                                                    TABLE 14
                                        CROSS-LAKE PASSENGER TRAFFIC
                                                   1969 - 1979

                      Year         Ludington          Muskegon        Frankfort           Total

                      1969          174,224            101,096         25,225            300,545
                      1970          177,353            111,594         22,577            311,524
                      1971          205,389                 742        29,666            235,797
                      1972          176,598                  -         21,614            198,212
                      1973          179,055                  -         15,076            194,131
                      1974          188,426                  -         13,021            201,447
                      1975          149,251                  -         14,077            163,328
                      1976          156,218                  -         13,410            169,628
                      1977          169,871,                 -         17,449            187,320
                      1978          110,006                  -         28,451            138,457
                      1979          133,765                  -         16,105            149,870

                                                                                       2,250,259

                                                        1-33
<pb n="57" />

                                                         e

 v

                                                                    Chapter II
                                     Existing Harbor Facilities
 I .
<pb n="58" />

                                            CHAPTER II

                                    EXISTING HARBOR FACILITIES

          INTRODUCTION

          The objective of this chapter is to present the information on existing commer-
          cial facilities in the Ludington Harbor gathered during an on-site inventory
          and review.  This review consisted of field observations of the existing com-
          ponents of each facility with regard to structural condition and need for
          general repairs. An evaluation of the site was made to ascertain the need for,
          or availability of, land for expansion. This chapter also addresses the func-
          tional viability of related facilities and intermodal connections. Input from
          the operators of these facilities was requested regarding viability, and is
          included in this chapter.

          The intent of this information is to provide an overview of the quality of
          existing harbor facilities, to identify significant deficiencies, and to deter-
          mine the type of repairs and new construction that would be involved in an
          upgrading effort. The detailed information which is required beyond the plan-
          ning stage, such as structural analysis of specific components in order to
          design repairs or a replacement, is not included in this review.

          A.   EXIS TING HARBOR FACILITIES

          An outer basin, formed by arrowhead breakwaters, protects the channel connect-
          ing Lake Michigan and Pere Marquette Lake. The breakwaters are 550 feet apart
          at the outer ends, diverging at a 90-degree angle. The north and south break-
          waters have lengths of 1,800 feet and 1,600 feet, respectively.        The inner
          channel is 2,000 feet in length and has a navigable width of about 230 feet.

          The recently completed Ludington Municipal Marina occupies the northernmost
          shores of Pere Marquette Lake, just inside the inner channel.     A rubble mound
          wave absorber and steel sheet pile revetment also have recently been construc-
          ted along the southern edge of the inner channel and turn into Pere Marquette
          Lake.  These improvements were part of the project for modification of the
          harbor and channel at Ludington.

                                                 II-1
<pb n="59" />

           The Ludington Yacht Club and Ludington Outboard Club have private docking
           facilities on the northeast shores of Pere Marquette Lake.     Major commercial
           docks on the lake are operated by the C&amp;O Railroad for ferry docking, by The
           Dow Chemical Company, and by Sand Products, Inc.     Figure 16 shows the major
           harbor structures, along with harbor dimensions and controlling depths.

           B.   ON-SITE REVIEW OF EXISTING COMMERCIAL FACILITIES

           1.   Chesapeake &amp; Ohio Railroad Car Ferry

           A site plan of the C&amp;O Railroad Ferry slips and docks are shown in Figure 17.
           The railroad currently operates one ferry run per day between Ludington and
           Kewaunee, Wisconsin, and is using only Slip 2.     The steel sheet pile docks
           located between Slips 1 and 2, Slips 2 and 3, and south of Slip 3 are referred
           to as docks 1-1/2, 2-1/2 and 3-1/2, respectively.     The long wing fender and
           pile clusters at Slip 1 were removed in 1982.   Slip 3 is currently not in use
           due to damage and may be removed in the near future by a private firm under
           contract with the C&amp;O Railroad.

           a.   Car.Ferry Slip 2

                The following information-is presented for this slip only as it is the
                only one in current use and may be the only remaining slip in the future.
                Significant differences in Slips 2 and 3, in addition to a discussion of
                their damages, follows:

                (1)  Components and Materials of Construction

                     The car ferry slip consists of a long-wing fender or pier, a hinged
                     apron or bridge for loading railroad cars onto the ferry, a ramp for
                     loading automobiles on the mid-level of the ferry, a passenger load-
                     ing ramp, and several piling clusters for ferry turning and mooring.

                     Figure 18 is a view of the end of the long-wing fender at Slip 2. It
                     consists of three rows of creosote treated timber piling with a butt
                     diameter of 18 to 24 inches.    The pilings are separated by double
                     rows of 3" x 12" creosote treated cross members. The vertical facing

                                                 11-2
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          -WILLIAMS Bt WORKS                                                                           MARCH
<pb n="62" />

                                                                    CATWALK-
                                                                    STEEL GRATING

                                                                    18-24!1DIA.
                                                                    TREATED TIMBER PILING

                    VERTICAL FACING
                    UNTREATED OAK:3@'X 12"-
                    REPLACED EVERY                                  CROSS MEMBERS
                    10 to 15 YEARS
                    MORE FREQUENT
                    REPLACEMENT IN
                    IMPACTAREAS

                    FACING WHALERS

                                                                    PILING EMBEDDED IN
                                                                    SAND/GRAVEL BOTTOM

                                                                               Figure IS
                                                                       CROSS-SECTIONAL VIEW
                                                                       OF LONG-WING FENDER
                                                                        CAR FERRY SLIP No. 2
                                                                          CITY OF LUDINGTON
             WILLIAMS 81 WORKS                                        PORT DEVELOPMENT STUDY
<pb n="63" />

                    boards, which are in contact with the docked ferry, are 311 x 12"
                    untreated oak.   Along the top of the long-wing fender is a metal
                    grating catwalk.

                    The turning pile cluster is located at the end of the long-wing
                    fender to facilitate maneuvering and turning of the ferry and to
                    protect the fender from impact. Figure 19 shows a cross-section view
                    of the pile cluster. The inner pile core and outer row of piling are
                    separated by numerous wraps--of neoprene tubing, 6 inches in diameter,
                    held in place with a steel cable through the center.      This tubing
                    functions as a shock absorber within the pile cluster.    The cluster
                    is wrapped on the outside with 3/4" steel cable.    There are approx-
                    imately 50+ creosote treated piles in this cluster.

                    In addition to the turning pile cluster, the slip has a lining clus-
                    ter of 25-30 treated piles located midway along the long-wing fender.
                    An opposite cluster is located next to the apron and across from the
                    fender to facilitate docking.

                    The apron or bridge includes a wood platform which is hinged at the
                    dock side and raised and lowered with a counter weight system.      The
                    bridge surface is constructed of treated 12" x 12" timbers, with rail
                    tracks on each side to allow loading and unloading of-both sides of
                    the ferry. During loading and unloading, the apron rests in a pocket
                    at the stern of the ferry.

                    The auto and passenger loading ramps are behind the long-wing fender
                    near the apron area.  The auto ramp is a wood structure supported by
                    treated timber piling and cross members. Figure 20 shows a photo of
                    the support structure of the auto loading ramp.

                    The passenger ramp is a staircase supported by concrete-encased
                    structural steel piling.

               (2)  History of Repairs and Current Conditions of Components

                    Most components of ferry Slip 2 are generally in good condition. The
                    original date of construction of the slip is not known.         It was
                                                11-3
<pb n="64" />

                                                                     6" DIAMETER NEOPRENE
                                                                     TUBING (IMPACT ABSORBER)

                                                                     3/4't STEEL CABLE WRAP

                                                                     INNER CORE PILING

                                                                     OUTER CORE PILING

                                                             CAT WALK

                                                                                         Figure 19
                                                                              CROSS-SECTIONALVIEW OF
                                                                               TURNING PILE CLUSTER
                                                                                 CAR FERRY SLIP No. 2
                                                                                   CITY OF LUDINGTON
               WILLIAMS Ek WORKS                                               PORT DEVELOPMENT STUDY
<pb n="65" />

                                                        , ld
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                                                      A4

                                                                      if

                                                                            Figure 20
                                                                          AUTO RAMP
                                                                       SUPPORT PILING
                                                                     CAR FERRY SLIP No. 2
                                                                       CITY OF LUDINGTON
             WILLIAMS 84 WORKS                                     PORT DEVELOPMENT STUDY
<pb n="66" />

                     completely rebuilt in the late 20's or early 30's.          The long-wing
                     fender is showing some signs of impact midway along its length and is
                     beginning to lean slightly toward the shore.        The oak facing along
                     this fender is replaced as needed, usually every 10-15 years, and'
                     more frequently in high impact areas.

                     The turning pile cluster, which was completely rebuilt in the 1950's,
                     is also in good condition. The original construction of this piling
                     reportedly failed, breaking off at the point of penetration.             The
                     condition of the lining cluster pile is good, with slight damage to
                     the exterior piling. Figure 21 is a photo of this piling. The oppo-
                     site pile cluster, which can be seen in the background of the photo,
                     is in fair condition and beginning to lean away from the docking

                     area.

                     The auto and passenger ramps are in generally good condition, with no
                     visible signs of rot or decay. The bridge is also in good condition.
                     Maintenance on this structure, involving timber replacement, is
                     reportedly done on a regular basis to insure that rail alignment is
                     maintained.

          b.    Car Ferry Slip I

                Ferry Slip I has the same basic com      ponents as Slip 2.     However, it is
                lacking an auto and passenger ramp and has a shorter apron.          This ferry
                slip was the original docking facility for ferry runs across Lake
                Michigan.   In the mid 1970's, the slip was taken out of service when the
                bridge or apron was damaged by a ferry during unloading. It has not been
                repaired or used since that time.

                In 1982, the long wing fender and pile-clusters were removed at Slip 1.
                The long-wing fender of Slip 1 was not in good condition at the time of
                removal, leaning away from the dock area approximately 10'-15'.

                Reportedly, the configuration of Slip 1 has several inherent disadvan-
                tages.  The orientation of the slip made docking difficult during strong
                northerly winds. The short bridge did not accommodate wide or long rail-
                road cars well and was less secure in the ferry pocket than the longer
                                                    11-4
<pb n="67" />

                                       I W

                                    -7

                                                                                 low-

                                                                              Figure 21
                                                                       LINING CLUSTER PILE
                                                                       AND OPPOSITE PILE
                                                                       CAR FERRY SLIP No. 2
                                                                         CITY OF LUDINGTON
            WILLIAMS Sk WORKS                                        PORT DEVELOPMENT STUDY
<pb n="68" />

                bridges at Slips 2 and 3.   Finally, the railroad tracks leading up to the
                bridge are on a fairly sharp curve;        occasionally, train derailments
                resulted.

          C.    Car Ferry Slip 3

                Slip 3 has severe long-wing fender damage and currently is inoperable.
                Figure 22 is a photo of the the long-wing fender taken from the bridge.
                This damage, which reportedly is the result of impact during docking, has
                caused the collapse of the long-wing fender and turning cluster piling.

                The original date.of construction.of Slip 3 is unknown. It was in service
                when two ferries were running per day up to a year ago, but was damaged
                and beginning to lean severely at that time. The components of Slip 3 are
                similar to those of Slip 2 with the exception that the auto ramp is con-
                structed of steel rather than wood.     Other components of the slip, aside
                from the piling clusters and long-wing fender, are generally in fair to
                good condition.   As mentioned previously, Slip 3 may be removed in the
                near future.

          d.    Sheet Pile Dock 1-1/2

                The location of this docking area is shown in Figure 17.      It consists of
                steel sheet pile with a steel cap over the top of the piling.           Rubber
                tires are attached along the face to provide some protection against
                impact. The dock has concrete-filled steel mooring bollards spaced approx-
                imately every 30 feet.

                Currently, this dock is used by a local asphalt firm to unload bulk sand
                and aggregate from self-unloading barges moored at the dock.        The bu I k
                material is unloaded and piled approximately 50 feet from the dock face on
                the landward side of the railroad tracks.

                This dock piling was installed in the late 50's and is generally in good
                condition.  Some of the steel plate across the top has become dislodged
                and bent in places. One of the mooring bollards has also been dislodged.

                                                  11-5
<pb n="69" />

                                                                           7

                                                                           Figure 22
                                                                            SLIP 3
                                                                     LONG-WING FENDER

                                                                      CITY OF LUDINGTON
            WILLIAMS EN WORKS                                      PORT DEVELOPMENT STUDY
<pb n="70" />

          e.    Sheet Pile Docks 2-1/2 and 3-1/2

                Dock 2-1/2 is located between Slips 2 and 3 and is about half as long as
                Dock 1-1/2. Date of construction of the dock is not known. The dock is
                constructed of steel sheet pile with untreated wood whalers.

                The sheet pile is in good condition with the exception of the westerly 100
                feet.   The top 1 to 2 feet of this piling has been bent, probably due to
                impact. The wood whalers show evidence of impact damage along the length
                of the dock and are in fair condition. Reportedly, the whalers have been
                replaced as necessary in the past, usually every 10 years.

                Dock 3-1/2 is generally of the same construction as 2-1/2 and is in good
                condition, with some impact damage to the whalers.         Currently, docks 2J
                and 3J are used for ferry mooring for maintenance and repairs.

          f.    Site Considerations

                The Site Plan of the C&amp;O property is shown in Figure 17.         Aside from the
                land adjacent to dock 1-1/2, there is little vacant land.            Rail spurs
                which extend to each of the slips occupy a major portion of the land.
                Buildings on the site are the marine shop, marine store, roundhouse, and
                fou r storage buildings.

           g.   Functional Viability

                The general purpose dock (1-1/2) is adequate for small vessels and barges.
                It is presently being used by Laman Asphalt for landing and storage of
                bulk materials. Stockpiling of heavy materials is limited to the landward
                side of the railroad tracks due to the potential of seawall failure at
                this facility.    This dock could be used, with substantial improvements,
                for lake ships. However, tugboat assistance would be necessary for leav-
                ing the dock during times of strong west winds. The general purpose dock
                has good rail access and limited over-the-road access.            This dock is
                served by full utilities.

                                                    11-6
<pb n="71" />

                 At present, only one slip (2) is functional for car ferry service and the
                 other two sheetpile docks (2-1/2 and 3-1/2) are being used for vessels in
                 layup. The car ferry terminal facilities are supported by the following:

                 (1)  Machine shop (car ferry maintenance and supplemental freight yard
                      maintenance)
                 (2)  Marine storage (storage of supplies for car ferries, such as food,
                      linen, etc.)
                 (3)  Roundhouse (eastbound and westbound railroad yard; no piggyback
                      facilities)
                 (4)  Paint shop (supply and maintenance for marine structures)
                 (5) Storage buildings (four individual storage buildings)

                 The C&amp;O Railroad considers the single serviceable slip as adequate for
                 present use.

           2.    The Dow Chemical Company

           The Dow Chemical Company Ludington Plant was built during the war in the 1940's
           and produced magnesium.      It was later converted to a commercial lime plant.
           Figure 23 shows the site plan of the Dow Chemical docking facilities.           Liquid
           product transfer takes place on the east dock face, while dry bulk materials
           (primarily limestone) are unloaded on the west dock face.

           a.    Area East of the East Dock Face

                 The shoreline east of the east dock face was formerly used for mooring
                 barges and loading bulk products through a conveyor system.          This dock
                 area no longer serves a functional purpose.        The shoreline consists Of
                 rock and slag on a 1:1    slope.   Mooring pile clusters, 20 feet from the
                 shore, are spaced approximately 200 feet apart.          These pile clusters
                 consist of approximately 15 untreated wood pilings wrapped with steel
                 cable.   Steel mooring bollards are spaced approximately 175 feet apart
                 along the shoreline.

                 The mooring pile clusters were installed 10 to 15 years ago and are in
                 fair condition, with some visible signs of decay.           The steel mooring

                                                    11-7
<pb n="72" />

                                                       N

                        MOORING
                        BOLLARDS

                                              OPEN
                                           STORAGE
                                             AREA

                      STEEL
                       SHEET
                        PILE
                        WITH
                      TIE BACKS
                                      DI RT
                                      ROAD

                 HOPPER

                                                                        OVERHEAD
                                                                        PIPELINE

              25-P
              PIL ,_-                                                    1,, 7" -,
              CLUSTER                                                           MOORING
                                                                                BOLLARD
                                                                                SPACING
                                                                                   175 FT

                     CONCRETE                                   BUILDING
                     SLABS FOR
                     SLOPE                                 LIQUI
                     PROTECTION                            PRODUCTS
                                                        EL
                                                      OIL           PILE
                                                                    CLUSTER
                                                 STEEL              SPACING
                                                 SHEET               200 FT
                                                 PILE
                                  PILE                                         NO
                    PERE          CLUSTER                                      DOCK
                                                                               FACE
                        MARQUETTE

                                   LAKE

                                                                          LUDINGTON
                                                                   PORT DEVELOPMENT STUDY
                                                                         Figure 23
                                                                   DOW CHEMICAL CO.
                                                                        SITE PLAN

             WILLIAMS a WORKS                                   MARCH, 1982 NO SCALE
<pb n="73" />

              bollards are in excellent condition. Figure 24 is a photo taken from this
              area facing west.   In the foreground is the bulk material loading equip-
              ment which is presently inoperative.

         b.   East Dock Face

              The east dock is the area where bulk liquid products are loaded and un-
              loaded from barges.   The date of construction of this dock is not known.
              The dock consists of steel sheet pile with two rows of horizontally placed
              untreated wood whalers bolted to the sheet pile.

              The general condition of the steel sheet pile is good. The timber whalers
              along this dock are in fair condition, with some impact damage which may
              necessitate repair.

         C.   Area Between East and West Dock Face

              This area is undeveloped for docking purposes.     The slope has,been pro-
              tected with salvaged concrete road slabs placed side by side.     Two 25-30
              pile clusters are located at the ends of this area.

         d.   West Dock Face

              The west dock face is used by self-unloading vessels which tie to mooring
              bollards along the dock face and unload limestone to a bulk storage area.
              Harbison-Walker leases a part of this dock for product export.
              The dock face'consists of steel sheet pile protected by a double row of
              treated timber whalers.    This sheet pile has tiebacks and is in good
              condition. A one-inch diameter pipe railing is attached to the top of the
              sheet pilei--

         3.   Mohawk Transportation

         a.   Facilities and Conditions

              The Mohawk Transportation docking facility site plan is shown in Figure
              25.   The site is located along the channel on the east side of Pere
              Marquette Lake.   Current use of the facility is by shallow draft barges
              which self-unload and stockpile limestone on the site.

                                                11-8
<pb n="74" />

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                                                                                                        Figure 24
                                                                                              PHOTO FROM EAST OF
                                                                                                   EAST DOCK AT
                                                                                                DOW CHEMICAL CO.

                                                                                                 CITY OF LUDINGTON
                                                                                            PORT DEVELOPMENT STUDY

                 WILLIAMS a WORKS
<pb n="75" />

                                   OPEN STORAGE AREA

       MUNICIPAL
         DOCKS      MOORING                                  MOORING
                    BOLLARD,                                 BOLLARD

                     - - - - - - - - - - - - - - - - - -

                                                                                  WOOD
                           WPOD PILINGS                                         CATWALK
                             DIAM. UNTREATEDOAK
                           SIGNS OF DECAY ON TOP
                           CONDITION - FAIR

               PERE MARQUETTE LAKE                CHANNEL

                                                                            LUDINGTON
                                                                      PORT DEVELOPMENT STUDY
                                                                             @wooo

                                                                            Figure 25
                                                                   MC*-IAWK TRANSPORTAMON
                                                                           SITE PLAN

     L-WILLIAMS        WORKS                                 __j  MARCH, 1982 NO SCALE     870291
<pb n="76" />

               Figure 26 is a photo of the facility, taken from the west.     The facility
               consists of timber piling near the shoreline, mooring bollards, a bulk
               material storage area, and an elevated wood walkway along the shoreline.
               The timber piling, while providing shoreline protection, is basically
               nonfunctional, since barges remain in the center of the channel moored to
               bollards on either side of the channel.

               The wood pilings are untreated oak, with a diameter of approximately 15
               inches and an approximate age of 10 years. Spacing of the piles is 20 to
               25 feet.  The one -mooring bollard on the Mohawk site is a 12-inch dia-
               meter, concrete-filled iron pipe.   A second mooring bollard, located on
               the municipal dock site, consists of a 24-inch concrete-filled steel pipe.
               The wood walkway along the shoreline is also untreated wood and is about
               50 feet in length.

               The condition of the piling along the shoreline is fair.        Al 1 of the
               piling show decay of the outer edge and across the top of the piling.
               Condition of both mooring bollards is good, with no visible signs of
               displacement. The wood walkway is in fair condition.'

          b.   Functional Viability

               The Mohawk terminal has minimum docking and material handling facilities.
               The space is extremely limited and there is no room for expansion without
               razing some existing buildings. This site has poor road/highway access.

               The use of this facility is limited to barges due to channel depth, width,
               and configuration.   When the barges use this facility, they tie off to
               both sides of the channel and block it for use by recreational boaters.

          4.   Western Concrete Products

          a.   Facilities and Conditions

               The Western Concrete Products facilities are located across the channel
               from the Mohawk terminal. Figure 27 shows the site plan of this terminal.

                                                11-9
<pb n="77" />

                                    4L

                                                                     Figure 26

                                                             MOHAWK TRANSPORTATION
                                                                EXISTING PILINGS

                                                                CITY OF LUDINGTON
                                                             PORT DEVELOPMENT STUDY

           WILLIAMS 8k WORKS
<pb n="78" />

            PERE

         MARQUETTE

            LAKE

                                                                     CHANNEL

                   111,00' SUBMERGED PILINGS
                                                  4 41,                  &amp;

                                  OPEN STORAGE AREA

                                                                            LUDINGTON
                 -6F--- MOORING                           OCK RIP-RAP-o@
                       BOLLARDS        -49-

                                                                      PORT DEVELOPMENT STUDY
                                                                            Figure 27
                                                                      WESTERN CONCRETE
                                                                           PRODUCTS
                                                                           SITE PLAN

     L-WILLIAMS Sk WORKS                                          MARCH, 1982 NO SCALE     87029 j
<pb n="79" />

               The piling was installed over 20 years ago and consists of untreated,
               timber piling, 6 to 14 inches in diameter.     Excessive decay has rendered
               the piling useless.

               The facilities are not in current use.     Past usage involved self-unload-
               ing, low-draft barges that tied to concrete piling or mooring bollards on
               either side of the channel. The condition of concrete piling and mooring
               bollards is good.    Future usage for other than this type vessel would
               require extensive reconstruction of the dock facilities and probable
               deepening of the channel.

          b.   Functional Viability

               The Western Concrete terminal has minimal docking and material handling
               facilities.   There is adequate room for the use of these facilities.
               However, there is minimal area for expansion.     There is poor road/highway
               access to this site. The navigation facilities (channel depth, width-, and
               configuration) are adequate for current use.

          5.   Sand Products

          The site plan of the Sand Products docking facilities is shown in Figure 28.
          This dock is located on property leased from The Dow Chemical Company.          The
          dock and bulk loading equipment is used to load sand brought by truck from
          Hart, Michigan onto vessels bound for Buffalo, New York, or Cleveland.

          a.   Facilities and Conditions

               The dock face is steel sheet pile with a strong tieback system and is in
               good to excellent condition.

               The general condition of mooring clusters is fair.     The timber piling for
               mooring clusters is untreated and some clusters are showing severe decay
               above the water line.    General condition of the clusters in the area of
               sheet piling is fair to good.    The clusters are constructed of 20± piles
               with wire wrapping 1.0 foot from the top and at the water line.

                                                  II-10
<pb n="80" />

                                                                       PERE

                                                                  MARQUETTE
                                    LOADING                            LAKE
                                    CONVEYOR
                         \.ISTACKER

                                                                     SHEET PILE - INTERLOCKING
                                                                     TIEP BACK
                                                                     3.5 FROM VERTICAL
                                                                     TIE BACK EVERY 10'

                                                   WOOD
                                                  CATWALK            STEEL/CEMENT
                                 MOORING                             M ORING DOLPHIN
                                BOLLARDS
                                  GOOD/
                                 EXCELLENT
                                 CONDITION                           WOOD
                                                                     CLUSTER
                OPEN                                                 PILINGS
               STORAGEi
                AREA

                                                                     20t PILE
                                                                     CLUSTERS
                                                                     (TYPICAL)

                                                                     EXCESSIVE DECAY

                                                     60-70'

                                                              50'

                                                    CATWALK
                                                     (WOOD)           50 PILE CLUSTER

          NOTE:
             TIMBER PILING- MATERIAL-
             UNTREATED OAK OR OTHER
             HARD WOOD                                                   LUDINGTON
                                        rr

                0'
            L S TACI

             EXPOSED WOOD SHOWS                                    PORT DEVELOPMENT STUDY
             SIGNS OF DECAY                                              Figure 28
             GENERAL CONDITION -FAIR                               SAND PRODUCTS CO.
                                                                   TERMINAL SITE PLAN

     L-WILLIAMS 8t WORKS                                        MARCH, 1982 __ NO SCALE 870291
<pb n="81" />

         b.   Functional Viability

              Sand Products maintains a dock, conveyor loader, and sand stockpile on
              land leased from Dow. The conveyor is generally in good condition and the
              dock condition varies from good to poor.     There is adequate area for
              existing operations and limited area for future expansion. The navigation
              facilities (channel depth, width, and configuration) are considered
              adequate for current use.   This facility is serviced by a private haul
              road.
<pb n="82" />

            %

U

                               Chapter III
                        Land Use Analysis
<pb n="83" />

                                               CHAPTER III

                                            LAND USE ANALYSIS

           INTRODUCTION

           The main focus of this study, port development and its related industrial
           development, must be balanced with other coastal land uses.          The purpose of
           this section is to analyze the opportunities/1 imitations for other competing
           land uses around Pere Marquette Lake.        It is focused on underdeveloped and
           undeveloped areas.

           This analysis reports land use opportunities/1 imitations for remarkable areas,
           large or small. Thus, not every parcel is discussed, but all areas of the lake
           are covered.   Alternate land use opportunities, as discussed in this chapter,
           are shown in Figure 29.

           A.   RESIDENTIAL

           Little of the coastal area within the corporate limits of Ludington is residen-
           tial.  There is some residential development, with lake views on the bluff
           behind the Dow Chemical Plant.     There is also some mixed residential develop-
           ment behind the C&amp;O Railroad property.      However, this development has neither
           lake views or access.     In the vicinity of the new municipal marina, there is
           some limited residential development. There is also a new multi-family condo-
           minium development at the north end of the Buttersville bar. This development
           enjoys direct access and views of both Lake Michigan and Pere Marquette Lake.
           It has maximized this advantage by providing a swimming beach on the Lake
           Michigan side and private marina facilities on the Pere Marquette Lake side.

           Although residential development along the Ludington coastal areas of the Pere
           Marquette Lake is limited, the opportunities are not.         An abandonment of the
           C&amp;O Railroad facility would open many acres of waterfront property to develop-
           ment.  The cost of removing the existing improvements, the railroad's general
           reluctance to sell land, and the cost of building the project would push the
<pb n="84" />

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<pb n="85" />

          cost of this project very high. Other industrial facilities, such as the Star
          Watch Case plant, may offer similar redevelopment opportunities at a more
          modest,cost.   The Western Concrete Products area also could be developed for
          residential use.

          The mixed use areas along South Washington Avenue and East Dowland Street have
          limited coastal residential redevelopment opportunities due to the fragmented
          ownership and limited water access/views.

          In contrast to the City of Ludington, the Pere Marquette Township coastal areas
          have large open spaces.      The area along the South Shore, between the Sand
          Products dock and the Dow disposal lagoons, is generally undeveloped.            This
          area is characterized by steep slopes and a wetlands shoreline.        Most of this
          area is owned by Dow and is zoned Harbor Industrial. It could be developed for
          multi-family (condominium), residential use if utilities are available to
          support it.

          The existing residential areas on the Buttersville Bar will continue to infill
          with the development of now vacant.lots. Due to the pattern of development and
          the fragmentation of ownership, no significant amount of multi-family develop-
          ment is anticipated.

          B.   COMMERCIAL

          Commercial as used in this section refers to Commercial Recreational.          Neigh-
          borhood Commercial and General Commercial is not considered in this section.
          Commercial Recreational includes all uses which are related to water uses or
          tourism.   Examples of this include motels/hotels, marinas, charter fishing
          service, restaurants, etc.

          Within Ludington, there are a number of established commercial recreational
          areas.   One is along West Ludington Avenue near the beach.         As the new City
          Marina grows in popularity, the pressures on this area to grow in size will
          increase.   The City has recently completed a plan for the area around the new
          marina.   It calls for a mix of commercial and residential and a variety of
          streetscape improvements.    Currently, the new municipal marina is at capacity
          and there is a demonstrated need for additional marina berths.           The current
          trends of increasing tourism in the area will further add to this need.

                                                  111-2
<pb n="86" />

           The small channel , over which South Washington Avenue passes, supports several
           marinas and charter fishing services.      At present, there is little room for
           expansion.   However, there are a number of abandoned or under-utilized indus-
           trial structures in this area that could be recycled for commercial recreation-
           al use. A need for a large boat lift and boat repair facility has been identi-
           fied.

           The Pere Marquette Township coastal area has no existing commercial recreation-
           al land uses. Some marina facilities could be developed on either side of the
           Sand Products facility.

           C.   PUBLIC FACILITIES

           The City of Ludington has several waterfront facilities, including the Lake
           Michigan beach/boat ramp, the new marina, the City dock, and the City Park
           (south of Western Concrete). Each of these facilities provides some waterfront
           contact.   However, an integraied Pere Marquette waterfront park system is
           lacking.   A promenade along the waterfront by the City Marina would be an
           attractive spot to watch boating and shipping activitioes.

           There is also an opportunity to expand the City Park (between Dow and Western
           Concrete) into the Western Concrete area.      This would about double its land
           area and would permit    it to be developed into a major park facility, thus
           providing the impetus for neighborhood redevelopment and giving some relief to
           Stearns Park. Such a facility could include boat rentals (private concession),
           food service (private concession), picnic areas, concerts, art/antique shows,
           and transient boat moorings.

           Pere Marquette Township has a park with Lake Michigan frontage. This facility
           probably serves the Township's current needs.      If, however, there is signifi-
           cant residential development along the Pere Marquette Lake waterfront, then
           some land should be reserved for park usage.

           The wetland areas would make an excellent nature study area. A park, developed
           with boardwalks through the wetlands and offering guided natur; tours, could be
           a regional attraction.    Currently, Pere Marquette Township is endeavoring to
           develop this type of park in the wetlands.

                                                  TTT-3
<pb n="87" />

         D. . CONCLUSIONS

         Opportunities for all types of land use exist around the Pere Marquette Lake.
         Often, several opportunities exist for a single piece of property.         Further-
         more, certain key properties can greatly influence a neighborhood's character
         or reinforce existing land use patterns.

         The opportunities discussed in this chapter must be integrated into an overall
         plan and balanced with industrial/port development.

                                                111-4
<pb n="88" />

                                 Chapter IV
                        Economic Analysis
<pb n="89" />

                                            CHAPTER IV
                                         ECONOMIC ANALYSIS

          INTRODUCTION,

          The purpose of this chapter is to analyze and interpret economic base data and
          influences. This chapter covers a commodity flow analysis, based upon both the
          existing, published sources and the commodity survey prepared as part of this
          project. This chapter also includes an economic analysis of the harbor of the
          City of Ludington and the Ludington area.    As a basis for determining future
          opportunities and limitations, an analysis of general national economic trends
          for specific commodity groups is provided.

          A.   GENERAL ECONOMIC ANALYSIS

          1.   Economic Base

          a.   The Harbor

               The basic economic purpose of the Ludington Harbor is twofold - commercial
               recreation and commercial shipping.  As a commercial recreation facility,
               it supports various marinas, boat yards, and charter fishing services. It
               also provides an attraction for fishermen and sightseers who, in turn,
               purchase goods and services in the Ludington area.     Although it is not
               possible to quantify the contribution of Pere Marquette Lake to the local
               economy, it is an important element to the local and regional economy.

               Commercial shipping usage of the harbor makes possible such facilities as
               the Dow plant, Harbison-Walker, and the C&amp;O car ferry.       It reinforces
               operations such as Mohawk Products, Western Concrete, Laman Asphalt, and
               Sand Products. In the past, it supported a commercial fishing industry.

               The harbor has the fiscal and economic potential to support other similar
               industrial/transportation uses/facilities.

                                               IV-1
<pb n="90" />

           b.    Ludington

                 The City  of Ludington grew from the lumber industry of the last century.
                 As this industry declined, the city diversified its industrial base. The
                 city has,a variety of industries, the largest of which is the Dow Chemical
                 plant which-was located here in the 1940's.       The Dow facility has had a
                 strong positive economic influence on the community.        It is responsible
                 for the attraction of the Harbison-Walker plant, which converts a Dow
                 by-product into a saleable commodity.

                 At present, the city is home to a wide variety of small and medium indus-
                 tries.   This tndustrial base has cushioned Ludington from some of the
                 recent economic declines,,- however, some national trends are starting to
                 take their toll on Ludington   industries.

                 Ludington, as the county seat, supports a variety of service firms.
                 Ludington is also the wholesale/retail center for the area.

           C.    The Area

                 Ludington is the industrial and employment center for Mason County and the
                 region.  Nevertheless, Mason County and the region support several impor-
                 tant industries - tourism, agriculture, and natural resource extraction.

                 The second home market and tourism market has enjoyed marked success          in
                 Mason County and the region.     Many smaller farms have been converted       to
                 vacation developments.

                 Land in agriculture has been declining, and presently about one third of
                 Mason County is devoted to agriculture. Total agricultural production has
                 been increasing. This has maintained agriculture as an important. economic
                 element in Mason County and the region.

                 Mason County ranks seventh in natural resource extraction within the State
                 of Michigan.   It ranks second in natural saline production and fourth in
                 industrial casting sand production.

                                                   IV-2
<pb n="91" />

          2.   Local Economic Growth Estimates

          Local overall economic development estimates are not available.           However,
          growth is anticipated in several economic sectors. Even with a negative popu-
          lation growth rate, Ludington can contribute to the area's economic growth.

            o  Ludington has a finite and limited supply of residential land. Thus, its
               population will stabilize based on available residential area.
            o  Ludington's population will fluctuate in relation to the average number of
               people in a household.
            o  Ludington's population will also vary as the density of housing in resi-
               dential areas changes.
            o  As Ludington's industrial and commercial base (both water related and
               non-water related) expands, resident.ial areas may be lost and their popu-
               lation displaced to elsewhere in the county.

          Economic growth in Mason County and Ludington can be broken into several groups
          for purposes of analysis.

          Agriculture.   Agricultural production in Mason County is increasing and is
          forecast to continue.    Since the   amount of farm land has been decreasing,
          increased agricultural production can be attributed to improved farming prac-
          tices, better farming methods, increased mechanization, improved seed stock,
          and improved/increased use of fertilizers/pesticides.

          Manufacturing.   The forecast for local manufacturing is poor.       Manufacturing
          has been decreasing in Mason County. Small and medium sized industries do not
          depend upon harbor availability, but may depend on rail service.      Forecastable
          growth/decline is more directly related to these industries than to large basic
          manufacturing facilities which need waterborne commerce.       The attraction of
          these basic manufacturers must  be considered on an individual basis.    They are
          not statistically forecastable in an economic unit the size of Ludington.

          Recreation/Tourism.   Recreation and tourism in Ludington and Mason County has
          been increasing and is forecast to continue. , The continued development and
          improvement of recreation and tourism facilities will contribute to this
          increase. Likewise, the extension of the tourism season into the winter months
          will contribute to the increase.

                                                 IV-3
<pb n="92" />

           Construction.   The construction industry in Ludington and Mason County is
           driven by general economic expansion and the second home market.       Currently
           these economic segments are depressed; however, a significant amount of deman;
           is building up. The long range prospect for the construction industry is good.

           Natural Resource Extraction.   Several types of natural.resources are extracted
           from Mason County and the area.     These include:   oil and gas, foundry sand,
           construction sand and gravel, and brine.    Oil and gas exploration and produc-
           tion will*vary according to local supply, national demand, and international
           economics.  Foundry sand from the Ludington area is in competition with other
           sand mining areas along the western shore of Lake Michigan.        It is directly
           related to Michigan dune mining laws and the automotive industry's need for
           foundry sand.  The foreign manufacture of "domestic" automobile engine blocks
           could reduce the demand for'local foundry sand production.      Construction sand
           is available locally to meet local demand. Construction aggregates and gravel
           are usually imported into the Ludington area.

           3.   Influences on the Local Economy

           a.   State and National

                Ludington, and especially the car ferry traffic,,is economically dependent
                on the national and state economy. The state economy is in turn dependent
                on the' national economy and particularly the auto industry, although
                Ludington is less directly tied to the the auto industry than other areas
                of the state. The national economy, as related to Ludington, is discussed
                in depth in Part B of this chapter.

           b.   Capital Supply

                Capital is necessary for industrial development, redevelopment, or expan-
                sion. It must be available at reasonable rates for local economic growth.
                Although Ludington cannot control the national capital supply or cost, it
                can, through municipal loans and bonds, make capital available to indus-
                try.

                                                 Tit A
<pb n="93" />

         Cl.   Labor Supply

               Industry needs a source of labor to staff its facilities. Ludington, how-
               ever, can only indirectly influence the labor supply. In the recent past,
               Ludington has had a well-balanced labor supply of blue collar, white col-
               lar, farm, and service industry workers. Recent poor economic conditions,
               with closing factories and rising 'unemployment, may cause a surplus of
               certain types of workers and cause others with needed skills to leave the

               area.

         d.    Land and Infrastructure

               Industry cannot grow without land and supporting infrastructure.       Recent
               state statutes now permit cities to condemn and assemble land for indus-
               trial and commercial development. The ability to assemble large tracts of
               land adjoining existing industrial facilities is an important economic
               development tool. Lik@wise, industrial expansion is dependent on support-
               ing infrastructure such as roads, utilities, waste disposal facilities,.
               etc. These are services typically provided by the public sector.

         4.    Physical -Implications

         a.    Land Available

               The industrial areas of Ludington's waterfron    -t are crowded.    Expansion
               area is needed.   Some industrial areas are in conflict with residential

               and commercial land uses.

            A  Non-industrial land uses  along the north shore of Pere Marquette Lake are
               mixed and unconsolidated. In several areas, commercial, residential, and
               industrial land uses run together.    Additional recreation and commercial
               facilities such as a major waterfront park, a large boat hoist, etc. are
               needed to enhance and reinforce the recreation/tourist industry.

                                                T V-9;
<pb n="94" />

          b.   Util i ties

               Adequate natural gas, water, and sewer are available on the north side of
               Pere Marquette Lake. Natural gas, water, and sewer are generally unavail-
               able on the south side of Pere Marquette Lake.    Electricity and telephone
               are available to all areas.

          C.   Transportation

               The Ludington downtown waterfront area needs a good over-the-road trans-
               portation link. It may be possible to develop a truck route along part of
               the railroad right-of-way.   The completion of the US-31 four-lane through
               to Ludington is also necessary to provide good truck access to the down-
               state areas.

               Waterborne transportation in Ludington enjoys a year-round cross lake
               shipping season, a good natural turning basin, good wave protection, and
               an adequate anchorage area. The harbor entrance is maintained at the full
               St. Lawrence Seaway depth and provides access to a natural deep harbor.
               If the Seaway were ever to be deepened, then only the Ludington entrance
               channel would need dredging.   Pere Marquette Lake in most cases would be
               of sufficient depth, although some dredging would be necessary at individ-
               ual berths.

               Several uses are available for the Western Concrete Products site.       The
               site is well situated for receiving dry bulk and liquid bulk materials.
               In contrast, the Mohawk Transportation Terminal is too small for a major
               dry bulk operation. However, with some site development, it could be used
               as a liquid bulk facility by self-unloading barges.

               The structural condition of the C&amp;O Railroad Slips   No. 1-and 3 make them
               unusable at this time. At present, the C&amp;O has one slip in usable condi-
               tion, plus the general purpose barge dock. Dock No. 2-1/2 presently has a
               vessel in layup and could be used as a ship's berth.

                                                T 11-r
<pb n="95" />

               The Sand Products Terminal appears adequate for present use.      L i kewi se,
               Dow Chemical indicates that their terminal facilities are adequate for
               present and anticipated future use.

               So long as the cross-lake car ferry continues, Ludington will be served by
               excellent rail service.  Along the north side of the lake, there are rail
               sidings to several sites.  The car ferry and Michigan's network of rail-
               roads gives Ludington excellent access to points east and west.

         d.    Ownership

               The major landowners around Pere Marquette Lake are the C&amp;6''Railroad and
               Dow Chemical. Dow Chemical owns most of the land from its facility south
               and east and along the south side of the lake up to and including the Sand
               Products facility.  The C&amp;O Railroad owns a large tract of land in close
               proximity to downtown Ludington.

               Other areas show a fractured and fragmented ownership pattern. Ownership
               on the Buttersville Bar is predominantly individual single family. Owner-
               ship along parts of the north side of Pere Marquette Lake is fragmented
               according to its use.

         e.    Natural Limitations

               As noted, Ludington enjoys a year-round navigation season. The ice prob-
               lems in Pere Marquette Lake and the harbor channel are minimal if ice
               buildup is kept under control.   The ability to use the Port of Ludington
               year-round is an asset which should not be understated.

               Along the north shore of Pere Marquette Lake, there are few large flat
               areas which are available for development or redevelopment.    Among these
               few are the C&amp;O Railroad site, the industrial area in the vicinity of the
               Mohawk Transportation terminal, and the Western Concrete Products site.

               The eastern end of the lake is characterized by shallow wa   ter depths and
               wetlands. This limits the development potential of this part of the lake.

                                               IV-7
<pb n="96" />

                 The topography along the south shore of Pere Marquette Lake is very
                 rugged.  The steep slopes and undulating terrain do not make this area
                 suitable for intensive industrial development.           However, residential
                 development would be possible in this area if utilities were available.

                 Except for the wetland areas, soils generally do-not constrain development
                 around Pere Marquette Lake. Likewise, geology does not constrain develop-
                 ment around Pere Marquette Lake.

           5.    Cross-Lake Ferry - Implications of Discontinuance

           The C&amp;O Railway has filed for abandonment of the Ludington to Kewaunee route.
           The Ludington to Manitowoc route has already been abandoned.

           Cross-lake  ferry service has been cut back from its peak of six round trips per
           day to the present one trip per day. The decline in ferry service was followed
           by a decline in cross-lake carloads carried.        This decline continued through
           1978 but was reversed for the year 1979.

           Kearny Management Associates, in their final report of June 1980, noted several
           reasons for the decline in car ferry traffic:

             o Rate structures, especially flag-outs on certain commodities
             o Car supply problems
             o Marketing efforts

           Nevertheless, all but   one of the scenarios prepared by Kearny forecast a 1985
           increase in cross-lake   traffic.

           Since the car ferry accounts for an estimated 90%+ of the Ludington port traf-
           fic, its discontinuance would drop Ludington's importance as a Michigan port.
           Ludington yould have a special purpose port status, serving several specific

           users.

           Discontinuance of the ferry would have a variety of negative effects on the
           Ludington area.    Among  these are: a) the loss of a major employer; b) the

                                                   IV-8
<pb n="97" />

         potential loss of rail service to Ludington; c) the potential loss of federal
         harbor improvements or priority status (thus delaying improvements); d) the
         loss of ferry passengers as area tourists; e) the potential loss of year-round
         navigation. These are serious adverse effects, especially when weighed against
         the cross-lake traffic potential for rail service and motor trucks.

         The full scope of direct and indirect effects of discontinued ferry service is
         beyond the scope of this analysis. However, it is evident that discontinuance
         of ferry service would have a major adverse effect on the local economy.

         B.   NATIONAL ECONOMIC TRENDS

         1.    Pulp,_Paper, and Converted Paper Products

         This sector of the economy is strongly tied to the lumber industry through,the
         construction industry.    If interest rates slow down the construction industry,
         this section will also be hurt.

         This industry is historicaily a solid performer.     It is capital -intensive and
         generally modern.   The United States paper industry is cost-competitive world-
         wide; however, the U.S. imports newsprint and pulp from Canada.

         The paper industry is a major water user. Pollution abatement and waste treat-
         ment regulations are considered an industry problem.

         Long-range growth is predicted to increase at 2.9% per year.          Imports are
         expected to decline by about 4% due to increased plant capacity.       Exports to
         Canada, Japan, and many western European countries will decline due to reces-
         sionary trends in these countries.     Little growth in plant capacity is anti-
         cipated before 1985; therefore, operations are anticipated to continue at close
         to 100% of capacity.

         2.    Energy

         In general, energy usage is related to general economic activity.        Utilities
         have been tending to convert from oil to gas to coal.

                                                IV-9
<pb n="98" />

           There seems to be some future in the production of gasohol based on coal-fired
           fermentation process.    Biomass inputs for this process include:        grains and
           starches, food processing by-products, wood chips, solid waste, and other
           sources of cellulose.

           3.    Cemenj

           Canada is the major supplier of cement to the United States. Continued growth
           is expected, but this depends upon the construction industry.       Local shortages
           may exist through 1985 in certain geographical areas.

           4.    Lumber

           Exports to Japan and Europe are expected to continue at a high level. Canada
           the United  States' second largest market for export, is anticipated to increase
           by 10% through 1985.

           5.   Agricultural Chemicals

           In general, agricultural chemicals      fall into two' groups      fertilizers and
           pesticides.   Fertilizers are based upon a mixture of nitrogen, phosphates, and
           potash.   Nitrogen, in particular, must be renewed     yearly.   Research is pres-
           ently underway to find a cost-effective vehicle to hold nitrogen in the soil.
           Likewise, new technology is being developed      to extract potash from low-grade

           ore.

           Nitrogen is forecast to rise in production'by 3% per year and in consumption by
           4% per year through 1985. World consumption is forecast to increase by 6% per
           year through 1985. Plant capacity probably will not expand due to the present
           cost of natural gas and the pricing structure of ammonia.        In 1980, the U.S.
           imported ammonia (as nitrogen) in excess of 700,000 tons.       Major exporters of
           ammonia are Mexico, Canada, and Trinidad-Tobago.        Phosphates production con-
           siderably exceeded domestic consumption in 1980 due to strong export demand.
           This situation is forecast to continue through 1985.

                                                  IV-10
<pb n="99" />

          The United'States imports over 70% of its potash from Canada. Canadian produc-
          tion capacity increases, now in progress, will ease the current tight supply.
          United States consumption is forecast to increase 2% per year through 1985.
          World consumption is forecast to increase 5% per year through 1985.

          No single or small number of companies account for a major share of pesticide
          production.   Likewise, production is not limited to one or more definable
          geographic areas.

          The industry is mature and little growth is expected; however, due to high
          domestic consumption and expanding exports, production should remain high
          through 1985.

          Individual pesticide consumption has generally been decreasing due to environ-
          mental regulations and integrated pest management programs.

          6.   Mining

          Long-term domestic production is uncertain, and    imports are increasing due to
          the lack of United States production facilities. Nevertheless, the short-term
          picture is good.   The U.S. is a net exporter of non-metallic minerals and has
          just recently become a net exporter of metal ores and concentrates.

          In recent past years, about 25% of available capital has been put into making
          existing f@cilities comply with environmental regulations. There is now a need
          for production modernization which is being frustrated by the lack of capital.
          Several "cash rich" oil companies have taken advantage of this situation and
          become involved in mining operations. They have the cash to make the necessary
          capital improvements.

          Much of the once readily available federal lands are now closed to mining.
          Currently 42% of the federal lands are closed to mining, 16% are severely
          restricted, and 10% are moderately restricted.       Thus, mining operations on
          private lands are expected to increase.

                                                 IV-11
<pb n="100" />

           7.   Primary Metals

           Demand for raw materials (mineral and non-metallics) is expected to increase
           about 2.7%   per year through 1985.      The primary steel industry is directly
           related to the general economy, especially durable goods such as the auto
           industry and the construction industry.      Slow growth of about 1% per year is
           anticipateJ through 1985. Copper is a volatile and unpredictable primary metal
           economic component. It is, in part, related to the general economy and federal
           regulatory actions.     It is also related to market speculation and precious
           metal fluctuations.    Consumption is expected to increase about 3% per year
           through 1985.    Changes in the auto industry (especially electric cars) and
           solar energy systems could increase this growth rate significantly.

                      0
           AMAX Exploration Inc. has recently identified a major new deposit of copper-
           nickel,   This deposit, known as the Duluth Gabbro Copper-Nickel Deposit, is
           thought to contain 9.9 million tons of recoverable nickel.

           At present, Canada is the world's largest single nickel producer.              Canada
           provided 44% of the U.S. imports in 1980.

           Nickel consumption is-projected to rise at about 2.9% per year through 1985.
           The development of an effective battery (e.g. zinc nickel) for the electric
           auto could substantially increase nickel consumption.

           8.   Shipbuilding and Repair

           In general, there is a surplus of world shipbuilding capacity.          Shipbuilding
           orders are badly needed by shipyards to avoid layoffs and dispersal of skilled
           work force.    The Reagan Administration's military expenditures will provide
           some relief.

           Additions to the dry   bulk fleet are a prime source of future commercial ship
           orders. The U.S. Flag Fleet has only 15 dry-bulk vessels. The Maritime Admin-
           istration estimates that a 10% market share could be achieved by the year .2000
           if existing operating restrictions are dropped.         A 10% market share could
           sustain a 172-ship fleet of various size dry-bulk vessels.

                                                   IV-12
<pb n="101" />

         The market'for off-shore drilling rigs is booming along the Caribbean, Pacific
         and Atlantic coasts.    If oil and gas exploration is permitted in the Great
         Lakes, a significant market could open up.

         The forecast for shipbuilding of inland vessels is strong.     A 24% growth rate
         through 1990 is projected for inland vessels and barges.

         9.   Freight Movement

         The future of railroad freight traffic, especially unit trains, is solid.
         Class I railroad freight traffic is projected to increase 2.5% through 1985.

         Truck traffic is expected to increase about. 3% per year through 1985.

         Renewed econ,$Inic growth and increased coal production are expected to increase
         inland waterway traffic about 3% per year through 1985.

         Economic growth and rising petroleum consumption are expected to result in
         increased pipeline movement of crude oil and products through 1985.     A growth
         rate of 3% per year is expected.    The cost-effectiveness of coal slurry pipe-
         lines is now approaching competitiveness with unit trains and bulk movements.

         C.   SHIPPERS SURVEY

         1.   Ludington Commodity Flow Survey

         Although the Ludington Commodity Flow Survey was distributed to a variety of
         existing and potential port users (272), a very poor rate of return (11%) has
         been achieved. , Even though the rate of return is too low for use in making
         projections, the survey results provide some interesting and useful pieces of
         information:

           o The main reason for using Ludington is the total transportation cost;
              however, there are a wide variety of secondary reasons.

           o  Imports listed were road salt, wood pulp, newsprint, limestone, and compo-
              nents.

                                               TV-13
<pb n="102" />

             o Exports listed were iron ore pellets, dead burned magnesite, sand, buck-
                wheat, peas, birdseed, appliances, and frozen fruit.

             o  Import origins in the U.S. Midwest and Canada/Mexico were given.

             o  Export destinations in the U.S. East, Europe/USSR, and South America were
                given.

           Tabu] ations of the surveys  returned are included in Appendix A.

           2.   Additional Commodity Flow Information Sources

           In addition to the original survey prepared for the Port of Ludington, other
           sources of commodity flow information exist.        The U.S. Coast Guard has been
           conducting a survey of the origin and destination of ships calling at
           Ludington. Unfortunately, the Coast Guard information is too gen%ral, particu-
           larly with respect to commodities carried, for port planning.

           The U.S. Maritime Administration, Office of Domestic Assistance, can use U.S.
           Army Corps of Engineers data for an origin/destination computer run.              This
           would be the best information source, since it reflects actual harbor usage
           over a number of years.     If the computer run is not available, then Corps of
           Engineer s Commodity Flow maps and harbor information can be judgmentally
           assessed.

           D.   OPPORTUNITIES AND LIMITATIONS

           A variety of opportunities and limitations appear to exist for the Port of
           Ludington. It is difficult to quantify their magnitude at this time. Opportu-
           nities and limitations for the Port of Ludington are discussed on the basis of
           their local, regional, and inter-regional service areas.

           1.   Local

           Local port development opportunities are centered around the waterborne trans-
           portation needs of major facilities, including power plants, major manufactur-
           ing facilities, or fabricators of large/heavy components.        Each of these uses

                                                   IV-14
<pb n="103" />

          would require industrial development encouragements to locate in Ludington.
          These facilities also have large land requirements. Sufficient land would have
          to be made available through condemnation or conventional assemblage programs.

          A second alternative is to attract an industry which only needs a small water-
          front terminal for a manufacturing/processing facility-which is located off the
          waterfront.   In order to avoid unnecessary drayage fees, this opportunity is
          limited to industries moving liquid products through pipelines.

          A third alternative is to attract a sufficient nu(nber of medium sized indus-
          tries, with occasional waterborne transportation needs. These industries could
          contract for, or lease, facilities at a general purpose public terminal.

          2.   Regional

          The best opportunities for port facilities which service regional needs is in
          the delivery of dry bulk construction aggregates and liquid bulk petroleum
          products (gasoline, heating oil, diesel fuel), and liquid bulk agricultural
          chemicals Ifertilizers and pesticides). As with any'bulk operation, the envi-
          ronmental impacts of operation would have to be carefully controlled.

          A limited potential for imports and exports of other construction materials
          (especially lumber) and durable goods exist.       This potential should be con-
          sidered as supplemental to other similar port uses.

          3.   Inter-Regional

          As the Kearny study indicates, there      is a good potential for consolidated
          cross-lake railroad car ferry traffic. It would also seem that there is a good
          potential for cross-lake motor truck or container traffic.

          With a competitive rate structure, it could be-possible to offer Ludington as
          an alternate route for Western coal or pulp and basic paper products.          Like-
          wise, it may be possible to offer an Escanaba-Ludington route for winter ship-
          ping pf iron ore from the Upper Peninsula area.

                                                 IV-15
<pb n="104" />

                              Chapter V
                Feasibility Determination
<pb n="105" />

                                              CHAPTER V

                                       FEASIBILITY DETERMINATION

          INTRODUCTION

          The information and analyses which are necessary to determine the feasibility
          of port expansion are evaluated in this chapter.          Commodity flow data and
          conclusions presented previously in combination with these additional analyses
          provide the basis for determining the level of port expansion which may realis-
          tically be accommodated in Ludington.

          SCOPE

          The scope of this analysis encompasses an investigation of potential develop-
          ment related to commodity flows on the local, regional and inter-regional
          levels. This is accomplished by taking a close look at several selected devel-
          opment scenarios. The selections made were based on the economic analysis and
          input from the Harbor Commission and are not intended to be exclusive of other
          real or potential development opportunities.       These scenarios were chosen as
          representative of typical industries with a good future outlook, or those
          showing future technological developments.

          KEY ISSUES

          The key issues of this investigation can be associated with the local, regional
          and inter-regional levels of commodity flow patterns.         On the local level ,
          various types of industrial/manufacturing facilities which could be constructed
          and operated in Ludington were compared with similar developments in other
          cities.   A regional terminal operation involving shipping and warehousing was
          investigated in terms of both feasibility to develop and feasibility to oper-
          ate.  On the inter-regional level, the cost of shipping railroad, motor truck,
          and containerized freight through Ludington is compared to the cost of shipping
          on competitive alternate routes.

                                                   V-1
<pb n="106" />

          A.   PERSPECTIVE ON FEASIBILITY

          1.   Industrial Location Theory

          Industrial location theory has  been employed for the purposes of this study to
          provide an organized framework  for the investigation of potential development
          in the Ludington area.    A primary feature of this theory is the pattern of
          product distribution to the market area. Secondly, the relationship to region-
          al elements, such as the transportation of raw materials and provision of a
          power source, is important.      Thirdly, inter-regional elements affect the
          locational outlook in a more comprehensive sense.

          Natural elements of a particular region, such as the location and availability
          of raw materials and energy, land surface characteristics, and climate have a
          definite bearing on its attractiveness to potential industry.     Cultural fea-
          tures are somewhat flexible, will influence, and are themselves affected by the
          location of a new industrial facility.      Among the cultural elements to be
          considered are the labor supply, markets, transportation facilities, subsidies
          and government regulations.

          In order to qualitatively evaluate the many important factors involved in this
          study of industrial location, they are expressed in terms of costs.   The study
          of these costs is most important, since manufacturing ceases to operate or
          fails to establish in a region when costs become too high. These cost differ-
          entials are examined in one of two ways, depending on which is most appro-
          priate:

          1.   Comparison of development and production costs between competitive loca-
               tions; or

          2.   Evaluation of the feasibility to develop and operate a facility in terms
               of profitability.

          Information on the detailed approach taken to evaluate the various development
          scenarios is contained in the methodology discussion.

                                                V-2
<pb n="107" />

          2.   Traffic Management - Shipping Operations

          a.   Functions of Traffic Management

               Traffic management encompasses all phases in the control of goods in
               transit. It involves the arrangement    for carriers to move goods, arrange-
               ment for temporary storage or warehousing if necessary, the preparation of
               goods for shipment, and the receipt of incoming shipments.       Traffic man-
               agement also involves establishing the rates and charges for the above
               services.

               Traffic management serves an important role in plant location decisions,
               whether they be regarding new plant facilities, warehousing facilities, or
               development of a new product line at existing facilities. Transportation
               management and costs are inseperable from industrial location theory. The
               analyses of transportation routes and facilities themselves, under varying
               commodity flow patterns, are a vital step in the industrial location
               analysis.

          b.   Major Shipping Operati.ons

               The,water borne shipping business is highly competitive and its operations
               are complex .  The principles of industrial sales management apply to the
               promotional work of the shipper's services.      Booking space on a car    rier
               involves ascertaining when that space will be available within the desired
               time limits, and obtaining the necessary freight contract and shipping
               permits. Other paperwork must be coordinated, which is generally referred
               to as shipper's papers.    It includes the bills of lading, freight bills,
               dock receipts, and delivery receipts.

               The operation and management of terminal facilities is another facet of
               the shipping business, although the terminal may be' operated by other
               public or private concerns. Stevedoring is an essential auxiliary opera-
               tion which has to do with the actual handling of cargo between the termi-
               nal and the hold of the ship.       The physical operation of the carrier
               itself involves purchasing fuel and ship stores, arranging for maintenance
               and repairs, scheduling, purchasing insurance, and staffing the ship,
               among many other things.

                                                  V-3
<pb n="108" />

           B.   METHODOLOGY

           1.   Criteria for Defining Case Parameters

           In order to approach the question of economic feasibility from a least cost or
           profitability viewpoint, the criteria for defining variables was chosen to
           simplify the complex study of industrial location and transportation costs.
           These criteria are also helpful in understanding the relationships between
           transportation cost and locational factors, marketing area breadth, and region-
           al or community development trends.

           a.   Local Plant Development

                Plant development  costs are expressed in terms of a cost per unit of
                finished product.  This cost is the sum of production costs, transporta-
                tion costs for raw materials from their sources, and transportation costs
                for finished goods to their various markets.   Raw materials were assumed
                available from the closest sources. Market areas were established based
                on characteristics of each particular industry.      Production costs are
                often based on economies of scale; thus, the size of a particular facility
                plays an important role.   An effort was made to obtain production costs
                based on modern, typically sized facilities that are appropriate for the
                particular market they serve.

           b.   Regional Shipping Terminal Development

                The cost of developing and operating a regional shipping terminal is the
                sum -of shipping costs to and from the terminal and operating costs,
                including storage or warehousing costs.      For the various commodities
                investigated, warehousing, handling and shipping costs were developed
                appropriate to the commodity. Where a trade-off between holding costs and
                transportation costs exists, an attempt was made to reach an optimum
                balance which reduces total distribution costs.    For example, when sub-
                stantial costs are involved in holding inventories, it is possible to
                substitute a higher-priced, but faster means, of transportation.

                                                 V-4
<pb n="109" />

         C.    Inter-Regional Shipping Operations

               In the development of inter-regional shipping costs, the total shipping,
               transfer, and terminal charges were compared for a commodity traveling on
               various routes.  Railroad routes were identified between urban centers
               which follow natural traffic patterns and minimize switching and transfer
               operations. Motor truck routes were based on the shortest and most direct

               route.

         2.    Data Sources

         A complete listing of references and sources of data for the feasibility deter-
         mination are contained in Appendix B.    Published references on transportation
         and location theory were largely utilized to establish the equations, define
         the variables involved, and make the necessary simplifying assumptions. Trans-
         portation and material cost quotes were obtained from various sources, as
         necessary, to supplement and update published cost data.

         3.    Judgments

         Many simplifying assumptions were made in order to provide an understandable
         and workable system for analyzing the cost data. Explanation of the principal
         assumptions made for each case studied are explained in the section containing
         the results.

         4.    Equations

         a.    Local Plant Development

               The equation used in the cost comparison for local plant development is as
               follows:

               Is (total cost) for Ludington less than (total cost) for other locations?

               Where total cost is defined as:

                                                V-5
<pb n="110" />

                Total cost    = T raw + T fin + MFG
                      T raw   = Total cost of transporting raw materials to the plant site
                                by appropriate means
                      T fin   = Total cost of transporting products to the market area by
                                appropriate means
                      MFG     = Total cost of manufacturing, including facility construc-
                                tion costs, labor costs, energy costs, taxes, etc.

           b.   Regional Terminal

                The equation used for determining the feasibility to operate a regional
                shipping terminal is:

                Are (total terminal and shipping costs) for Ludington less than
                (total terminal and shipping costs) for other locations?

                Where total terminal and shipping costs include:
                (total terminal and shipping costs) = Sd       + T fee + S dest

                Where:

                      Sd      = Total shipping costs to deliver commodity to the terminal
                      T fee   = Total terminal fees, including transfers and surcharges
                      S dest  = Total shipping costs to deliver commodity to its destination

                The equation  used to assess the feasibility to develop a regional shipping
                terminal is:

                      (cost to develop the terminal) + (terminal operating expenses)
                      is compared to (volume) x (revenue rate)

                Where the cost to develop and operate the terminal is compared to the
                revenues collected.

                Where:

                    Cost to develop          Construction cost (including engineering)
                                             Financing + Land cost + Equipment cost
                      Operating Expense      Fixed costs (utilities, taxes, administrative
                                             overhead, etc.)
                                           + Variable costs (labor, energy, etc.)
                                           + Non-productive'burden
                      Volume               = The anticipated amount of tonnage that will be
                                             handled
                      Rate                 = The charges for using various services of the
                                             terminal (i.e., docking fees, storage fees,
                                             transfer fees, etc.)

                                                   V-6
<pb n="111" />

          C.   Inter-Regional Shipping

               The equation used to evaluate inter-regional shipping operations compares
               shipping costs through Ludington to shipping costs through other routes,
               as follows:

               Are (total shipping costs) through Ludington less than (total shipping
               costs) via other routes?

               Where total shipping costs include:

                    Overland transportation costs to Ludington (or other)
                    Cost to transfer onto vessel
                    Vessel transportation charges cross-lake
                    Cost to transfer off vessel
                    Overland transportation costs to destination
                    Commodity penalties (if any)
                    Empty carrier return charges

          5.   Cases Investigated

          The following industrial/manufacturing facilities were investigated regarding
          feasibility of development in the Ludington area:'

                    Cement manufacturing
                    Pulp/paper production
                    Agricultural chemical processing

          A limited investigation was made in three additional areas:

                    Steel fabrication
                    Ship building and repair
                    Power generation with wood fuels

          The other locations which were used for comparison vary by industry and are
          given in the section on results.

                                                 V-7
<pb n="112" />

           The feasibility to develop and operate a regional shipping terminal was evalu-
           ated for the following commodity groups:

                      General cargo
                      Dry bulk material (such as sand, gravel, cement, etc.)
                      Liquid bulk material (petroleum products, chemicals,
                        fertilizers, etc.)

           Operational costs were compared for the following routes:

                      Cross-lake through Muskegon
                      Overla-nd through Chicago
                      Cross-lake through Chicago
                      Through Mackinaw Straits

           Inter-regional traffic was also evaluated for the commodity groups and routes
           listed above.     The analyses were performed for rail freight, motor truck
           freight, containerized/piggy back cargo, and for passenger travel.

           C.   RESULTS

           1.   Local Plant Development

           a.   Cement Manufacturing

                The cement manufacturing industry is characterized by a fairly widespread
                distribution of raw materials, comparatively low finished product costs,
                and great bulk materials with consequently high transportation costs
                involved.    Since considerable fuel is used in production and bulky raw
                materials are involved, cement can be produced profitably only on a large
                scale.

                Cement manufacturing involves mixing and crushing the raw materials,
                limestone, clay and gypsum, and firing them in kilns to a temperature of
                about 15000C.    The material from the kilns, called       clinker, is crushed
                into a fine powder to which a variety of additives may be combined to
                produce the cement.

                                                    V-8
<pb n="113" />

               The ideal location for a cement plant is nearby the raw materials and fuel
               sources, and fairly centralized with respect to markets. The availability
               of labor is rarely important in the location of new cement plants, since
               the industry is highly mechanized. However, labor is an important factor
               in the cost of production and will influence the choice of location in
               this manner.

               Major U.S. market areas where water borne transportation of cement have
               developed are along the East Coast, the lower Great Lakes, and the
               Mississippi River.  Where there is a large concentrated market which can
               be reached by water routes, substantial economies of scale can be achieved
               in shipping costs.  This shipping method requires the use of huge barges,
               docks, and automatic loading and unloading facilities in order to be
               economical.

               The results of the feasibility analysis for the development of a cement
               manufacturing plant are presented in Table 13.     Since the proximity to
               market areas and transportation costs play a vital role in the location,
               the equation for cost comparison was modified to compare the breadth of
               market area which could feasibly be reached. This modified equation is as
               follows:

                    Market cement price = Total production costs + profit

                    Where the total production costs are:
                         Total costs = T raw + T fin + MFG, as defined previously.

               The average market price of bulk cement, from Engineering News Record's
               monthly market quotations for January 1982, is $57.23/ton or $2.86/cwt.
               For the purposes of comparison, a uniform profit of 10% has been assumed.
               This assumption allows estimation of the feasible market radius by various
               modes of transportation, presented in.Table 13.

               As seen in Table 13, Ludington does compare favorably to other locations
               for the production of cement. In addition to the markets reached directly
               by rail and truck, market areas across the lake and in Chicago could feas-
               ibly be reached by barge.

                                                V-9
<pb n="114" />

                                                                  TABLE 13

                                                        COMPARISON OF MARKET AREAS

                                                                    FOR

                                                 CEMENT MANUFACTURING IN SELECTED CITIES

                                                                                Available Trans-
                                                           Raw Material          portation for
                                                          Transportation        Finished Cement
                                     Manufacturing         Costs, (Traw)         (Tfin) after               Approximate
                                      Costs (MFG)            (Trucked)            10% Profit           Market Radius (Miles)
              city                                  - $/CWT -                                          Motor Truck         Rail

              Chicago                     1.07                 0.78                   0.73                  100           150

              Grand Rapids                1.07                 0.78                   0.73                  100           150

    CD        Lansing                     0.99                 0.58                   1.01                  250           350

              Ludington                   1.02                 0.54                   1.01                  250           350

              Traverse City               1.00                 0.74                   0.84                  150           200

                       "M      1W     =I      M" No                                                            an      an     -am
<pb n="115" />

         b.   Pulp/Paper Production

              Pulp mills process wood and other fiberous materials into pulp through
              either mechanical or chemical processes, or a combination of both.     The
              principal woods used are spruce, hemlock, southern pine, poplar and fir.
              Cereal straw such as oats, rye and barley are often pulped for making
              corrugated box board. Paper mills refine the pulp and add bleaches, dyes,
              or other additives, depending on the paper stock desired.    The pulp is
              formed into paper through a process of screening, drying, rolling and
              pressing.

              Pulp mills are commonly located near or at the source of wood. Many mills
              own or lease timberland and produce up to 75% of their raw material
              requirements. When not integrated with the paper mill, the pulp is rolled
              into bundles and shipped to the paper mill.

              As with the cement industry, pulp and paper mills are highly mechanized
              and thus not dependent on a large labor force. The major factor in loca-
              tion of pulp and paper mills is proximity to the growing area as the raw
              materials are bulky and low-valued and will not bear high transportation
              costs.

              The results of the feasibility analysis for a pulp mill alone are pre-
              sented. For the purposes of comparison, it wa's assumed that pulpwood was
              not available locally and would be purchased and transported from
              Escanaba, Michigan. Markets for the pulp (paper mills) were assumed to be
              located in five major cities in proportion to their population: Chicago,
              Grand Rapids, Lansing, Milwaukee, and Madison.     Table 14 presents the
              results of this analysis.

              As seen in Table 14, Ludington compares favorably with the other areas.
              If a pulpwood source could be located nearby to supply a portion of the
              wood requirement, this would greatly reduce the total manufacturing costs
              as it would reduce the cost of raw material transportation.        If the
              timberland were owned or leased by the pulp mill, the total manufacturing
              cost would be further reduced.

                                               V-11
<pb n="116" />

                                                   TABLE 14

                                   APPROXIMATE COSTS OF TRANSPORTATION AND
                                      PRODUCTION OF BLEACHED KRAFT PULP

                 Plant Location          T Raw           T Fin            Mfg          Total

                 Chicago                 1.54            0.43           20.65          22.62
                 Grand Rapids            3.24            0.87           20.75          24.86
                 Ludington               1.22            0.97           19.45          21.64
                 Milwaukee               1.38            0.65           21.50          23.53
                 Traverse City           1.20            1.12           19.00          21.32

           C.    Fertilizer Production

                 The three main components of commercial fertilizer are nitrogen-phos-
                 phorus-potassium (N-P-K). Fertilizer production at Ludington would depend
                 upon the importation of these materials, plus nitric acid, at production
                 levels.   Since Canada is a major producer of two of these components -
                 nitrogen (as ammonia) and potash, the Great Lakes Basin has good potential
                 for fertilizer production.     It must be noted, however, that this area is
                 in competition with the Gulf Coast (especially Louisiana, Texas and
                 Florida), which have established production facilities. In addition, the
                 Gulf Coast has year-round ocean shipping service for large size vessels.
                 Of course, the cost of transporting the final product from these areas to
                 northern markets would be greater.        Likewise, a fertilizer production
                 facility at Ludington could be in competition with existing/potential
                 Canadian facilities.

                 Production costs for six selected cities are compared in      Table 15.

                                                TABLE 15

                                     APPROXIMATE MANUFACTURING COST
                                     OF FERTILIZER (13-11-12, Grade)        Mfg
                                                                           $/cwt*

                           Chicago                                          5.40
                           Detroit                                          5.57
                           Grand Rapids                                     5.42
                           Ludington                                        5.18
                           Milwaukee                                        5.22
                           Traverse City                                    5.09

                           ------------
                             Includes the cost of raw material transportation

                                                      V-12
<pb n="117" />

               Since natural gas is the third largest production cost (after raw materi-
               als and labor), Ludington's competitiveness could be enhanced if a depen-
               dable private source of natural gas were available.

               Si.nce there are no local fertilizer production facilities, a Ludington
               facility must provide fertilizer at a lower wholesale price than other
               competing wholesalers.     A Ludington facility also must have sufficient
               market demand to absorb its 100,000 tons of annual production.

               Total cost delivered to Big Rapids from selected cities is shown in Table
               16.

                                                     TABLE 16

                                     APPROXIMATE COSTS OF TRANSPORTATION AND
                                   PRODUCTION OF FERTILIZER (13-11-12, Grade)
                                                       Wton)

               Plant Location                      Mfg                T fin               Total

               Chicago                            107.92               20.70            -128.62
               Detroit                            111.30               21.45            132.75
               Grand Rapids                       108.35                7.15            115.50
               Ludington                          103.70                7.80            111.50
               Milwaukee                          104.33               22.50            126.83
               Traverse City                      101.80               10.40            112.20

               As seen in Table 16, Ludington compares favorably      with other  area  s.

          d.   Steel Fabrication

               Steel fabricating involves the operations of cutting and shaping the
               steel, and fastening components together.         Depending on the item being
               produced, operations could involve stamping, rol      ling, cutting, riveting,
               welding, machining of parts (tool and die), and finishing operations such
               as painting, plating or corrosion treatment.         This type of industry is
               fairly flexible, producing many specialty items and constantly changing to
               meet varying product markets.      It is capital intensive, as most processes
               are mechanized and many are computerized.       It is also labor dependent, as
               skilled craftsman, machinists, and equipment operators and repairmen are
               vital to the industry.

                                                   V-13
<pb n="118" />

                 Since the Ludington area would not support a large scale, general fabri-
                 cator, only a specialty fabricator has been considered.             Preliminary
                 investigations revealed that the only significant advantage to a Ludington
                 location is the harbor access for hea     vy lift ships which handle extra
                 large size components. Even this advantage is limited by the lack of
                 suitable terminal facilities and the limited navigation season of the St.
                 Lawrence Seaway.

           e.    Ship Building and Repair

                 Ship building and repair can be considered as having three sub-groups:
                 ocean-going vessels, inland vessels, and private pleasure craft.            Each
                 sub-group has been considered.

                 There is, at present, a world surplus of ship building and repair
                 capacity.   Likewise, there is a surplus of Great Lakes ship building and
                 repair capacity for "laker" class vessels. Despite the aged nature of the
                 Great Lakes fleet, these vessels and ones built at existing shipyards will
                 meet Great Lakes demand for the foreseeable future.

                 The forecast for inland vessels is strong (refer to Chapter IV, Section B,
                 8); however, these vessels are primarily river tugs and barges. Although
                 such vessels could be built at Ludington, preliminary investigations did
                 not indicate favorable conditions. Ludington does not have direct access
                 to, nor favorable transportation rates for, steel supplies.         Steel from
                 Gary, Indiana must be transported up-lake,- against it's ultimate market
                 direction.  Steel from Europe or Japan is available only during a limited
                 navigation season.    In addition, Ludington does not have a ready labor
                 pool of skilled labor for this specialization.

                 In short, Ludington would be in competition with many other communities on
                 the Mississippi-Ohio-Missouri River system.

                 Boat building and repair for pleasure craft has its own set of economic
                 variables.  The pleasure boat building market is very volatile and highly
                 competitive.   It is characterized by a few industry "giants" and many

                                                    V-14
<pb n="119" />

               smaller companies. Survival of these smaller companies depends on fic      kle
               consumer acceptance, a sound product, and a competitive price. Boats less
               than about 15 feet LOA (length over all)can be built almost anywhere and
               trailered to the retailer.    Boats above 25 feet LOA (especially above 35
               feet LOA) are usually built on-order at a waterside plant.       The industry
               giants seems to locate production facilities near major boating centers.
               As a result, delivery costs to the owner are reduced and sales represen-
               tatives have models to work with.        Major yacht building areas are:
               California, South Florida, Connecticut, and Maryland.       Within the Great
               Lakes, the   population centers of Chicago, Detroit, and Cleveland would
               seem to be   logical production centers.    It is known that there is are
               medium and   small yacht building companies throughout the Great Lakes;
               however, it is difficult to justify this location in terms of economic
               advantage.   What seems to be  their major attraction is a quality of life
               that a community offers.

               Boat and yacht repair do seem to have some potential; however, the demand
               is difficult to quantify at this level of analysis.

               The demand for facilities, beyond those offered by a competent marina, is
               related to the number of permanent and transient boats at Ludington.
               Likewise, the availability of major repair services and out-haul facili-
               ties will influence work people to call Ludington home port.

               Several local people, familiar with Ludington's facilities, have indicated
               a need for a large boat out-haul facility.      Given the occupancy rate at
               the new city marina, if the city doesn't need a large boat out-haul now,
               then it will probably need one soon.

          f.   Power Generation with Wood Fuels

               On November 29, 1977, Governor William G. Milliken's Conference on Wood
               Energy was held in Ann Arbor, Michigan.      The purpose of this conference
               was to examine the benefits and problems associated with the use of wood
               for energy. A variety of topics were presented at the conference, includ-
               ing the following:

                                                  V-15
<pb n="120" />

                     I.   Methods of harvesting wood
                     2.   Forestry management
                     3.   Combustion and power generation technology
                     4.   Requirements of the annual growing stock
                     5.   Cost analysis of power generation with wood vs. other

                          energy sources
                     6.   Efficiency of wood fuels
                     7.   Two case studies where wood has successfully been
                          used for steam heating

          The main conclusion of this conference was that wood might feasibly be used as
          a supplemental and renewable source of energy, particularly if the cost of
          conventional fuels continued to rise at the rates that had been observed prior
          to 1977.

          Following this conference, a feasibility study was conducted for Consumers
          Power Company by a consulting engineering firm.     The study investigated the
          potential for a 50-megawatt wood-burning power plant which would be located in
          Osceola County near Hersey, Michigan.    Following the study, a public hearing
          was held to present the results and obtain public input.    Based on the amount
          of public opinion against the power plant and related environmental concerns
          which were expressed, the project was terminated.      No further investigation
          into a wood-burning power plant at this or other locations has been undertaken.

          2.   Regional Distribution

          a.   General Cargo Terminal

               A review of the commodity flow information and survey results did not
               reveal any significant general commodity movements.    This lack of volume
               makes a general cargo terminal infeasible at any development cost or rate

               structure.

               The lack of a general cargo terminal does not      have to leave Ludington
               without such service.   An inland warehouse could  be used to make up rail
               car loads or container loads for transhipment.     A freight forwarder, or
               other agent, knowledgeable in the preparation of marine documents, would
               also be necessary.

                                                 V-16
<pb n="121" />

         b.    Dry Bulk Terminal

               Phase I Operations (limited to inert construction aggregates only):

               Direct contacts revealed a current dry bulk importation of about 12,000
               tons of limestone annually.     A limited terminal, utilizing C&amp;O Dock No.
               1-112, could easily meet this demand. It would also provide the basis for
               additional terminal growth and open two existing terminal sites on the
               channel for redevelopment.    Information detailing a limited bulk terminal
               development cost, operating cost, and site layout is included in Chapter
               VIII, Development Opportunities, Dry Bulk Terminal, Phase I.

               Phase II Operations:

               Preliminary investigations indicate that the dry bulk terminal operations
               might feasibly be expanded in Ludington in the future to receive greater
               incoming shipments. The materials which have the most potential are:

                    Crushed stone (primarily limestone)
                    Rock salt (for ice control on roads)
                    Seal coat chips

               Use of an existing terminal to receive shipments of agricultural lime has
               also been reported.    Any materials other than inert aggregates which are
               considered for shipment through this terminal in the future must be
               carefully considered with      respect   to   their potential     environmental
               impacts.

               The demand for crushed limestone and aggregates varies naturally along
               with the volume of heavy construction.      The use of road salt is somewhat
               more constant, although quantities are cut back during slow economic
               periods.   A market for the following quantities of materials could be
               developed for the terminal:

                                                  V-17
<pb n="122" />

                                                                     Annual Demand

                     Crushed limestone                                100,000 tons
                     Rock salt                                          5,000 tons
                     Seal coat chips                                    5,000 tons

                The cost to develop   and equip a terminal to receive these materials is
                approximately $578,000.   The terminal would receive shipments which could
                be loaded directly into rail cars or stockpiled by self-unloading barges.
                Annual operating costs for this facility are estimated at approximately
                $237,000, of which $82,000 is- retirement of capital debt.         Information
                detailing the development costs and layout for such a terminal is given in
                Chapter VIII; Development Opportunities, Dry Bulk Material Terminal, Phase
                Ii.

                The market price for crushed limestone in the Ludington area varies,
                depending on the quantity and gradation desired.        A typical cost for
                truckload quantities of limestone is approximately $18 per ton.       To pay
                the terminal I s annual operating costs and make a 15 percent prof it, the
                terminal charges would be approximately $2.50/ton, or 14% of the market
                cost of limestone (assuming 110,000 tons annually).

           C.   Bulk Petroleum Terminal

                A bulk petroleum terminal would be the most capital     intensive and costly
                of the various types of bulk terminals investigated.    It would most likely
                be developed in Ludington by an oil company or by       a major distributor
                which has a large enough share of the market to         recover  its capital
                investment. The map on the following page shows the     location of existing
                marine and pipeline terminals in Michigan.     From the map, it  can be @een
                that there are cu rrently no terminals in the immediate area of  Ludington.

                The approximate annual consumption of petroleum products in the Ludington
                hinterlands is as follows:

                                                  V-18
<pb n="123" />

                 NAG"                      14AAGA

                                                               MANNIFITS                                                     LUCE
                                                                                              ALGER
                                        um                                                           SCHOOLCRAFT                     MACKINAC     CHIPF"IWA
                                                                                      MIA

                                                                                                                             J

                                                                                                                                                        CHEBOYGAN

                                                                                                                                                                        PRESWE ISLE
                                                                                                                                        CNAMLEVOIX
                                                                                                             oq                         ANT IM         OTSEGO                    ALPENA

                                                                                                                 LEELANAIJ

                                                                                                                          OR                        CRAWFORD        OSCODA         ALCONA
                                                                                                             UNIN        Ta

                                                                                                            MAXISTIll     WFJIPORD     IMSSAIJKH ROSCOMMON OGIMAW                  losco

                                                                                                                                                                            ARIMAC
                                                                                                       MANN          I.Allf       Oscim         CLARK        OLAD"
                                                                                                                                                                        SAY                           muwm

                                                                                                     OCIANA                       MICOSTA       ISABELLA     MIDLAND
                                                                                                                   NEWAYGO                  I                                             TUSCOLA           "HILAC
                                                                                                           0                        MONTCALM                           SAGINAW
                                                                                                                                                        GRATIOT
                                                                                                               tam
                                                                                                              OTTAWA         KINT         IONIA         CLINTON DWASUMS            GENES"         LAPUR        Loa CA
                                                                                                                                                                                                                       0

                                                                                                                                                                                                           MAC
                                                                                                            0    ALIJIGAN           Ulu           lA"          IMONAM LMHUM                 GARLAND            00
                                                                                                           VAN PJUN                          0,              00                                  00
                                                                                                                                                             JACKSON
                                                                                                                          KALAMAZOO           ..             00                                            0
                                                                                                                CAN        V JOSEPH                                                      0
                                                                                                                                            NANO
                                                                                                   00

                                                                                                                                                                                       R NOT'
                                                                                    REFINERIES                                                                      PORT DEVVEL'OPMT STUDY
                                                                             0 MARINE TERMINALS                                                                                  FIGURE 30
                                                                              0 PIPELINE TERMINALS                                                                           MICHIGAN BULK
                                                                                                                                                                    PETROLEUM TERMINALS

                   SOURCE: MPA1980-131 MARKET ING,C)IRECTORY ANDYEARBOOK
                               WILLIAMSaWORKS                                                                                                                OCTOBER, 1982                                           670291
<pb n="124" />

                    Gasoline (all grades) and diesel fuel         1,400,,000 barrels
                    Fuel Oil (#1 and #2)                            400,000 barrels

               The cost to develop and equip a terminal which could receive and distrib-
               ute 25% of this annual amount with a two-month storage period is approxi-
               mately $4.4 million. This terminal would provide a total storage capacity
               of 96,000 barrels in nine tanks, which could be rotated by product, as
               demand dictates. This capacity is typical of existing marine terminals in
               northern Michigan.

               Annual operating costs for this facility are approximately $782,000, of
               which the major portion is the retirement of capital facilities debt.       If
               the annual operating costs and a 10% profit are levied uniformly on the
               annual volume of bulk products, the terminal fee would be approximately
               $1.93/barrel, or $0.046 per gallon.

               Information detailing the development costs, operating costs, and site
               layout for such a terminal is given in Chapter VIII, Development Opportu-
               nities, Bulk Petroleum Terminal.

         3.    Inter-Regional

         a.    Railroad Traffic

               Several comprehensive studies -of cross-lake railroad car traffic have been
               made. A. T. Kearny &amp; Associates published a study in 1980 that indicted a
               possible range of 16,145 to 62,433 carloads annually for Ludington and
               Frankfort combined.   These estimates are based upon six scenarios which
               test several variables such as rate structure, level of service, and
               natural growth.

               The most recent study: ITB Utilization Plan for Lake Michigan   ' (by John J.
               McMullen Associates, et al) was prepared for the Michigan Department of
               Transportation. It was published in draft form in May 1982. The McMullen
               study estimates 35,000 carloads annually in 1985, based upon a four round
               trips per day schedule.      The demand is estimated at 27,000 carloads

                                                 V-19                           -
<pb n="125" />

               annually in 1985, if only two round trips per day are provided.            These
               estimates do not include empties which would increase total volume by
               about 50 percent. These estimates are for "upper lake" service; that is,
               all rail car traffic for Ludington and Frankfort combined.             9

               The McMullen estimates are intended to be conservative and to reflect
               status-quo conditions.    A major factor is the future policy of the C&amp;O
               Railroad with respect to traffic routing through Chicago, Illinois. A C&amp;O
               policy to route all traffic through Chicago could lower these estimates by
               as much as 50 percent.

               The McMullen study suggests that 99% of the estimated railroad traffic and
               all of the passenger/auto traffic can be accommodated by using the inter-
               grated tug barge (ITB) and either the Spartan or the Badger.                This
               combination of vessels results in the lowest cost ($329/carload) but does
               not accommodate any of the projected truck/trailer traffic.

               The McMullen study is based upon a direct survey of railroad cross lake
               users and analysis of historical trends.

          b.   Truck, Trailer, Container Traffic

               As used in this section, trucks -refers to tractor trailer trucks with
               drivers.   Trailers refer to semi-trailers, which are transported cross-
               lake unattended.    This distinction is important with respect to vessel
               capacity and turn-around time.       It is especially important to vessel
               assignment, since the ITB will not be certified for passengers.       In addi-
               tion, containers are considered as semi-trailers.       The lack of container
               handling equipment requires that they be transported on their over-the-
               road wheels.

               The McMullen study estimates between 2,000 and 2,900 semi-trailer move-
               ments per year in 1985 for the upper lake crossing.      A conservative esti-
               mate would be 2,000 semi-trailer movements per year.
               As with' the railroad car estimates, these are based upon direct surveys
               and trend analysis. This estimate is intended to reflect the status-quo.

                                                  V-20
<pb n="126" />

         C.    Passengers

               The McMullen  study estimates that upper lake service to Kewaunee,
               Wisconsin would generate 28,000 passengers and 10,000 autos. They believe
               that a route to Manitowoc would generate more volume; however, how much
               more is not estimated. It is also believed that separating auto-passenger
               service from rail service would increase auto-passenger volume.

               Auto-passenger service is sensitive to rates, marketing, level of service,
               and route.   We speculate that the volume for a Ludington-based auto-
               passenger ferry would be higher than for a Frankfort-based ferry, based on
               route considerations.

               The McMullen estimates are based on:

                o Data for past cross-lake pa  ssenger traffic
                o Data of the summer 1981 demonstration project
                o Past survey results

               It was estimated that 10 percent of all inter-state Michigan: Illinois,
               Wisconsin, and Minnesota pleasure auto trips would use a cross-lake ferry.
               Potential business person trips were estimated at 5 percent.      Most of
               these trips were assigned to a lower-lake route.

                                                V-21
<pb n="127" />

                                 Chapter VI
               Draft Land Use Alternatives
<pb n="128" />

                                           CHAPTER VI

                                   DRAFT LAND USE ALTERNATIVES

         FUNCTION AND PURPOSE

         The fundamental, official document a community uses to set down goals is a
         long-range land use plan which can be referred to by public officials and pri-
         vate citizens.   The Municipal and Township Planning Act, Public Act 285 of
         1931, and Public Act 168 of 1959, as amended, specifically give respective
         planning commissions the authority to prepare and officially adopt a Plan.
         -When prepared, officially adopted, and maintained, this Plan should provide an
         advisory guide for physical development of the community into the best possible
         living environment for present and future community residents.

         Because our social and economic structure and activities constantly change the
         Plan, periodic review and revision must reflect contemporary trends while
         maintaining long-range goals.

         To be effective, the Plan must:

           -  Reflect needs and desires of the people;
           -  Interpret realistically the existing conditions, trends, and the dynamic
              economic and social pressures for expansion;
              Inspire approval and cooperation among the various public agencies and
              citizens of the community so that they will build conformity with the
              objectives it sets forth.

         The Land Use Plan provides:

         1.   A comprehensive means of integrating proposals that look 15 to 20 years
              ahead to meet future needs regarding general and major aspects of develop-
              ment throughout the community.

                                              VI-1
<pb n="129" />

           2.   An official, advisory policy statement for encouraging orderly and effi-
                cient use of the land for residences, business, parks, recreation, and
                industrial areas, and for coordinating these uses of land within each
                other and with streets and highways and other necessary public facilities
                and services.

           3.   A logical basis for zoning, subdivision design, public improvement plans,
                and for facilitating and guiding other work of the Planning Commission and
                the legislative body, as well as other public and private endeavors deal-
                ing with the community's physical development.

           4.   A means for private organizations and individuals to determine how they
                may relate their building projects and policies to official community
                planning policies.

           5.   A means of relating plans (Ludington and Pere Marquette) to plans of
                adjacent communities and to   development of the region as a whole.

           The Land Use Plan is intended to be long-range and dynamic; it is based on
           potentials and projects, population growth, economic development, and ways of
           living.   It attempts to look 15 to 20 years ahead.         Present trends such as
           those indicating lower birth rates, higher energy costs, more leisure time, and
           higher standards of living have been considered in making plans that anticipate
           long-range needs.    It would be desirable to base plans on even more distant
           goals, but the unpredictable events that may occur during longer periods make
           this impractical.    Instead, the Plan must be subject to periodic review and
           revision. Through this process, it will always express 15 to 20 year goals and
           will reflect contemporary conditions and trends.

                THE LAND USE PLAN IS GENERAL IN SCOPE: IT IS NOT INTENDED TO ESTAB-
                LISH PRECISE BOUNDARIES OF LAND USE AREAS OR EXACT LOCATIONS OF
                FUTURE USES.     ITS FUNCTION IS TO GUIDE GROWTH TOWARD LONG-RANGE,
                BROAD GOALS.    IT ESTABLISHES THE FRAMEWORK REQUIRED TO ASSURE THAT
                MORE DETAILED DECISIONS CAN BE RELATED TO THE BROADER SCENE.

                                                   VI-2
<pb n="130" />

          ALTERNATIVE LAND USE OPPORTUNITIES

          Five alternative land use opportunities have been developed based upon the
          information gathered and analyzed in the previous sections of this report.
          Three alternatives are presented for the City of Ludington and two for Pere
          Marquette Charter Township.    Each alternative expresses different land use
          development philosophies for planning and each will have a different impact on
          -the community.

          A common element in all five 'alternatives is the preservation of the wetland
          areas adjacent to the Dow disposal lagoons. These natural areas provide impor-
          tan,t habitat and breeding grounds for Pere Marquette Lake and River.   A buffer
          area is also designated between the wetlands park in conjunction with a town-
          ship park.  These three areas (wetlands park, buffer and township park) will
          serve to enhance the aesthetic and recreation qualities of the area for enjoy-
          ment by existing and future resid ents and visitors to the area.

                                                VI-3
<pb n="131" />

           Alternative A-1

           The following figure graphically illustrates the concepts of Alternative A-1.-
           This alternative encompasses land in the City of Ludington from the City Marina
           to the City Park adjacent to the Dow property.

           As can be noted, this alternative recommends that the existing rail corridor be
           maintained to serve and support ind,ustry in the area. This corridor has been,
           and should be, encouraged to be the backbone of moving goods in and out of
           Ludington.   Coupled with the function of the rail corridor are the adjacent
           industrial designations. Approximately 35 acres are indicated, recognizing the
           existing industry and encouraging future industrial development in this area.
           Chapter V - Feasibility Determination - found the following industrial uses to
           be marginally feasible in Ludington: cement manufacturing, pulp/paper production,
           agricultural and chemical processing.

           East of this industrial area and west    of the bridge, a marina development is
           proposed. This area could be developed   as a marina and/or other water recreation
           oriented commercial uses.    This would take advantage of the existing water
           frontage and serve as a logical line between the existing commercial/ recrea-
           tional uses adjacent t6 the area along the waterfront.

           Immediately south of the marina area, multi-family residential housing is
           proposed.  Housing in this area should be of a low-rise medium density charac-
           ter strongly oriented toward the water.     These units should not exceed three
           stories in height nor more than 12 units per acre. As a result, this 5.5± acre
           site could contain 60-70 dwelling'units with a resultant permanent population
           of approximately 200.

           Recent development trends for waterfront properties indicate a stronger poten-
           tial for seasonal occupancy and the construction of a condominium-type project.
           In any event, the proposed low-rise medium density development will blend with
           the existing character while allowing a reasonable density for this location.

                                                 VI-4
<pb n="132" />

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                   WILLIAMS &amp; WORKS
<pb n="133" />

          Alternative A-2

          Alternative A-2 is graphically illustrated on the following figure.              This
          alternative encompasses land in the City of Ludington from the City Marina to
          the City Park.

          Starting at the existing City Park, this alternative proposes to enlarge this
          park to the north.    At present, this park serves as a local recreation facil-
          ity.  The proposed expansion would allow the development of more facilities
          (e.g., beach, play equipment, fishing, etc.) and upgrade the park to a regional-
          type facility.    This regional park will reinforce the recreation/commercial
          uses existing in the area, plus wil  I act as a tourist attraction.

          The Michigan DNR Waterways Division has stated that the westerly shoreline of
          the park was too exposed for docking facilities and the northerly shore offers
          water depths that are generally inappropriate for recreational docking facili-
          ties. In light of these comments, the future development of this park must be
          coordinated within these parameters-

          Moving north and west, this alternative designates three types of industrial
          uses - general industrial, marine transportation, and general marine terminal.
          The general industrial areas are intended to encourage the existing industries
          to continue and expand, plus provide land for additional manufacturing, ware-
          housing, and storage-type uses. The marine transportation area is intended for
          uses oriented toward water and land transportation networks.          Utilizing the
          designated highway and railroad corridor, industrial uses would be provided
          convenience access to needed transportation systems.      The marine terminal area
          is designed to promote Ludington as a shipping and receiving terminal, as
          detailed in Chapter V-Feasibility Determination.          Again, the highway and
          railroad corridor will facilitate the future development of the marine terminal
          area by offering two modes of transportation.

                                                 VI-5
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           Alternative A-3

           As graphically illustrated, Alternative A-3 is similar to Alternative A-1 with
           respect to the rail corridor, marine, city park, and industry.     This concept
           differs in the area east and south of the city hall.      Commercial and multi-
           family residential uses are proposed.

           The commercial area includes the land adjacent to city hall.    Commercial uses
           in this location would be retail and recreation oriented, catering to the needs
           of the marina users and seasonal visitors along with the downtown shopper.
           This area could also provide convenience goods for the adjacent multi-family
           residential area.

           The multi-family residential area is proposed to have a low-rise medium densi,ty
           character strongly oriented toward the water.    These units should@ not exceed
           three stories in height nor more than 12 units per acre.

           As a result, this 45± acre site would require extensive redevelopment-, to ade-
           quately provide a desirable living environment.     When fully developed, this
           site would contain approximately 540 dwelling units, resulting in a population
           of 1,600 persons. This type of development will allow an aesthetically pleas-
           ing, well landscaped project, while allowing a density to help support downtown
           business.

                                                VI-6
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           Alternative B-1

           Alternative B-1 encompasses land in Pere Marquette Charter Township as illus-
           trated in the following figure.   At the present time, access to this area is
           hampered by a narrow, two-lane road.     This alternative proposes an Improved
           Vehicular Corridor within the existing right-of-way to County Road Commission
           standards for a major roadway.     Immediately north of the corridor, a large
           (400± acres) multi-family residential area is designated.       Approximately a
           third of this property is tree covered, providing a desirable environment for
           low-rise, medium density development.    This type of project should take full
           advantage of the natural assets on the site and utilize innovative design
           concept (e.g., cluster housing, zero lot lines, etc.) to make this area an
           asset to the community and a desirable place to live. Prior to the development
           of this site, utilities (sewer and water) will need to be provided at the site.
           With a potential population of approximately 10,000 to 15,000 people, it will
           be necessary to have this infrastructure.

           A neighborhood commercial center has been located in the residential area to
           provide convenience shopping opportunities for local residents.    Uses in this
           commercial center could consist of barber and beauty shops, financial institu-
           tions, florists and gift shops, self-service laundry and dry cleaning pick-up
           stations, shoe repair, tailor and grocery store, to mention a few.

           To help service the water access needs in this area, a private marina is pro-
           posed in the southwest corner of Pere Marquette Lake.    As a complement to the
           marina, an area of commercial /recreational use is designated immediately adja-
           cent. This commercial area would have recreation emphasis and not compete with
           the nearby neighborhood commercial center.

                                                 VI-7
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          Alternative B-2

          As graphically illustrated, Alternative B-2 contains land use concepts for Pere
          Marquette Charter Township. The rural ranchettes area is proposed for develop-
          ment of large lot (1-5 acre) single-family homesites.       Since much of the 350±
          acres is tree-covered, a majority of the 140± sites could be nestled among the
          trees, leaving a natural-looking environment.          If developed as proposed,
          approximately 400-450 people would populate this area.

          North of this area is a multi-family residential area.         This 150± acre low-
          rise, medium density area should be designed and developed with,prime consider-
          ation to existing natural features. Much of this area is tree-covered, provid-
          ing desirable living opportunities for the 4,000 to 5,000 people who may
          inhabit this location.

          Moving further north is a commercial /recreational area.     This type of develop-
          ment will serve as a buffer between the multi-family area and the existing
          industry.   Next to the industry, a marina development is designated.       A small
          marina operation is proposed to serve the needs of the nearby residents.

                                                 VI-8
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<pb n="141" />

                                 Chapter VII
                      Harbor Land Use Plan
<pb n="142" />

                                           CHAPTER VII
                           PERE MARQUETTE  LAKE LAND USE AND PORT PLAN

        INTRODUCTION

        The purpose of -this plan is to provide a broad framework to meet all the peo-
        ple's needs and activities (current and future).       It also has the purpose of
        fitting these activities (land uses) to the natural characteristics of the land
        and with existing land uses.    It is the further purpose of this plan to en   cour-
        age and preserve desirable land uses and to discourage certain undesirable land

        uses.

        This plan is based upon the study data and analysis. It also reflects steering
        committee and public input.

        This plan is focused on the  Pere Marquette Lake area. It provides for a compre-
        hensive range of land uses,  from natural area preservation to heavy industrial.

        The discussion of land uses is presented in two sections (Ludington and Pere
        Marquette Township) for ease  of adoption.

        A.   GENERAL PLAN CONCEPTS

        This plan embodies several concepts which are common to both the City -of
        Ludington and to Pere Marquette Township.      These are general development con-
        cepts on which the other plan features are based. These concepts include:

        1.   a balanced use of Pere Marquette Lake, with respect to industrial, commer-
             cial, residential, and natural area preservation.

        2.   the creation of a strong local economy through the use of Pere Marquette
             Lake for recreational  boating and commercial shipping.

        3.   the preservation and enhancement of desirable land uses along the shore-
             line.                       %

                                               VII-1
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         4.   the redevelopment of under-utilized areas or inappropriate land uses.

         5.   blending of new areas with existing land uses and with the area's natural
              characteristics.

         B.   THE CITY OF LUDINGTON: PLAN ELEMENTS

         1.   Residential

         The plan provides for the continuance of the existing multi-family area between
         the United States Coast Guard station and the new city marina.     This small area
         is developed with multi-family residential.

         A second multi-family area, at the end of the Buttersville Bar, is also shown on
         the plan.  Like the first area, it is developed with multi-family residential.
         It is the new condominium development known as the Crosswinds.

         The plan shows one single-family residential area, north of the new city marina.
         This area reflects the planning results of the marina area development plan.

         Another residential area is shown north of the Dow Chemical Industrial Complex.
         Although bisected by a small commercial strip, it is predominantly single-family
         developed.

         This plan does not seek any change in the character of any of these multi-family
         or single-family residential areas.

         One area, the Western Concrete site (also known as the Blout property) is
         designated commercial/recreation and multi-family residential.    As multi-family
         residential, it is an attractive site for a seasonal condominium development. A
         prospectus for condominium development is included in Chapter VIII, Development
         Opportunities.   The commercial/ recreation opportunities are discussed in
         Section 3, Mixed Commercial.

                                               VII-2
<pb n="145" />

          2.   Commercial

          The plan shows the downtown area simply as commercial without delineating CBD
          areas from other types of commercial.       No change from existing development
          patterns is contemplated, except near the Star Watch Case facility.

          The Star Watch Case facility is planned for redevelopment as an office facility.
          It would provide almost 100,000 square feet of office space for a large business
          such as  a research and development facility, a professional design firm, a
          computer processing center, or municipal offices. A prospectus of redevelopment
          for this facility is included in Chapter VIII, Development Opportunities.

          The plan also provides for the development of a major hotel /restaurant complex
          south of the Star Watch Case facility.    A hotel at this location would enjoy a
          good proximity to the downtown.     It would have -a good view of Pere Marquette
          Lake, the harbor-channel, and Lake Michigan. Its view, however, would overlook
          the marine bulk terminal. If a hotel/restaurant is not developed on this site,
          it could be 'used for general commercial, commercial recreation, or light indus-
          trial.

          The area immediately south of the city hall is planned for commercial recre-
          ation. It is well related to the new marina and enjoys an excellent view of the
          entrance channel and outer harbor. Commercial recreation is intended to include
          those retail uses which are especially tourism oriented.         Examples include:
          restaurants, handicraft shops, antiques and art galleries, bait and tackle
          shops, marinas and boat rentals, and the like.

          'The area west of the Washington Street Bridge is also designated commercial
          recreation.  This area presently supports several marinas.     The commercial area
          along Washington Street, immediately south of the bridge, is presently mixed
          commercial.   It should be encouraged to develop as commercial recreation with
          special emphasis on antique shops, art galleries, and handicraft shops.

          3.   Mixed Commercial

          The area immediately  north of the C&amp;O Railroad yards, north to Dowland Street is
          planned for a mix of commercial and industrial.     It could support heavy commer-
          cial uses or provide  expansion space for light industrial uses.

                                                VII-3
<pb n="146" />

         The Western Concrete site, also known as the Blount property, is proposed for
         commercial/recreation or multi-family residential. As commercial/recreation, it
         is especially attractive as a major hotel/restaurant site. It enjoys good views
         of Pere Marquette Lake and overlooks the Buttersville Bar and Lake Michigan. A
         prospectus for hotel development is included in Chapter VIII, Development
         Opportunities.

         4.   Industrial

         The plan shows the Dow plant as industrial. This reflects its current use.

         A second industrial area is shown just west of the Washington Street Bridge and
         south of the C&amp;O Railroad tracks. This area includes a variety of small indus-
         tries, some of which are only marginally viable.     The eastern portion of this
         area is proposed for industrial redevelopment.    It is a good site for a small
         recreation boat manufacturer or a heavy repair boat yard. Redevelopment of this
         site could be aided by the relocation of Lake Street, along the railroad tracks.
         A development prospectus for this site is included in Chapter VIII, Development
         Opportunities.

         5.   Marine Transportation/Terminal

         The C&amp;O Railroad property is shown as partly marine terminal and partly marine
         transportation. The marine terminal is shown along dock No. 1J. Uses proposed
         for this site include a bulk petroleum terminal and a small bulk construction
         aggregate terminal.   Th'ese terminals are discussed in depth in Section D, Port
         Plan Features.   A development prospectus for each of these is included in
         Chapter VIII, Development Opportunities.

         The marine transportation facility is intended to support a car ferry and in the
         future, the Integrated Tug Barge.    Since much of the railroad car marshalling
         and train makeup is done inland, the smaller area allocated for marine transpor-
         tation should not affect the car ferry/ integrated tug barge viability.     Marine
         transportation facilities are further discussed in Section D, Port Plan Fea-

         tures.

                                               VII-4
<pb n="147" />

          6.   Public Uses

          The existing Lake Michigan beach, boat launch, and U.S. Coast Guard station are
          shown as public use on the plan.    Likewise, the city park between the Western
          Concrete property and the Dow plant is also shown as public use.

          The new city marina and city hall are also shown as public use.       If the city
          hall ever is moved to another location, then its present site could be    used for
          commercial/recreation.

          7.   Transportation

          The plan assumes the continuance of waterborne shipping for Dow Chemical and
          Harbison-Walker.  The plan also assumes the continuance of the inter-regional
          service of the car ferry and possible service by the Integrated Tug Barge.      The
          import of bulk construction aggregate is provided for by the marine terminal.

          An access route will be necessary if and when both the dry bulk terminal and the
          petroleum terminal are fully developed. The plan calls for the development of a
          limited access truck route parallel. to the existing railroad tracks.    This will
          provide a direct route to the bulk terminal.

          C.   PERE MARQUETTE TOWNSHIP: PLAN ELEMENTS

          -1.  Residential

          The plan provides for about 400 acres of residential in the upland sloped areas
          on the south side of Pere Marquette Lake. This area lends itself to low-density,
          single-family residential.   This area should be developed with prime consid-
          eration to existing natural features and constraints.         In particular, the
          wetland areas must not be degraded as a result of this area's development.

          This area is designated for rural ranchettes, large lot (1 to 5 acre) single-
          family homesites. Since about 350 acres is tree-covered, many of the 140± sites
          could be nestled among the trees, leaving a natural-looking environment.        The
          larger ranchet tes could support gentlemen farms or equestrian activities.       If

                                                VII-5
<pb n="148" />

         developed according to this plan, about 1400 people eventually, would populate
         this area.

         The plan also shows two single-family residential areas, along the Lake Michigan
         shoreline, and on the Buttersville Bar.      This reflects past development and it
         is anticipated that future development will be similar.       The plan provides for
         the continuance of the White Pine Village.

         2.    Commercial

         The plan provides for three small commercial areas.         The existing commercial
         area on US-31 is shown on the plan as commercial.

         A small commercial area is shown inland      in the rural ranchette area, however,
         the location of this area is not fixed.      It is intended to provide convenience
         goods and services to the neighborhood population.       It should not be developed
         until the population is in place to support it. Its size and locati,on must be
         tightly controlled to insure neighborhood service and not neighborhood dis-
         service.   A third commercial area is the Sand Products site.         At some future
         date, when this site is no longer needed for sand export, it would be a good
         site for a first-class restaurant or a small lodge.          This site enjoys some
         interesting views of Pere Marquette Lake, the wetlands, and the City of
         Ludington.   This site could also be developed with seasonal convenience retail
         thus eliminating the need for the new neighborhood commercial area (described
         above).

         3.    Industrial

         Two sites in Pere Marquette Township are shown as industrial on the plan. They
         are the Harbison-Walker plant and the Dow Disposal Lagoons. The Harbison-Walker
         designation reflects its current use.      The disposal lagoons are intended to be
         limited to disposal operations and must be in compliance with state regulations.
         Future use of this land for industrial development is questionable.

                                                 VII-6
<pb n="149" />

          4.   Public Use

          The plan provides for two public use areas.    The first is the existing Township
          park on Lake Michigan. It is planned that this park will expand to the east to
          Pere Marquette Lake and the area behind the Sand Products facility.

          The second public use area is the wetlands along the south side of Pere
          Marquette Lake.   These surround the Dow Disposal Lagoons on three sides.       Some
          of this area is planned as preserved open space with no development activity.
          Some of this area could be developed as a wetlands nature center with educa-
          tional stations and guided tours.      Development should be limited to upland
          areas, except for hoardwalks into the wetlands. This area also includes a new
          Township park, developed in an upland area near the US-31 neighborhood com-
          mercial center.

          D. PORT PLAN FEATURES'

          1.   Regional Terminals

          This plan allows for the continuance of the Dow Chemical/Harbison-Walker Termi-
          nal. However, it provides for the regional import (or export) of other dry bulk
          materials at the planned marine terminal.     This will free up other sites, such
          as Mohawk Transportation and Western Concrete for redevelopment.         Neither of
          these sites is extensively developed, therefore, operations could be moved to a
          new terminal with relative ease.     Unless an alternative terminal is provided,
          these sites cannot be redeveloped.

          The data collected through contacts with existing dry bulk terminal users
          indicated a current importation of about 12,000 tons annually.       The U. S. Army
          Corps of Engineers reports that in 1979, 18,700 tons of sand, gravel , and
          crushed rock were received in the Port of Ludington.      It is possible that some
          of the Corps of Engineers reported imports were an inter-regional commodity flow
          utilizing the car ferry.

          Since there is an existing need for at least 12,000 tons annually, a small
          terminal is planned as Phase I.    This terminal would have a minimum of capital

                                                VII-7
<pb n="150" />

         improvements and administrative organization. A prospectus for the Phase I dry
         bulk terminal, which details development and operational costs, and site layout,
         is included in Chapter VIII, Development Opportunities.

         The data collected through contacts with potential dry bulk terminal users
         showed a demand for at least 56,500 tons annually. Contacts included the State
        -of Michigan (Office-of Management and Budget), Mason County Road Commission,
         Lake County Road Commission, the Wexford County Road Commission, three trucking/
         construction companies, and five redi-mix concrete product manufacturers.

         The State of Michigan, Office of Management and Budget, expressed little inter-
         est in using the Port of Ludington because it might lower volumes, thus raising
         prices at other ports.    Five of the other contacts indicated an interest in
         using the terminal.     The contacts made, which represent about half of the
         potential users, yielded a little more than half of our estimated annual ton-
         nage. Therefore, the dry bulk terminal volume estimates of 110,000 tons annual-
         ly (Chapter V, Feasibility Determination) could be obtainable, in time.

         The Phase II dry bulk terminal prospectus, which details development and opera-
         tional costs and site layout, provides for a larger public terminal.            This
         terminal, which could handle about 55,000 tons of    material at a time, could be
         developed as demand expanded.

         A bulk petroleum terminal is also shown at the C&amp;O Railroad dock No. 11.         The
         direct contacts indicated little interest in a public terminal, as private
         terminals are typical of the industry.     Since there are several wholesalers in
         the Ludington area, there is a good potential that a terminal operator could be
         attracted to this site. A development prospectus for a bulk petroleum terminal
         is included in Chapter VIII, Development Opportunities. A bulk petroleum termi-
         nal is an appropriate private sector project.

         2.   Inter-Regional Terminal

         The plan provides for the continuance of the C&amp;O Railroad facility as either a
         car ferry or integrated tug barge terminal.       The Kerney &amp; McMullen studies
         identified a good potential for cross-lake railroad car ferry traffic.             A

                                               VII-8
<pb n="151" />

          sizable flow of passengers has also been identified. The continuance of cross-
          lake railroad car, automobile/ passenger and truck-trailer service is considered
          vital to Ludington's economy.

          In the future, it is possible that the northern area of the C&amp;O Railroad facili-
          ty could be put to another use. This should not affect the viability of the car
          ferry terminal.

          3.    Harbor Improvements

          No major harbor improvements are necessary under this plan. The existing harbor
          entrance, navigation channel, turning basin', and aids to navigation are ade-
          quate.   Some improvements to the C&amp;O Railroad dock No. lf are necessary and
          their costs are included in the development prospectus.       In addition, McMullen
          Assoc. recommends some modifications to the wing fender and the pile cluster at
          C&amp;O Railroad dock No. 2.    These modifications are necessary for the integrated
          tug barge.

          E. IMPLEMENTATION

          .1.   Port and Terminal Management Options

          A variety of organizational structures       can function as the lead agency to
          implement the port and terminal plan elements.      The advantages and limitations
          of each are discussed in this section.      Particular emphasis has been placed on
          the advantages and limitations of each with respect to Ludington.

          a.    Ludington Harbor Commission

                The Ludington Harbor Commission is an advisory body to the Ludington City
                Commission.   It is established by the City Ordinance in accordance with
                responsibilities similar to those of Public Act 234 of 1925, as amended.
                Public Act 234 of 1925    has been repealed by the Port Authority Act (P.A.
                639 of 1978); however, the     repeal is not effective until the Harbor
                Commission has converted to a port authority.

                                                 VII-9
<pb n="152" />

              As the Harbor Commission stands now, it may study and recommend improve-
              ments, but has limited means of implementation.      It must seek the assis-
              tance of another agency to undertake physical development or promotion.
              Furthermore, it has no responsibility to undertake such development or
              promotion.

              Another serious deficiency with the Harbor Commission is its lack of
              regulatory authority.    It can not make and enforce rules and regulations.
              Furthermore, it does not have regular input to the Pere Marquette Township
              Board nor does the Township Board have regular input to the Harbor Commis-
              sion.

              Despite its disadvantages, the Ludington Harbor Commission has several
              advantages.   The first is that it is an existing, functioning body.        Its
              members are familiar with   all aspects of Pere Marquette Lake.     The second
              advantage depends upon its  individual members. No single agency, no matter
              how broad its powers, can   implement a comprehensive plan single- handedly.
              It must have the support of many agencies.        This requires a continuing
              effort to "sell" the plan.-

              Given an operating budget, some individual initiative, and some minor
              organizational changes, the Ludington Harbor Commission could become the
              lever which moves a host of agencies into action.

         b.   Port Authority

              Public Act 639 of 1978 created an agency new to Michigan, the Port Authori-
              ty.   The creation - of a port authority requires approval of the voters
              within the county it is located and approval by the Governor.      A combina-
              tion of cities and counties (including at least one city and one county)
              may incorporate a port authority, however, no direct township participation
              is provided for.

              The authority is eligible for state assistance for 50% of its annual
              operating budget. It may also seek grants for specific projects. The port
              authority is a body corporate and politic.     It may own and operate a wide

                                                VII-10
<pb n="153" />

                variety of harbor facilities, terminals, bridges and ferries, waterways and
                lands, and the like.

                The port authority can regulate (i.e., zone) waterways,including pierhead
                lines. It can promulgate safety and environmental regulations.

                Port authorities make "payments in lieu of taxes" on public income produc-
                ing property; however, other public property is exempt..         Port authority
                property used for private purposes is taxable as private property.

                The chief. disadvantage of the port authority approach in Ludington is the
                limited scale of viable development and income producing projects.           Since
                many of Ludington's terminals are privately owned and operated, there could
                be much activity, but litt  le port authority revenue.

                Another disadvantage of the port authority approach is the lack of direct
                Pere Marquette Township participation. Pere Marquette Township would have
                to depend upon the county for representation; however, the county must
                represent all its constituent units.

                A less significant problem could be the reliance on state funds for operat-
                ing expenses. a port authority's annual operating budget is subject to
                approval by the Michigan Department of Transportation and appropriations by

                the State Legislature.

                The adv antages of a port authority are many and fairly obvious.              They
                include: regulatory authority, rea-1 estate ownership, terminal operation,
                bonding and fee collection, state operational funding, and grant eligi-
                bility. In short, a port authority can plan, decide, develop, and operate.

          C.    Independent Public Action/Private Development

                This approach could also be termed the "non-lead agency - all independent
                approach".   Under this approach, no agency or a very ineffective agency
                would be given the responsibility of implementing the plan and managing the
                port.   Each agency would be requested to implement that which it felt

                                                  VII-11
<pb n="154" />

              timely and important. Likewise, the decision as to what is and what is not
              an agency's responsibility would be left to each agency.

              The principle advantage to this approach is its simplicity, and low "up-
              front" cost.     It also makes use of existing agencies and private de-
              velopers.    The disadvantages of this approach are many, and could be
              ruinous.    Since each agency would act according to its own time table,
              development would be haphazardous at best. Many projects could be delayed
              for years while two agencies waited for each other to act. Without a lead
              agency advocating implementation, important projects could inappropriately
              lose priority status.

              Development, regulation, and management, when it did happen, could be
              contradictory, duplicative, or uneconomical.      A lack of coordinated timing
              could delay a project and drive costs up.

         d.   Pere Marquette Lake Council

              Under this approach, a joint council representing Pere Marquette Township,
              the City of Ludington, and Mason County would be established.           It could
              also include the Mason County Economic Authority or other similar agencies.

              Such a*council would be organized under the authority of Public Act 66 of
              1952, Harbors, Channels, and Other Navigational Facilities, or under the
              authority of Public Act No. 7 of 1967, the Urban Cooperation Act.

              Under P.A. 66 of 1952, political units    may create a joint agency to:

                 - govern the use of waterways, channels, harbors, and other navigational
                    facilities;

                 -  adopt ordinances and rules to safeguard the public;

                 -  be empowered to undertake these duties;

                 -  employ a harbor master and other officers with full police powers.

                                                 VII-12
<pb n="155" />

               An agency created under this Act is not a corporate body. It is an exten-
               sion of the constituent government units.        It cannot tax, issue bonds, or
               own property. It is financially dependent upon the parent governments.

               The principal advantage of a joint council, created under Act 66 of 1952,
               would be the ability of each political unit to be involved.           This should
               aid effective development and management.

               Another advantage    woul d be the counci I 's abi 1 i ty to promul gate envi ron-
               mental and safety    regulations.   It should, however, be noted that certain
               state and federal    laws would remain in force.      Usi@g the existing Harbor
               Commission as the    lead agency, the Pere Marquette Lake     Council could also
               act as a catalyst   to move other agencies to action.

               The principle di-s-advantage of such a council are financial and operational.
               Financially, the council could be so dependent on the parent governments
               that it might not be able to get its activities started.

               A Public Act 66 joint agency is operationally hampered        by the prohibition
               on owning land.      This would make assembling land for redevelopment, or
               developing a terminal very difficult.

          e.   Economic Development Authority/Economic Development Corporation

               Under this approach, a local economic development authority/ economic
               development corporation (either city or county) would be charged with-
               port/terminal plan implementation.       An EDA/EDC has the ability to issue
               bonds for public and private development, own land, and operate facilities.
               It does not have the ability to promulgate rules and regulations for
               environmental control.

               The principle advantage of the EDA/EDC approach are financial and opera-
               tional.   The EDA/EDC can issue bonds and raise capital.        It can cooperate
               with private industry for development and expansion projects.

                                                  VII-13
<pb n="156" />

               The principle disadvantage of this approach is the lack of direct control.

         2.    Agency Responsibilities

         This  section of the plan recognizes the roles of the many federal, state, and
         local agencies which will be involved in various stages of implementation of the
         plan.    The responsibilities of these agencies range from ownership and
         management of port facilities to serving the development plan in various
         advisory capacities.    Naturally, local agencies will have the most active roles
         in establishing policy and making decisions, while state and federal agencies
         will mainly be involved in a regulatory and/or advisory capacity, with some
         exceptions.

         a.    Local Agencies

               Planning Commissions (Ludington and Pere Marquette Township):          The local
               planning commissions will be involved in long and short range planning for
               port developments, particularly with respect to the needs and concerns of
               the two communities. They are directly concerned with site plan approvals,
               zoning changes, and comprehensive planning.

               City Commission/Township Board: The.Ludington City Commission and the Pere
               Marquette Township Board will have central roles in the implementation
               actions either directly or indirectly, such as the creation of a lead
               implementing agency.

               County Commission:     The Mason County Commission can have a significant
               participation in the implementation of the plan. They can provide adminis-
               trative and financial support and marketing assistance.

               County Economic Development Authority:      The Mason County Economic Develop-
               ment Authority is a semi-autonomous body concerned with county-wide econom-
               ic development.    The Mason County EDA historically serves as a financial
               resource. It also could act as a promotional and development agency.

                                                  VII-14
<pb n="157" />

               West Michigan Regi onal Planning Commission:   The Regional Planning Commis-
               sion, in order to coordinate its comprehensive planning program and address
               the needs of the many communities in Region 8, will provide input on the
               plan and its implementation.

          b.   State Agencies

               Michigan Department of Transp  ortation (MDOT):    The MDOT is the primary
               agency in Michigan involved with commercial navigation, and its activities
               in this area include planning, development, policy formation and analysis,
               and provision of grants and operating assistance. It also provides liaison
               between other agencies involved in commercial navigation, in addition to
               the private sector.

               Michigan Department of Natural Resources (MDNR):     Activities of the MDNR
               are mainly related to environmental protection during s,uch projects as
               harbor or channel dredging and other construction on or near Michigan's
               waterways.  The MDNR and U.S. Army Corps of Engineers have somewhat over-
               lapping regulatory functions for projects on the Great Lakes, and typically
               issue a joint permit for these approved activities.

               Michigan Waterways Commission:    A Commission of the MDNR, the Waterways
               Commission's powers include the acquisition, construction, and maintenance
               of recreational harbors, channels, docking, and launching facilitfes, and'
               the administration of commercial docks 'in the Straits of Mackinac.        The
               commission provides control of recreational boating in Michigan, and
               collects a tax on fuel used for boating.    The commission will be actively
               involved in any developments related to recreational boating in Ludington.

               Michigan Interagency Port Council: As the name implies, this agency exists
               to assure an appropriate balance between the aims of other state agencies
               involved in port development. Its members are representatives of the MDOT,
               MDNR, and state departments of commerce and agriculture.

                                                VII-15
<pb n="158" />

              Michigan Environmental Review Board (MERB):     The purpose of this agency is
              to review projects in Michigan of major environmental significance.        With
              respect to Great Lakes Ports, these activities would primarily be harbor
              and channel dredging.     The state departments of Agriculture, Commerce,
              Management &amp; Budget, MDN-R, Public Health, MDOT, and the Attorney General
              are represented on the MERB.

         C.   Federal Agencies

              International Joint Commission (IJC):     The IJC was created between Canada
              and the U.S. to study problems along the water boundary. The IJC also has
              control over the surface levels of the boundary waters through the power to
              approve of any use, diversion or obstruction which may alter the water
              levels. Thus it has an impact on commercial navigation on the Great Lakes.

              U.S. Army Corps of Engineers:     The Corps of Engineers serves as designer,
              builder, and operator of navigational facilities authorized by congress, in
              addition to a wide range of planning and development activities.            The
              recent harbor improvements in Ludington illustrate@ the Corps' involvement
              in commercial navigation.      These improvements and channel depths are
              maintained by the Corps on an on-going basis. The Corps also issues joint
              permits with the MDNR for approved activities on or nearthe Grbat Lakes
              which could affect water quality and/or navigation.

              U.S. Customs and Immigration Service:      The U.S. Customs and Immigration
              Service is the agency of the Federal Government responsible for the control
              of goods and people across our national borders.      Since only Dow Chemical
              and Harbison-Walker have any regular international shipping, the U.S.
              Customs and Immigration Service has a minor role in Ludington's port
              activities.

              U.S. Maritime Administration: This agency regulates waterborne shipping in
              foreign and domestic offshore commerce in the United States. It publishes
              long-term forecasts of waterborne foreign trade and other informational
              publications on the U.S. Merchant Marines and shipping.

                                                VII-16
<pb n="159" />

               U.S. Economic Development Administration:     The U.S. Economic Development
               Administration is responsible for administering certain economic develop-
               ment local government grant programs and certain economic development
               private sector loan programs.     These grants and loans are described in
               Section 3 of this chapter.

               U.S. Coast Guard (USCG):   The Coast Guard has many responsibilities con-
               cerning commercial navigation and recreational boating, including mainten-
               ance of navigational aids, ice breaking services, vessel           inspection,
               pollution control and cleanup, search and rescue, law enforcement and
               boating safety.    The Coast Guard also compiles daily observations of
               weather and wave conditions which can be useful for design purposes.       The
               U.S. Coast Guard station in Ludington is-located along the harbor entrance
               channel next to the Municipal Marina.

         3.    Funding Sources, Land Acquisition Methods, and Development Incentives

         The purpose of this section is to present alternative funding sources,          land.
         acquisition methods, and development incentives. Implementation of complicated
         plans require the use of many of these tools.      This discussion is intended to
         provide a basic summary.

         a.    Funding Sources

               Although there has been much publicity about grant cutbacks, there are
               still many grants available.   Competition is tough, but a sound project in
               an economically depressed area can be successfully funded.

               The most viable grant program in Michigan for economic development is the
               HUD Small Cities Block Grant program. The Michigan Department of Commerce
               is administering this program and they have established a selection proce-
               dure which favors job producing projects in economically depressed areas,
               with supporting private funding and grant paybacks.     This payback feature
               can be of great benefit to the local community because these monies are
               earmarked for the community's -use.   In this way, the grants are converted
               to low interest loans which in turn become the basis of an economic devel-
               opment revolving fund.

                                                VII-17
<pb n="160" />

               The U.S. Economic Development Administration has local public works grants
               which cover design and startup administration, land acquisition, and
               construction.  These grants are available in economically depressed areas
               only. These grants require a 50% non-federal match.

               The U.S. Maritime Administration provides grants for comprehensive port
               planning. These  grants require a 50% non-federal match.

               The U.S. Department of Interior, under former heritage conservation and
               recreation servict programs, has urban park and recreation recovery grants.
               These may be used for redesign, and rehabilitation of existing public
               parks. These grants require a 30% non-federal match.

               The U.S. Army--Corps of Engineers has a harbor cleanup program. Its purpose
               is to improve channels for navigation.

               The U.S. Department of Housing and Urban Development has urban development
               action grants (UDAGs) which are designed to assist the private sector with
               urban redevelopment projects.   They may be used for residential, commer-
               cial, or industrial projects.

               The Michigan Waterways Commission makes grants for boat launch ramps,
               harbors of refuge, and public marinas.     A Waterways Commission grant was
               used for the new city marina.

               The U.S. Economic Development Administration also has a loan and loan
               guarantee program to assist private sector projects, in economically
               distressed areas.   Monies under this program may be used for land and
               building acquisition, machinery (process), construction, and rehabilita-
               tion. These loans require a 35% non-federal match.

               A few of the many foundation grants may be used for activities outside of
               the areas of the humanities, arts, and recreation.    These should be tapped
               for special arts and recreation activities.

                                                VII-18
<pb n="161" />

               Several foundation programs are development/redevelopment oriented.         The
               National Trust for Historic Preservation has been providing grants for
               preservation of historic marine vessels or maritime heritage in "signifi-
               cant" communities.   Typically, these are the focus of tourist and recre-
               ation activities.

               The National Trust for Historic Preservation, through its main street
               program, makes grants for the rehabilitation or adaptive reuse of historic
               structures.  The Star Watch Case facility is a candidate for this type of
               grant.

               The Audubon Society and other similar nature conservation groups have
               purchased land and established private nature parks.      The Pere Marquette
               Lake wetlands is a candidate for this type of foundation activity.

               The standard financial institutions - banks and mortgage companies, savings
               and loans, insurance companies, and retirement funds can play an important
               role in plan implementation.   Banks and mortgage companies make loans for
               residential, commercial, and industrial projects of all sizes. Savings and
               loans usually make loans only for individual residences; however, they can
               play an important role in the resale of a condominium project.       Insurance
               companies and retirement funds participate in large projects of all types.
               They usually do not participate in projects smaller than one or two million
               dollars.

               Various agencies have the authority to sell bonds to raise capital for
               projects. Bonds fall into two categories - general obligation and revenue.
               General obligation bonds are sometimes used to fund projects which benefit
               the community as a whole.   They usually require a vote of the people, and
               are paid off with general tax revenues.

               Revenue bonds are paid off with revenues raised by the project or by the
               benefitting  industry,  according to a repayment schedule..         With the
               assistance of a public agency issuing bonds, a private sector business or
               industry can get a loan at lower than market rates.

                                                VII-19
<pb n="162" />

              Public agencies which can issue revenue bonds include:             the City of
              Ludington, Pere Marquette Township, Mason County, the Ludington Economic
              Development Corporation, the Mason County Economic Development Corporation,
              and the Mason County Industrial Development Corporation.

              Another method of raising revenue for public improvements is tax increment
              financing.    In this situation, a public body pledges to use the new tax
              revenues, generated by certain private sector improvements, to develop
              public infrastructure benefitting that private sector industry. This is an
              "I will, if you will" approach. For example, a factory wants to expand but
              can't because the public water main to its factory is not large enough.
              Therefore, the factory will not expand until the water main is enlarged.
              Meanwhile, the city (or township) will not enlarge the water main until
              there is a real need, but it nevertheless would like to see the factory
              expand.   The solution is for both to agree to move ahead simultaneously,
              with the city using "borrowed" monies in anticipation of new tax revenues
              for repayment.

         b.   Land Acquisition Methods

              Land and buildings may be acquired or used under a variety of mechanisms.
              Each has its own advantages and disadvantages for meeting an owner's terms
              and a buyer's needs.

              The most direct means of obtaining property is to buy it outright.           This
              involves buying all or most of its associated rights including the right to
              resell it. Unless a "bargain sale" or gift is involved, it can be the most
              expensive.

              A second technique is called leasing.         Under this technique the owner
              "rents" property for a relatively long period, usually 20 years at minimum.
              The leasee has the responsibility for maintena'nce and may make major
              improvements to the property.      The property owner can include operations
              requirements in the lease and at the end of the lease period it reverts to
              the owner's use and control.      Leases are often used for temporary uses,
              where the owner expects a greater future value.

                                                 VII-20
<pb n="163" />

               A third technique is called land writedowns. Un,der this technique, a local
               government acquires blighted or run-down real estate through tax rever-
               sions, fee-simple purchase, and condemnation.        By clearing the land,
               assembling it into large tracts, or making other 'improvements, it increases
               its utility and, therefore, its value.    The government, however, sells or
               leases the land at below its new market value.        The purchase of these
               properties at depressed prices (due to blighting), acquisition of major
               parts through tax reversions, the creation of "new" land through road
               abandonments, and the condemnation of hold-out properties to assemble large
               tracts; usually permit the government to cover their costs while providing
               a private sector development opportunity. Michigan law permits the condem-
               nation of land in blighted areas for redevelopment purposes.       This is a
               very effective redevelopment tool. because often the private sector can not
               assemble a large enough parcel for a major user.

               ,A fourth technique for controlling the use of land is easement purchase.
               Historically, easements have been granted or sold for access or for utili-
               ties. Easements can be purchased for any of the many rights that come with
               property ownership.   Rece.ntly, e'asements have been granted for historic
               preservation of building facades, open space and natural area preservation
               or scenic vistas.   Easements may be temporary or permanent.     The propose@
               wetlands boardwalk'could transverse Dow Chemical's wetlands by easement.

               A fifth technique for.acq  uiring land is to trade for it.     Land is often
               exchanged in small amounts to increase the utility of a parcel. If surplus
               land is available, it can be an inexpensive way of gaining other needed
               land.

         C.    Development Incentives

               Some activities are intended to make development or redevelopment more
               attractive.   These can be grouped as financial        assistance, technical
               assistance, and the elimination of "red tape".

               Among the financial a  ssistance programs are the insured/guaranteed loan
               programs of the Small Business Administration and the Economic Development

                                                VII-21
<pb n="164" />

              Administration.  Under these programs a business or industry can qualify
              for a lower interest rate loan because of the backing of a government

              agency.

              Under Michigan law, a municipality may abate local property taxes for a new
              or enlarged business or industry.   This abatement may be for up to 50% of
              its taxes for a period of up to 12 years.     This has been widely used to
              encourage local community and industrial expansion.

              The Preservation and Tax Reform Act of 1976 provides for major tax credits
              for historic property rehabilitation. Section 2124 provides that a devel-
              oper may deduct, from his federal income tax, most of the costs for cer-
              tified rehabilitation of a "certified historic structure".     Recent amend-
              ments provide for a tax credit of up to 25% for certain rehabilitation.

              Many communities in Michigan have undertaken joint public/private develop-
              ment activities.   The Ludington public marina could be considered to fall
              within this category.   It is a public project which directly supports the
              local tourism and recreation industry.       The proposed public dry bulk
              terminal also fits into this category.

              Many local governments stand ready to offer technical assistance to new or
              expanding enterprises. A development coordinator, the most visible, helps
              secure grants or provides community facts. Sometimes cities hire a design
              firm to help downtown businessmen with storefront improvements, or the city
              engineer publishes important engineering data for all to use.        In some
              areas the local Chamber of Commerce or the electric power company also
              provide technical assistance to developers.

              A city's staff, particularly in the areas     of building and zoning codes,
              fire and life safety codes, and engineering   can greatly aid development by
              adopting a "work-with" attitude.    This need not be done at  the expense of
              proper and complete code enforcement.

                                               VII-22
<pb n="165" />

          4.   Zoning Ordinance and Map Review

          Zoning is an important tool for        implementing the plan, and will encourage
          orderly and compatibTe development    in accordance with the goals of the plan. It
          will also help to insure that the     best use is made of lands in the port area,
          and that the locational needs of potential investors in commercial or industrial
          facilities may be met.

          Several zoning changes were anticipated as a result of this plan.         A review of
          the-existing zoning map compared to the proposed Pere Marquette Lake Land Use
          and Port Plan has revealed differences that need to be addressed. Likewise, the
          zoning ordinance permitted uses are in some cases in conflict with the proposed
          plan.  The following discussion, for the City of Ludington and Pere Marquette
          Township separately, points out these differences and proposed zoning changes.

          a.   City of Ludington

               The proposed single and multiple family residential area          s next to the
               municipal marina currently are zoned M-R Motel Resort District which does
               not permit residentia-1 use.    This area should be rezoned according to the
               recommendations of the marina area neighborhood study.

               One area on the plan is noted as Commercial /Industrial.             The present
               Ludington zoning ordinance does not provide for mixed-commercial/industrial
               areas. Specific zoning for these areas should be-established as either C-2
               or C-3, depending on which development opportunity comes about.

               Currently, there are three RIB single-family residen       ce districts in the
               area shown on the plan as commercial. Wh-ile these areas are in the vicin-
               ity of the marine-transport zone, they are shielded by commercial develop-
               ment and do not present a problem to the plan.         No revisions are antici-
               pated at this time for those areas.

               The marine terminal and marine transport areas on the plan are currently
               zoned M-2, Heavy Industry. This zoning would provide for activities at the
               terminal and does not need to be modified.

                                                  VII-23
<pb n="166" />

              The Blount property (Western Concrete site) as discussed earlier would be
              an attractive site for seasonal condominium development or commercial
              development such as a hotel.     To encourage this type of development, a
              change from existing heavy industry zoning is necessary. ' This area should
              be rezoned either M-R or R-3 depending on the type of development oppor-
              tunity that comes about.

              Several other small areas, such as the downtown area in the city, are zoned
              in another category than shown on the plan but -do not present a conflict.
              The intent of the plan is to be flexible, allowing the character of exist-
              ing areas to remain and follow natural growth trends. For this reason, the
              plan will be more general than the actual zoning map, to encourage compati-
              ble development in surrounding areas and particular types of port-related
              development.

        b.    Pere Marquette

              The major area of conflict in Pere Marqu ette Township is the area currently
              zoned as Harbor Industry, which the plan identifies as a public use wet-
              lands park.  Zoning for this area will need to be changed to protect the
              area as a natural wetlands while permitting public access and compensating
              the owner for its use. The industrial disposal area where the lagoons are
              located needs to be identified separately so that its use does not conflict
              with the wetlands areas.     It is proposed that the areas designated as
              wetlands park be rezoned as conservation zone.

              The area south of the wetlands is designated as single family residential
              and is proposed to be developed as low-density single family residences
              (rural ranchettes).   Current zoning of this area is A-2, to promote res-
              idential and agricultural development.    The minimum lot size is one acre.
              This could be increased, up to five acres minimum size, at the Planning
              Commission's recommendation.

              While it appears that commercial -use of the Sand Products facility would
              require commercial zoning, in fact, when it is no longer used as a sand
              exporting terminal, it should be rezoned as A-2.     Under section 501:4 of
              the Pere Marquette zoning ordinance, certain commercial uses are permitted
              as a conditional use.

                                               VII-24
<pb n="167" />

          5.   Implementation Program

          This section details the overall implementation strategy of the responsibilities
          of a development coordinator, a specific marketing strategy, and other implemen-
          tation actions.   This section provides a "road map" for implementation as seen
          from a fall 1982 perspective. No doubt the actual implementation will encounter
          some detours. Hopefully, it will also find some short cuts.

          a.   Overall Strategy

               The overall implementation strategy is shown in Figure 37, Implementation
               Strategy.   It shows the critical path for implementation.      It begins with
               the Study Steering Committee's plan adoption.      Next the local legislati-ve
               bodies will need to consider and adopt the plan.       It is anticipated that
               input from the local planning commission and perhaps other advisory boards
               will be necessary.    The appointment of a lead agency for implementation
               follows.   This agency will have on-going responsibility for plan imple-
               mentation, including tasking responsibilities to other agencies.            Some
               implementation actions may be accomplished without direct lead agency
               involvement. The lead agency should try to involve the private sector.

               While these projects are in progress, the lead agency can be marketing the
               other development opportunities. A staff development coordinator would be
               most helpful in this task.     It is anticipated that the marketing program
               will be an on-going effort.     Likewise, each development project will move
               ahead at different rates through construction and into operation.,

               An important step in    the implementation of the development opportunities
               will be contacting the regulatory agencies which have authority over the
               proposed activities.    These agencies and their responsibilities are des-
               cribed in Section E.I., Agency Responsibilities.       Those activit-ies which
               involve construction of new commercial or recreational docks, dredging or
               filling, and other types of construction on or near the waterfront will be
               subject to complete review by the MDNR and U.S. Army Corps of Engineers.
               Regulations apply under the Michigan Inland Lakes and Streams Act and
               related laws regarding the amount and type of fill material which may be
               allowed, testing and disposal of dredged materials, etc.          The proposed

                                                 VII-25
<pb n="168" />

  mmm mm mm "Now w m m w

                                                                    8

                        2                                                                                 9               10

                                     5                         7                      .5

                       4                                                            8.6

                                     6
                                                6.2

                                                6.3

                                                6.4

                                                6.5

                                                6.6

            1. STEERING COMMITTEE ADOPTION             7. PROJECT MARKETING
            2. CITY COMMISSION ADOPTION                8. DEVELOPMENT PLAN COMMITMENTS
            3. TOWNSHIP BOARD ADOPTION                    8.1 DRYBULKTERMINAL
            4. COUNTY COMMISSION ADOPTION                 8.2 PETROLEUM TERMINAL
            5. LEAD AGENCY APPOINTMENT                    8.3 OFFICE COMPLEX
            6. RESPONSIBILITY TASKING                     8.4 HOTEL COMPLEX
               TOVARIOUSAGENCIES                          8.5 CONDOMINIUM COMPLEX
               6.1 ZONING AMENDMENTS                      8.6 MANUFACTURING FACILITY
               6.2 STATE/FEDERAL COORDINATION
                                                       9. PROJECT DEVELOPMENT&amp;
               6.3 WETLANDS PARK PROJECT                  CONSTRUCTION
               6.4 MARINA/RECREATION PROGRAMS         10. OPERATIONS                                           Figurer 37
                                                                                                         IMPLEMENTATION
               6.5 FERRY OPERATIONS
                                                                                                            STRATEGY
               6.6 PERE MARQUETTE LAKE                                                                   CITY OF LUDINGTON
                  ENVIRONMENTAL PROTECTION                                                            PORT DEVELOPMENT STUDY

          WILLIAMS A WORKS
<pb n="169" />

              location of recreational docking is to be reviewed by the MDNR Waterways
              Commission and the Michigan Department of Transportation.       Local regula-
              tions of the City of Ludington, Pere Marquette Township, and Mason County
              will also apply.

             -There is a great need for good inter-agency coordination.      This will have
              to be an on-going effort.       Each member of the lead agency should, be
              assigned a permanent responsibility for coordination with at least one
              other agency. This responsibility should include regular periodic meetings
              with the other agencies.

         b.   Lead Agency_

              A Pere Marquette Lake Commission seems-to be the most viable lead agency at
              this time.    It has several advantages in terms of local coordination,
              control, and environmental protection.     A lake commission could form the
              basis of a port authority.    The organization of a port authority could be
              effected at some later date when demand warranted or it could be organized
              to continue cross-lake ferry operations if the demand is sufficient. New
              opportunities should be monitored closely to determine as early as possible
              the need for a port authority. -

              The lake commission, or perhaps ultimately a port authority, should call
              upon any  resource or agency for assistance in developing the plan.         The
              agencies  discussed in Section E.2 of this chapter will be particularly
              helpful.

              Table 17 shows the annual operating budget for the Pere Marquette Lake
              Commission.   It includes the half-time services of a development coordi-
              nator, as Jt is presumed that this person's responsibilities will not be
              limited to Pere Marquette Lake projects.     While a development coordinator
              should not be a part-time employee, it is possible for a development
              coordinator to promote several projects at   a time.

              This budget provides a total of $6,000 for travel, advertising, and promo-
              tion.   These monies are conservatively estimated and are necessary for
              spreading the word about Ludington.

                                                VII-26
<pb n="170" />

                The commissioners meeting reimbursement has been arbitrarily set at $10 per
                meeting. Twelve members attending 18 meetings per year are budgeted.

                                                   Table 17

                                      Pere Marquette Lake Co  mmission
                                          Annual Operating Budget

                     Development Coordinator (1/2 time)                            $12,000
                         Fringe Benefits                                            3,600
                     Office Space                                                   5,000
                     Supplies and Postage                                           3,000
                     Travel                                                         4,000
                     Advertising and Promotion                                      2,000
                     Contract Services (accounting, legal, etc.)                    4,000
                     Commissioners Meeting Reimbursement
                          12 members, 18 meetings @ $10 each                        2,160

                                                   Total                           $35,760

          C.    Development Coordinator

                The position of Development Coordinator is a difficult one. A solid under-
                standing of the business world and real estate development are necessary.
                A development coordinator must be a "self-starter" and must meet people
                well.   A development coordinator must combine the qualities of a salesman
                with those of a diplomat to make projects happen. There is no one specific
                set of education/experience criteria which make up a good development
                coordinator. The key criteria seem to be experience in getting things done
                and industry contacts.

                The Development Coordinator should be the primary staff contact of the Lake
                Commission, although the Development Coordinator also works for the City
                Manager.   It should be the responsibility of the Development Coordinator to
                help with  all phases of a development project. Typically, this includes:

                        o  Information Development
                        o  Direct Marketing and Promotion
                        o  Marketing Assistance to Realtors
                        o  Development Proposal Review and Analysis
                        o  Grant and Financial Assistance
                        0  "Red-Tape" Cutting

                                                   VII-27
<pb n="171" />

               In short, the Development Coordinator locates a developer interested in a
               project which is viable in Ludington, helps him make the decision to
               develop in Ludington, and "runs interference".     Sometimes the Development
               Coordinator must bring together a group of divergent investors to make a
               project happen.

         d.    Marketing Strategy

               There are three basic approaches to marketing development opportunities
               such as those identified in Chapter VIII.       Each has its advantages and
               disadvantages and therefore the Development Coordinator must know when each
               is most appropriate.

               One approach is to advertise the advantages or opportunities of Ludington
               in industry publications.     This communicates these opportunities to a
               well-defined group of interested decision makers.      Using this technique,
               large geographic areas and many special interest groups can be reached.
               This approach can be used on the local scale (daily newspapers), the state
               scale (major metropolitan newspapers, West Michigan Magazine, etc.) or the
               national scale (the Wall Street Journal, industry magazines, etc.).

               A variation of this approach is to write feature articles describing the
               success or innovative approach of a recent project.      This article should
               make good use of the publicity to promote other projects.       Both of these
               approaches are inexpensive and get the information out to many people.
               This approach can, at best, spark some interest on the part of a developer.
               It is, however, a necessary step.

               The second basic approach is by the use of direct contacts. These contacts
               should be made by both the Development Coordinator and commercial /i ndus-
               trial realtors.  Both local and out-of-town realtors may be enlisted, on a
               commission basis.

               To the extent possible, these contacts should be targeted toward likely
               prospects.  Established personal relationships should be used where possi-
               ble, but the "cold" contacts should not be overlooked.

                                                VII-28
<pb n="172" />

                Although this approach is time-consuming and, therefore, costly, it is a
                requirement of any sizable project.          In difficult economic times it is
                especially necessary because it gives the Development Coordinator a chance
                to really sell Ludington.

                The third basic approach      is to solicit development proposals.        Under this
                approach potential developers are contacted either directly or indirectly
                and invited to submit a proposal for developing a certain piece of pro-
                perty.   The municipality supplies a "bid-package" of basic site informa-
                tion, economic data, and development potentials.             The developers submit
                their proposals, including jobs created, tax base expanded, and required
                development incentives (government-backed bonds, grants, tax abatement,
                etc.).    The municipality reviews all the proposals and selects the one
                which is best for the community as a whole.

                This approach works best in better economic       times, since it puts developers
                in competition with each other. In good economic times it is a very cost-
                effective technique. It can be held in reserve for future use.

          F.    RECOMMENDATIONS

          This section presents the studies recommendations and their reasons.               Rec.ommen-
          dations for both the harbor expansion feasibility study and the harbor land use
          plan are included.      No attempt has been made to prioritize these, recommenda-
          tions.    These recommendations are based upon the work completed by the consul-
          tants, - study steering committee input, the State of Michigan comments, and
          public input.

          The recommendations that are based on future development of land that is pri-
          vately owned are contingent on the availability and acquisition of that land.
          This study does not insure the availability or acquisition of these lands.

                                                     VII-29
<pb n="173" />

              CONSIDER HEAVY INDUSTRY ONLY IF A PROPOSAL IS PRESENTED BY A SPECIFIC
         INDUSTRY.   REVIEW DEVELOPMENT PROPOSALS AS THEY IMPACT SURROUNDING AREAS.          DO
         NOT ACTIVELY PROMOTE HEAVY INDUSTRY.

         Although the Feasibility Determination showed that certain heavy industries
         could be marginally feasible at Ludington, the active solicitation of these is a
         long and costly program.    The actual development of such a facility is a "long
         shot" un der the best of circumstances. The marginal feasibility, plus a lack of
         a local natural market or a local supply of raw materials, suggests that, even
         though such operations could be profitable at Ludington, these operations could
         be more profitable at other locations.

         In addition to these economic problems, there are environmental and land use
         problems associated with these facilities.       Even with the best environmental
         equipment, environmental problems of major consequence could cause significant
         public health problems.      Likewise, even minor environmental problems could
         degrade the quality of life, thus hurting the recreation and tourism industry.
         In addition, the harbor layout is such that the only place for a major indus-
         trial facility is the C&amp;O car ferry site.     This site is near downtown and prime
         recreation/tourism areas of Ludington. It is felt that such a facility would be
         inappropriate. Further, it would eliminate this site's availability for the car
         ferry or the in@egrated tug barge.

         2.   ENCOURAGE AND AID THE CONTINUANCE OF EXISTING WATERFRONT INDUSTRIES.

         The recommendation to not seek additional heavy industry should not be con-
         sidered as a negative attitude toward the existing heavy industries.             These
         industries which represent the status quo are the foundation of Ludington's
         economy. Since they operate year-round, they create a stabilizing influence on
         the area's economy.

         3.   ENCOURAGE AND AID THE CONTINUANCE OF EXISTING MARINE AND RECREATION RELATED
         COMMERCIAL, ESPECIALLY MARINAS, BOAT YARDS, HOTEL FACILITIES, AND TOURISM-
         ORIENTED COMMERCIAL.

         Tourism and recreation are important industries to Ludington.        They are proven
         to be successful and the new City Marina shows that the saturation point has not

                                                VII-30
<pb n="174" />

          yet been reached.     There is a demonstrated need for additional marina berths.
          Pere Marquette Lake has many opportunities for recreation/tourism development,
          yet many industrial -tourism land use conflicts exist.         Industrial and recrea-
          tion/tourism can co-exist, and each be improved, with proper planning. There is
          reason to believe that existing recreation/tourism industries have not been
          optimized to take full advantage of this opportunity.

          A national ly-known hotel complex would provide a magnet to draw visitors from a
          larger area.     A year-round facility, with convention facilities, would help
          eliminate the slow periods.     The Western Concrete site is an ideal location for
          a major hotel.

          4.    ENCOURAGE AND AID THE CONTINUANCE OF INTER-REGIONAL CROSS-LAKE RAILROAD AND
          PASSENGER SERVICES. EXPAND TRUCK TRANSPORT SERVICES.

          The importance of inter-regional traffic to Ludington has often been stated.
          The McMullen Study forecasts a solid future for cross-lake rail traffic.              It
          also forecasts a sizable cross-lake passenger volume.         The importance of this
          passenger traffic to the recreation/tourism industry in Ludington cannot be
          over-emphasized. Improved trailer/truck facilities, especially timely sailings,
          will support area industrial growth.

          Since Ludington is on the record as desiring to be the integrated tug barge home
          port, it follows that the Plan should give careful consideration to the needs,
          uses and implications of this facility.

          5.    ENCOURAGE AND PROMOTE WATER-RELATED, LIGHT INDUSTRIAL USES, SUCH AS
          PLEASURE BOAT BUILDING AND REPAIR.

          This Study did not focus on the myriad of light industries that could locate in
          Ludington, because they generally do not need waterborne transportation.             One
          exception to this is pleasure boat building.        Medium size boat builders often
          locate in a community because of non-quantifiable factors such as "quality of
          life".   Attracting such an industry, especially if coupled with a major repair
          facility, is a feasible objective for a city such as Ludington.

                                                   VII-31
<pb n="175" />

          6.   ENCOURAGE AND PROMOTE WATERFRONT OR NEAR-WATERFRONT DEVELOPMENT OF PROFES-
          SIONAL OFFICES, TECHNICAL RESEARCH FACILITIES, AND THE LIKE.

          Although   this study did not focus on the professional office and technical
          research facilities at or near the waterfront, Harbor Commission input indicates
          a strong desire to include these uses.         Historically, these uses have been
          successfully relocated to areas with a good quality of life rating.          A water-
          front or near-waterfront setting, with its choice views, can be the factor which
          determines where a company locates.      The area behind the C&amp;O Railroad facility
          and near downtown is a good location for these types of uses.         The Star Watch
          Case facility is an ideal facility for conversion.

          7.   ENCOURAGE AND PROMOTE A PUBLIC BULK MATERIALS TERMINAL FOR CONSTRUCTION
          AGGREGATES AND A PRIVATE BULK PETROLEUM PRODUCTS TERMINAL (GASOLINE, DIESEL
          FUEL, HEATING OIL).

          The Feasibility Determination shows the opportunity to develop a small scale
          public dry bulk materials terminal.        The present importers of construction
          aggregates would benefit from an improved facility and lower operating costs.

          Development of a limited facility (Phase I) is critical to the redevelopment of
          the North Lake and industrial area and the Western Concrete site.          The use of
          this terminal during Phase I will be limited to inert construction aggregates
          only.   If the market developed, then the terminal could be expanded as shown
          (Phase II).   Any materials other than inert aggregates which are proposed for
          shipment through the Phase II expanded terminal must be considered for their
          potential environmental impacts.      Certain improvements to the terminal under
          Phase II are anticipated, such as drainage diversion away from Pere Marquette
          Lake and stockpile covering to protect the lake and surrounding environment.

          A bulk petroleum terminal, developed by a private entity, could serve the
          hinterlands of Ludington (north of Muskegon, south of Frankfort, and west of
          Cadillac).

          8.   ENCOURAGE AND SUPPORT LAKE MICHIGAN AND PERE MARQUETTE LAKE ACTIVITIES AND
          EVENTS WHICH DRAW TOURISTS TO THE AREA.

          This recommendation is intended to support general recreation/tourism activities
          in the area.    Organized and advertised activities draw visitors to the area.
          They contribute to the activities which make Ludington popular.

                                                  VII-32
<pb n="176" />

         9.   DEVELOP THE SOUTHERN PORTION OF PERE MARQUETTE LAKE FOR LOW DENSITY
         RESIDENTIAL WITH NON-RESIDENTIAL FACILITIES TO SUPPORT THE NEIGHBORHOOD RESI-
         DENTS ONLY. -PRESERVE THE WETLANDS IN A SUBSTANTIALLY NATURAL STATE.

         Although some of the steep slopes in this area lend themselves to cluster type
         multi-family, there is not sufficient public infrastructure (roads, water,
         sewer, etc.) to support this level of development. This area, with some level
         areas, could be developed with large tract (about five acres) rural estates,
         despite the steep slopes in some places.

         Any non-residential development in this area should be limited to convenience
         commercial, sized to serve the needs of the immediate neighborhood only.        A
         small, limited service marina or gas dock also could be considered. . Churches
         and schools could be considered too.

         Preservation of the wetlands would be in keeping with state goals.      It would
         provide a buffer from the Dow disposal lagoons.    A nature park could also be
         developed.

         10. A PER-E MARQUETTE LAKE COMMISSION SHOULD BE ESTABLISHED AND TAKE LEAD AGENCY
         RESPONSIBILITY FOR PLAN IMPLEMENTATION

         A Pere Marquette Lake Commission, formed from the Ludington Harbor Commission,
         with representatives from the City of Ludington, Pere Marquette Township, and
         Mason County could provide fair representation to all local governmental units
         concerned with Pere Marquette Lake. It would have the ability to encourage plan
         implementa tion, but through financial dependency, would be controllable.

         11. ESTABLISH A PORT AUTHORITY, WHEN FUTURE NEED WARRANTS

         While a port authority can be an effective implementation agency, the level of
         activity in the Ludington Harbor does not justify it at this time.     This need
         could become real, however, if the C&amp;O car ferry operation is abandoned and if
         it becomes feasible for the city to operate it independently.    Therefore, cer-
         tain initial preparations could be justified by the Lake Commission.

                                              VII-33
<pb n="177" />

         12. APPOINT A DEVELOPMENT COORDINATOR

         A plan of this magnitude can not be implemented without the assistance of a
         professional staff person.  Volunteers can not be expected to implement this
         plan without day-to-day staff assistance.   The most effective marketing stra-
         tegy, direct contacts, require a professional staff person who is primarily
         concerned with implementation and development.

         13. ADOPT AND IMPLEMENT THE PLAN ACCORDING TO THE OVERALL IMPLEMENTATION

         STRATEGY CONTAINED IN SECTION E.5 OF THIS CHAPTER

         While the details of implementation may differ from those presented herein, it
         is not possible to fully implement the plan withbut the formal support of the
         Ludington City Commission, the Pere Marquette Township Board, or the Mason
         County Board of Commissioners. Likewise, without an agency taking lead respon-
         sibility for implementation, it is not probable that the plan will be either
         fully implemented or implemented on a timely, economical basis.

                                             VII-34
<pb n="178" />

                           Chapter VIII
             Development Opportunities
<pb n="179" />

                                              CHAPTER VIII
                                        DEVELOPMENT OPPORTUNITIES

          INTRODUCTION,

          In this chapter, the results of the feasibility determination (Chapter V) are
          presented in the form of a development prospectus for each identified opportu-
          nity.    Each prospectus contains a land development plan including a site
          layout.    The layout shows relationships to surrounding elements and to the
          harbor.    Site acquisition and development costs are also provided in the
          prospectus.

          The four commercial and recreational opportunities identified are:

          1.    Major hotel
          2.    Condominiums and recreation-oridnted commercial enterprise
          3.    Major office complex
          4.    Manufacturing facility

          There are two opportunities involving shipping:

          1.    Bulk petroleum products terminal
          2.    Dry bulk terminal (construction and road maintenance materials)
                a.   Phase I - initial operations (limited to inert aggregates only)
                b.   Phase II - expanded future operations

          Following  the prospectus for the bulk terminal opportunities is a brief summary
          of the information gathered during contacts with the prospective shippers.
          This information was used to demonstrate the potential for shipping various
          commodities into Ludington.

          The figure on the following page shows the location of the development opportu-
          nities with respect to the harbor and existing development.

                                                 VIII-1
<pb n="180" />

                                              N

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                                                                                                                                                31
                                                                                                        PROPOSED
                                                                                                        MANUFACTURING
                                                                                                        FACILITY    SITE

                                                          10
                                                                            LAK               U.

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                                                                                    Ist
                                                                                             PROPOSED        MAJOR       HOTEL
                                                                                    2no     SITE OR CONDOMINIUMS/
                                                                                  z
                                 z                                                0         RECREATION ORIENTLEC)
                                                                                                        COMME    RCIAL
                    PROPOSED          BULK
              MARINE TERMINAL SITE
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                                                                                                                    FIGURE 38

                                                                                                                  LOCATION OF
                                                                                                                  DEVELOPMENT
                                                                                                                OPPORTUNITIES
         -WILLIAMS a WORKS                                                                              Q5lo8Lrptj9a2
<pb n="181" />

                               A PROSPECTUS FOR THE

                                   DEVELOPMENT OF A

                                    MAJOR HOTEL IN
                  THE CITY OF LUDINGTON, MICHIGAN

                                               PREPARED FOR

                               THE     CITY OF LUDINGTON AND

                       THE LUDINGTON HARBOR COMMISSION

                                ALL INQUIRIES HELD IN STRICT CONFIDENCE

                                                                          WILLIAMS &amp; WORKS, INC.
                                                                                   September, 1982

                                                    VIII-2
<pb n="182" />

                                                                PROJECT DATA

                   LAND USE INFORMATION

                   Site Area        ...................................................................................................... 7.4 Acres
                   Land Use                Type                                                     Area                              Percent
                            0              Hotel and Restaurant                                     0.8 acres                             10%
                                           Efficiency Motel                                         0.3 acres                             4%
                                           Parking and Circulation                                  1. 3 acres                            18%
                                           Open Space                                               1. 7 acres                            23%
                                           Green Belt                                               0.5 acres                             7%
                                           Amenities                                                2.8 acres                             38%
                                                                                                    7.4 acres                         100%
                   Rental Units                Hotel - 14 rooms per floor times 7 floors plus 2 on first floor                 .... = 100 rooms
                                               Motel - 12 rooms per floor times 2 floors, efficiency type                  .......... = 24 rooms

                   ECONOMIC INFORMATION
                   Acquisition Cost            .......................................................................................... $474,000.
                   Less Area to Public Space (green belt)                        .......................................................... 24,000.
                                                                                                                                      $450,000.
                   SITE IMPROVEMENT COSTS
                   Demolish Existing Buildings                ....................................................................................... 21,000.
                   Earthwork        ..................................................................................................................... 55,000.
                   Pavements and Parking               ............................................................................................... 90,000.
                   Sewers, Water, Lift Station              ........................................................................................ 126,000.
                   Green Belt (rip-rap wall)             ............................................................................................. 12,000.
                   Marina, 42 slips          ......................................................................................................... 155,000.

                   CONSTRUCTION COSTS
                   Hotel, Resturant, Meeting Rooms                   ........................................................................ $5,000,000.
                   Enclosed Pools (2)          ...................................................................................................... 420,000.
                   Motel, Efficiency Type              ........................................................................................... 1,000,000.
                   Parking and Circulation             ............................................................................................. 165,000.
                   Landscaping          ............................................................................................................... 275,000.
                   Concessions         .................................................................................................................. 75,000.

                   Total Estimated Cost            ............................................................................................. $7,689,000.
                   Estimated hotel cost per square foot including resturant, meeting rooms,
                   pool, parking, roads, underground and landscaping                           .................................................. $68.07
                   Estimated motel cost per square foot including pool, parking, roads,
                   underground, landscaping and amenities                       ................................................................... $69.04
                   Estimated marina cost per slip                 ............................................................................... $7,524.00

                                                                                 VIII-3
<pb n="183" />

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                                                                                                                                                                           Mill

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                                                       LLLLJT-L

                                                              TYPICAL SITE LAYOUT
                                                                                            IVIII-4
<pb n="184" />

          PROSPECTUS                           This prospectus provides background information on the Ludington, Michigan area, Pere
          OBJECTIVES:                          Marquette Lake and harbor facilities, and the proposed hotel site. This information is intended
                                               as a resource for investors seeking an attractive and profitable location for a major hotel in Michi-
                                               gan's western Lower Pennisula.

          GENERAL                              The community of Ludington, with a 1980 populat                                   ion of 8937, is the commercial center of
          BACKGROUND:                          Mason County. Manufacturing currently provides over 60 percent of the area's employment.
                                               Located on the eastern shores of Lake Michigan, Ludington is also a major recreational hub of
                                               the region. Sport fishing, swimming, boating, hiking, snow skiing, and snowmobiling are among
                                               the popular outdoor activities that provide year-round enjoyment for both residents and tourists.
                                               New home construction costs in the Ludington area generally start at $60,000, while older homes
                                               are also available in favorable locations to fit various lifestyles. The West Shore Community
                                               College offers residents many special interest courses, training programs, workshops and lec-
                                               tures.

          HARBOR                               Ludingtion has a natural deep water year-round harbor which serves a variety of commercial
          FACILITIES:                          and recreational needs. Presently, approximately two million short tons annually are shipped
                                               through the harbor. The recently completed $5 million channel improvement project, under the
                                               guidance of the Army Corps of Engineers, has improved navigation in the port.

          SITE DESCRIPTION                     The land area available at the site is approximately 7.4 acres, located along the northeast shore
          &amp;INFORMATION:                        of Pere Marquette Lake. The information inside is provided for the typical site layout shown.

          BUSINESS                             The construction of new commercial facilities may lead the investor to a 50% exemption from
          INCENTIVES:                          the ad valorem property tax for 12 years, while restoration of obsolete facilities may lead to a
                                               100% exemption from ad valorem property taxes on the value of the improvements for 12 years.
                                               These incentives are provided forby Public Act 255 of 1978.

          STATE BUSINESS                       Michigan overhauled its business tax structure in 1976, replacing seven separate taxes with one
          TAXES:                               tax (known as the Single Business Tax). Businesses locating in Michigan, in effect, pay only
                                               2.35% in corporate income tax in place of the previous 7.8%. New business investment is re-
                                               garded under Michigan's tax laws with an immediate 100% write-off for all new personal prop-
                                               erty capital investments. Michigan is one of only sixteen states that do not levy a tax on inven-
                                               tories.

          TAX RATE:                            In Ludin ton and Pere Marquette Township the 1981 tax rate per $1,000 of equalized valuation
                                               is dividel as follows:

                                                        Ludington:                                                     Pere Marquette Township:
                                                        City ....................................................... 20.000 Township ................................................  1.000
                                                        School ................................................... 19.300 School ....................................................  19.300
                                                        County   ....................................................  4.876 County .....................................................  4.876
                                                        Special Voted    .........................................  3.799 Special Voted ..........................................  3.799

          INFORMATION
          SERVICES:                            For any of your informational services, please contact by phone or outline your needs and mail
                                               to one of the following:
                                                        City Manager                             Township Supervisor                          Development Coordinator
                                                        City of Ludington                        Pere Marquette Twp. Hall                     Mason County Bldg.
                                                        Municipal Bldg.                          1671 S. Pere Marquette Rd.                   Ludington, MI 49431
                                                        Ludington, MI 49431                      Ludington, MI 49431                          PH: (616)845-5407
                                                        PH: (616)845-6231                        PH:(616)845-1277

                                               ALL INFORMATION SERVICES PROVIDED AT NO COST TO POTENTIAL INVEST
                                               YOUR INQUIRY WILL BE PROCESSED IN COMPLETE PROFESSIONAL CONFIDENCE.

                                                                                                 VT T T -.1;
<pb n="185" />

                                    A PROSPECTUS FOR

         CONDOMINIUMS AND RECREATION ORIENTED

                        COMMERCIAL DEVELOPMENT IN

                  THE CITY OF LUDINGTON, MICHIGAN

                                              PREPARED FOR

                              THE CITY OF LUDINGTON AND

                      THE LUDINGTON HARBOR COMMISSION

                               ALL INQUIRIES HELD IN STRICT CONFIDENCE

                                                                         WILLIAMS &amp; WORKS, INC.
                                                                                  September, 1982

                                                  VIIT-6
<pb n="186" />

                                                                           PROJECT DATA

                           LAND USE INFORMATION

                           Site Area           ............................................................................................           7.4 Acres
                           Land Use                                Type                                            Area                                     Percent
                                                                   Residential                                     0. 7 acres                               19%
                                                                   Community Buildings                             0.4 acres                                5%
                                                                   Parking and Circulation                         1.3 acres                                18 %
                                                                   Amenities                                       0.1 acres                                1 %
                                                                   Open Space                                      3.7 acres                                41%
                                                                   Green Belt                                      1.2 acres                                16%
                                                                                                                   7.4 acres                                100%

                           Density                                 48 total dwelling units
                                                                   6.5 dwelling units per gross acre
                           Dwelling Units                          Units: 2 story condominium garden apartment
                                                                   Each apartment: 1250 square feet with 2 bedrooms

                           ECONOMIC INFORMATION
                           Acquisition Cost             ..........................................................................................    $474,000.
                           Less area to public space (green belt)                           ............................................................    76,000.
                                                                                                                                                      $398,000.

                           SITE IMIPROVEMEENT COSTS
                           Demolish Existing Buildings                        ..........................................................................    21,000.
                           Earthwork           ........................................................................................................     55,000.
                           Pavements and Parking                      ................................................................................      100,000.
                           Sewers, water, lift station                   .............................................................................      141,000.
                           Green Belt, Rip Rap Wall                      ...............................................................................    32,000.
                           Marina, 30 Slips              ............................................................................................       111,000.

                           CONSTRUCTION COSTS
                           Condominiums               .........................................................................................    $2,400,000.
                           Clubhouse and Restaurant                       .........................................................................   1,128,000.
                           Parking and Circulation                    ................................................................................      165,000.
                           Landscaping, pool                .........................................................................................       302,000.
                           Concessions            .....................................................................................................     75,000.
                           Total Estimated Cost                 ................................................................................   $4,817,000.

                           Estimated condominium cost per square foot
                           (including parking, roads, underground, landscaping)                                          .................................  $46.12
                           Estimated clubhouse cost per square foot
                           (including parking, roads, underground, landscaping)                                         ..................................  $87.88
                           Estimated marina cost per slip                        .......................................................................    $8,370.
                           Estimated condominium dwelling unit cost                                    ...............................................      $57,645.

                                                                                     VIII-7
<pb n="187" />

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                                                                TYPICAL SITE                                         LAYOUT
                                                                                                   rvi I @,- 8
<pb n="188" />

          PROSPECTUS                           This prospectus provides background information on the Ludington, Michigan area'                                                            Pere
          OBJECTIVES:                          Marquette Lake and harbor facilities, and the proposed condominium location. This information
                                               is intended as a resource for investors seeking an attractive residential and recreational develop-
                                               ment site in Michigan's western Lower Pennisula.

          GENERAL                              The community of Ludington, with a 1980 population of 8937, is the commercial center of
          BACKGROUND:                          Mason County. Manufacturing currently provides over 60 percent of the area's employment.
                                               Located on the eastern shores of Lake Michigan, Ludington is also a major recreational hub of
                                               the region. Sport fishing, swimming, boating, hiking, snow skiing, and snowmobiling are among
                                               the popular outdoor activities that provide year-round enjoyment for both residents and tourists.
                                               New home construction costs in the Ludington area generally start at $60,000, while older homes
                                               are also available in favorable locations to fit various lifestyles. The West Shore Community
                                               College offers residents many special interest courses, training programs, workshops and lec-
                                               tures.

          HARBOR                               Ludingtion has a natural deep water year-round harbor which serves a variety of commercial
          FACILITIES:                          and recreational needs. Presently, approximately two million short tons annually are shipped
                                               through the harbor. The recently completed $5 million channel improvement project, under the
                                               guidance of the Army Corps of Engineers, has improved navigation in the port.

          SITE DESCRIPTION                     The land area available at the site is approximately 7.4 acres, located along the northeast shore
          &amp; INFORMATION:                       of Pere Marquette Lake. The information inside is provided for the typical site layout shown.

          BUSINESS                             The construction of new commercial facilities may lead the investor to a 50% exemption from
          INCENTIVES:                          the ad valorem property tax for 12 years, while restoration of obsolete facilities may lead to a
                                               100% exemption from ad valorem property taxes on the value of the improvements for 12 years.
                                               These incentives are provided for by Public Act 255 of 1978.

          STATE BUSINESS                       Michigan overhauled its business tax structure in 1976, replacing seven separate taxes with one
          TAXES:                               tax (known as the Single Business Tax). Businesses locating in Michigan, in effect, pay only
                                               2.35% in corporate income tax in place of the previous 7.8%. New business investment is re-
                                               garded under Michigan's tax laws with an immediate 100% write-off for all new personal prop-
                                               erty capital investments. Michigan is one of only sixteen states that do not levy a tax on inven-
                                               tories.

          TAX RATE:                            In Ludin ton and Pere Marquette Township the 1981 tax rate per $1,000 of equalized valuation
                                               is divideg as follows:

                                                       Ludington:                                                       Pere Marquette Township:
                                                       City  ............................................... ...... 20.000 Township  ......................................  .........  1.000
                                                       School   ................................................... 19.300 School .................................................... 19.300
                                                       County     ....................................................  4.876 County  .....................................................  4.876
                                                       Special Voted      .........................................  3.799 Special Voted  ..........................................  3.799

          INFORMATION
          SERVICES:                            For any of your informational services, please contact by phone or outline your needs and mail
                                               to one of the following:
                                                         City Manager                             Township Supervisor                          Development Coordinator
                                                         City of Ludington                        Pere Marquette Twp. Hall                     Mason County Bldg.
                                                         Municipal Bldg.                          1671 S. Pere Marquette Rd.                   Ludington, MI 49431
                                                         Ludington, MI 49431                      Ludington, MI 49431                          PH: (616)845-5407
                                                         PH: (616)845-6231                        PH: (616)845-1277

                                               ALL INFORMATION SERVICES PROVIDED AT NO COST TO POTENTIAL INVESTORS.
                                               YOUR INQUIRY WILL BE PROCESSED IN COMPLETE PROFESSIONAL CONFIDENCE.

                                                                                                  VTTT-9
<pb n="189" />

                                 A PROSPECTUS FOR THE

                                     DEVELOPMENT OF A

                             MAJOR OFFICE COMPLEX IN
                   THE CITY OF LUDINGTON, MICHIGAN

                                                  PREPARED FOR

                                THE CITY OF LUDINGTON AND

                        THE LUDINGTON HARBOR COMMISSION

                                 ALL INQUIRIES HELD IN STRICT CONFIDENCE

                                                                              WILLIAMS &amp; WORKS, INC.
                                                                                        September, 1982

                                                       VT T T -10
<pb n="190" />

                                                               PROJECT DATA

                  LAND USE INFORMATION

                  Site Area        ........................................................................................... . ......... 4.5 Acres
                  Land Use                    Type                                      Square Feet             Area                 Percent
                                              Offices (three floors)                    33,300                  0.8 acres                18%
                                              Hotel                                     15,600                  0.4 acres                9%
                                              Restaurant                                  9,200                 0.2 acres                5%
                                              Parking and Circulation                   90,120                  2.1 acres                44%
                                              Amenities                                 47,800                  1.1 acres                24%
                                                                                                                4.5 acres             100%

                  ECONOMIC INFORMATION
                  Acquisition Cost            ..........................................................................................  $307,000.

                  SITE IMPROVEMENT COSTS
                  Demolish Existing Factory Buildings                    .....................................................................  ..105,000.
                  Demolish Existing Houses                ............................................................................................ 20,000
                  Earthwork.        .......................................................................................................................  3,000.
                  New Street Work            .......................................................................................................... 35,000.
                  New Sewers, Water              ...................................................................................................... 25,000.

                  CONSTRUCTION COSTS

                  Offices     ....................................................................................................................  $3,497,000.
                  Hotel     ........................................................................................................................  4,278,000.
                  Restaurant        ................................................................................................................... 800,000.
                  Parking and Circulation              ............................................................................................. 450,000.
                  Landscaping          ................................................................................................................. 80,000.
                  Total Estimated Cost            .............................................................................................  $9,600,000.

                  Hotel and Restaurant            .............................................................................................  $5,5089000
                  Offices     .....................................................................................................................  $4,092,000
                  Estimated new hotel cost per square foot including
                  parking, restaurant, and amenities                  .............................................................................. $75.57
                  Estimated remodeling building cost per square foot
                  including parking and amenities                   ................................................................................. $40.96

                                                                                viii-11
<pb n="191" />

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                                                      TYPICAL SITE LAYOUT
                                                                                  FVT T T -12 .1
<pb n="192" />

        PROSPECTUS                        This prospectus provides background information on the Ludington, Michigan area, Pere
        OBJECTIVES:                       Marquette Lake and harbor facilities, and the proposed office complex site. This information
                                          is intended as a resource for investors seeking an attractive and profitable office location in
                                          Michigan's western Lower Permisula.

        GENERAL                           The community of Ludington, with a 1980 population of 8937, is the commercial center of
        BACKGROUND:                       Mason County. Manufacturing currently provides over 60 percent of the area's employment.
                                          Located on the eastern shores of Lake Michigan, Ludington is also a major recreational hub of
                                          the region. Sport fishing, swimming, boating, hiking, snow skiing, and snowniobiling are among
                                          the popular outdoor activities that provide year-round enjoyment for both residents and tourists.
                                          New home construction costs in the Ludington area generally start at $60,000, while older homes
                                          are also available in favorable locations to fit various lifestyles. The West Shore Community
                                          College offers residents many special interest courses, training programs, workshops and lec-
                                          tures.

        HARBOR                            Ludingtion has a natural deep water year-round harbor which serves a variety of commercial
        FACILITIES:                       and recreational needs. Presently, approximately two million short tons annually are shipped
                                          through the harbor. The recently completed $5 million channel improvement project, under the
                                          guidance of the Army Corps of Engineers, has improved navigation in the port.

        SITE DESCRIPTION                  The land area available at the site is approximately 4.5 acres, located along the northeast shore
        &amp;INFORMATION:                     of Pere Marquette Lake. The information inside is provided for the typical site layout shown.

        BUSINESS                          The construction of new commercial facilities may lead the investor to a,50% exemption from
        INCENTIVES:                       the ad valorem property tax for 12 years, while restoration of obsolete facilities may lead to a
                                          100% @xemption from ad valorem property taxes on the value of the improvements for 12 years.
                                          These incentives are provided forbyPublic Act 255 of 1978.

        STATE BUSINESS                    Michigan overhauled its business tax structure in 1976, replacing seven separate taxes with one
        TAXES:                            tax (known as the Single Business Tax). Businesses locating in Michigan, in effect, pay only
                                          2.35% in corporate income tax'in place of the previous 7.8%. New business investment is re-
                                          garded under Michigan's tax laws with an immediate 100% write-off for all new personal prop-
                                          erty capital investments. Michigan is one of only sixteen states that do not levy a tax on inven-
                                          tories.
        TAX RATE:                         In Ludington and Pere Marquette Township the 1981 tax rate per $1,000 of equalized valuation
                                          is divide as follows:

                                                  Ludington:                                                Pere Marquette Township:
                                                  City ....................................................... 20.000 Township  ................................................  1.000
                                                  School ................................................... 19.300 School  .................................................... 19.300
                                                  County  ....................................................  4.876 County  .....................................................  4.876
                                                  Special Voted   .........................................  3.799 Special Voted  ..........................................  3.799

        INFORMATION
        SERVICES:                         For any of your informational services, please contact by phone or outline your needs and mail
                                          to one of the following:
                                                  City Manager                         Township Supervisor                       Development Coordinator
                                                  City of Ludington                    Pere Marquette Twp. Hall                  Mason County Bldg.
                                                  Municipal Bldg.                      1671 S. Pere Marquette Rd.                Ludington, MI 49431
                                                  Ludington, MI 49431                  Ludington, MI 49431                       PH: (616)845-5407
                                                  PH: (616)845-6231                    PH: (616)845-1277

                                          ALL INFORMATION SERVICES PROVIDED AT NO COST TO POTENTIAL INVESTORS.
                                          YOUR INQUIRY WILL BE PROCESSED IN COMPLETE PROFESSIONAL CONFIDENCE.

                                                                                      VIII-13
<pb n="193" />

                              A PROSPECTUS FOR THE

                                  DEVELOPMENT OF A

                       MANUFACTURING FACILITY IN

                 THE CITY OF LUDINGTON, MICHIGAN

                                             PREPARED FOR

                             THE CITY OF LUDINGTON AND

                      THE LUDINGTON HARBOR COMMISSION

                               ALL INQUIRIES HELD IN STRICT CONFIDENCE

                                                                       WILLI"S &amp; WORKS, INC.
                                                                                September, 1982

                                                VIII-14
<pb n="194" />

                                                                          PROJECT DATA

                         LAND USE INFORMATION
                         Site Area          ............................................................................................            6.0 Acres
                         Land Use                                Type                                            Area                                  Percent
                                                                 Industrial                                      4.5 acres                               75%
                                                                 Open Space                                      0.8 acres                               13%
                                                                 Public Streets                                  0.7 acres                               12%
                                                                                                                 6.0 acres                             100%

                         ECONOMIC INFORMATION
                         Acquisition Cost              ...........................................................................................  $346,000.
                         Less Area to Public Space                      ..............................................................................   86,000.
                                                                                                                                                    $260,000.

                         SITE IMPROVEMENT COSTS
                         Demolish Existing Buildings                        ..........................................................................   68,000.
                         Earthwork           ..........................................................................................................    7,000.
                         Relocated Street              ..............................................................................................    45,000.
                         Relocated Sewers, Water                      ................................................................................   48,000.
                         Green Belt (rip-rap wall)                    ................................................................................   32,000.

                         CONSTRUCTION COSTS
                         Manufacturing Plant                  ................................................................................    $1,330,000.
                         Offices       ............................................................................................................    318,000.
                         Service Facilities             ...........................................................................................    422,000.
                         Parking and Walks                  ........................................................................................   192,000.
                         Landscaping, Fencing                    ...................................................................................   150,000.
                         Total Estimated Cost                 ................................................................................    $2,872,000.

                         Estimated Building Cost per square foot                               ........................................................  $40.99
                         Estimated Amenities Cost per square foot of building                                         .................................. $ 7.41
                         Estimated Public Service Cost per square foot of building                                           ........................... $ 4.79
                         Estimated Land Cost per square foot of building                                     ..........................................  $ 5.15

                                                                                   VIII-15
<pb n="195" />

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                                              TYPICAL SITE LAYOUT
                                                                        IVITT-16
<pb n="196" />

        PROSPECTUS                        This prospectus provides background information on the Ludington, Michigan area, Pere
        OBJECTIVES:                       Marquette Lake and harbor facilities, and the proposed light-duty manufacturing site. This infor-
                                          mation is intended as a resource for investors seeking an attractive and profitable manufacturing
                                          site in Michigan's western Lower Pennisula.

        GENERAL                           The community of Ludington, with a 1980 population of 8937, is the commercial center of
        BACKGROUND:                       Mason County. Manufacturing currently provides over 60 percent of the area's employment.
                                          Located on the eastern shores of Lake Michigan, Ludington is also a major recreational hub of
                                          the region. Sport fishing, swimming, boating, hiking, snow skiing, and snowmobiling are among
                                          the popular outdoor activities that provide year-round enjoyment for both residents and tourists.
                                          New home construction costs in the Ludington area generally start at $60,000, while older homes
                                          are also available in favorable locations to fit various lifestyles. The West Shore Community
                                          College offers residents many special interest courses, training programs, workshops and lec-
                                          tures.

        HARBOR                            Ludingtion has a natural deep water year-round harbor which serves a variety of commercial
        FACILITIES:                       and recreational needs. Presently, approximately two million short tons annually are shipped
                                          through the harbor."The recently completed $5 million channel improvement project, under the
                                          guidance of the Army Corps of Engineers, has improved navigation in the port.

        SITE DESCRIPTION                  The land area available at the site is approximately 6 acres,-located along the northeast shore
      .&amp;.INFORMATION:                     of Pere Marquette Lake. The information inside is provided for the typical site layout shown.

        BUSINESS                          Construction of a new manufacturing facility could lead the investor to *a tax saving equivalent
        INCENTIVES:                       to 50% of the ad valorem property tax for 12 years. Property, such as land improvements, b
                                                                                                                                                                      'ul
                                          ings and structures, whether leased or owned, personal property, including machinery, equip-
                                          ment, furniture and fixtures would be eligible. Land and inventories are excluded. This incen-
                                          tive is provided by Public Act 198 of 1974.

        STATE BUSINESS                    Michigan overhauled its business tax structure in 1976, replacing seven separate taxes with one
        TAXES:                            tax (known as the Single Business Tax). Businesses locating in Michigan, in effect, pay only
                                          2.35% in corporate income tax in place of the previous 7.8%. New business investment is re-
                                          garded under Michigan's tax laws with an immediate 100% write-off for all new personal prop-
                                          erty capital investments. Michigan is one of only sixteen states that do not levy a tax on inven-
                                          tories.

        TAX RATE:                         In Ludington and Pere Marquette Township the -1981 tax rate per $1,000 of equalized valuation
                                          is divided as follows:

                                                  Ludington:                                                Pere Marquette Township:
                                                  City ....................................................... 20.000 Township  ................................................  1.000
                                                  School ................................................... 19.300 School  .................................................... 19.300
                                                  County   ............................................  .......  4.876 County  ......................................................  4.876
                                                  Special Voted   .........................................  3.799 Special Voted  ..........................................  3.799

        INFORMATION
        SERVICES:                         For any of your informational services, please contact by phone or outline your needs and mail
                                          to one of the following:
                                                  City Manager                         Township Supervisor                       Development Coordinator
                                                  City of Ludington                    Pere Marquette Twp. Hall                  Mason County Bldg.
                                                  Municipal Bldg.                      1671 S. Pere Marquette Rd.                Ludington, MI 49431
                                                  Ludington, MI 49431                  Ludington, MI 49431                       PH: (616)845-5407
                                                  PH: (616)845-6231                    PH:(616)845-1277

                                          ALL INFORMATION SERVICES PROVIDED AT NO COST TO POTENTIAL INVESTORS.
                                          YOUR INQUIRY WILL BE PROCESSED IN COMPLETE PROFESSIONAL CONFIDENCE.

                                                                                             VIII-17
<pb n="197" />

                        A PROSPECTUS FOR THE

                           DEVELOPMENT OF A

           MARINE PETROLEUM BULK TERMINAL IN

             THE CITY OF LUDINGTON, MICHIGAN

                                    PREPARED FOR

                        TH]E CITY OF LUDINGTON AND

                 THE LUDINGTON HARBOR COMMISSION

                        ALL INQUIRIES HELD IN STRICT CONFIDENCE

                                                         WILLIAMS &amp; WORKS, INC.
                                                                September, 1982

                                         VT T T -1,q
<pb n="198" />

                                                         PROJECT DATA

                   LAND USE INFORMATION
                   Site Area      .......................................................................................... 13.8 Acres
                   Land Use                        Type                                 Area                         Percent
                                                   Bulk Storage                           4.5 acres                    32%
                                                   Office and Facilities                  1.9 acres                    14%
                                                   Public Street                          0.9 acres                      6%
                                                   GreenBelt                              6.5 acres                    48%
                                                                                        13.8 acres                   100%

                   ECONOMIC INFORMATION
                   Acquisition Cost (approximate)             ................................................................. $300,000.

                   SITE IMPROVEMENT COSTS

                   New Street       ....................................................................................................... 90,000.
                   Sewer and Water          ............................................................................................. 48,000.
                   Dock Face Improvements              ............................................................................... 60,000.

                   CONSTRUCTION COSTS
                   Office    ............................................................................................................. $78,000.
                   Service Building        .............................................................................................. 48,000.
                   Parking and Loading Area             .............................................................................. 89,000.
                   Overhead Truck Loading Equipment                   ............................................................ 40,000.
                   Tanks and Appurtenances              ......................................................................... 2,525,000.
                   Tank Foundations          ......................................................................................... 875,000.
                   Earthwork (dikes)        ............................................................................................ 42,000.
                   Piping and Pumps          ......................................................................................... 104,000.
                   Metering and Miscellaneous Equipment                   ....................................................... 30,000.
                   Fencing     ............................................................................................................ 38,000.
                   Foam Extinguishing System              ........................................................................... 40,000.
                   Total Estimated Cost        ................................................................................ $4,407,000.

                   ANNUAL OPERATING COST ESTIMATE

                   Administration        ................................................................................................ 50,000.
                   Labor    ................................................................................................................ 60,000.
                   Retirement of Development Costs (20 years at 13 %)                     ................................ 627,000.
                   Operating Expenses (supplies and equipment)                     ............................................ 20,000.
                   Utilities   ............................................................................................................ 25,000.
                   Annual Estimated Operating Costs                ............................................................ $782,000.
                   Operating costs per gallon for
                   18,700,000 gallons annually            ............................................................................ $0.042

                                                              VIII-19
<pb n="199" />

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                                              TYPICAL SITE                          LAYOUT
                                                                       VFIII-20
<pb n="200" />

        PROSPECTUS                           This prospectus provides background information on the Ludington, Michigan area, Pere
        OBJECTIVES:                          Marquette Lake and harbor facilities, and the proposed bulk marine terminal location. This in-
                                             formation is intended as a resource for investors seeking a profitable marine petroleum terminal
                                             site in Michigan's western Lower Permisula.

        GENERAL                              The community of Ludington, with a 1980 population of 8937, is the commercial center of
        BACKGROUND:                          Mason County. Manufacturing currently provides over 60 percent of the area's employment.
                                             Located on the eastern shores of Lake Michigan, Ludington is also a major recreational hub of
                                             the region. Sport fishing, swimming, boating, hiking, snow skiing, and snowniobiling are among
                                             the popular outdoor activities that provide year-round enjoyment fbrboth residents and tourists.
                                             New home construction costs in the Ludington area generally start at $60,000, while older homes
                                             are also available in favorable locations to fit various lifestyles. The West Shore Community
                                             College offers residents many special interest courses, training programs, workshops and lec-
                                             tures.

        HARBOR                               Ludingtion has a natural deep water year-round harbor which serves a variety of commercial
        FACILITIES:                          and recreational needs. Presently, approximately two million short tons annually are shipped
                                             through the harbor. The recently completed $5 million channel improvement project, under the
                                             guidance of the Army Corps of Engineers, has improved navigation in the port.

        SITE DESCRIPTION                     The land area available at the site is approximately 13.8 acres, located along the northeast shore
        &amp;INFORMATION:                        of Pere Marquette Lake. The information inside is provided for the typical site layout shown.

        BUSINESS                             The construction of new commercial facilities may lead the investor to a 50% exemption from
        INCENTIVES:                          the ad valorem property tax for 12 years, while restoration of obsolete facilities may lead to a
                                             100% exemption from ad valorem property taxes on the value of the improvements for 12 years.
                                             These incentives are provided forby Public Act 255 of 1978.

        STATE BUSINESS                       Michigan overhaiiled its business tax structure in 1976, replacing seven separate taxes with one
        TAXES:                               tax (known as the Single Business Tax). Businesses locating in Michigan, in effect, pay only
                                             2.35% in corporate income tax in place of the previous 7.8%. New business investment is re-
                                             garded under Michigan's tax laws with an immediate 100% write-off for all new personal prop-
                                             erty capital investments. Michigan is one of only sixteen states that do not levy a tax on inven-
                                             tories.

        TAX RATE:                            In Ludington and Pere Marquette Township the 1981 tax rate per $1,000 of equalized valuation
                                             is divided as follows:

                                                      Ludington:                                                     Pere Marquette Township:
                                                      City ....................................................... 20.000 Township  ................................................  1.000
                                                      School  ................................................... 19.300 School  .................................................... 19.300
                                                      County   ....................................................  4.876 County  .....................................................  4.876
                                                      Special Voted    .........................................  3.799 Special Voted   ..........................................  3.799

        INFORMATION
        SERVICES:                            For any of your informational services, please contact by phone or outline your needs and mail
                                             to one of the following:
                                                      City Manager                             Township Supervisor                           Development Coordinator
                                                      City of Ludington                        Pere Marquette Twp. Hall                      Mason County Bldg.
                                                      MunicipalBldg.                           1671 S. Pere Marquette Rd.                    Ludington, MI 49431
                                                      Ludington, MI 49431                      Ludington, MI 49431                           PH: (616)845-5407
                                                      PH: (616)845-6231                        PH: (616)845-1277

                                             ALL INFORMATION SERVICES PROVIDED AT NO COST TO POTENTIAL INVESTORS.
                                             YOUR INQUIRY WILL BE PROCESSED IN COMPLETE PROFESSIONAL CONFIDENCE.

                                                                                               VIII-21
<pb n="201" />

          COMMODITY DATA

          Results of Bulk Shipping Terminal Contacts for Bulk Petroleum Terminal

          Summary

          A number of contacts were made with local distributors (jobbers), regional
          distributors, oil company representatives, professional organizations, and bulk
          users of petroleum products.   Most contacts reported that a marine petroleum
          terminal would typically be developed by a major distributor or an oil company,
          and thus public ownership would not be likely (although land could be leased).
          Most contacts reported that a thorough and detailed feasibility study would be
          necessary prior to consideration of this type of investment.      The petroleum
          distribution business is highly competitive; thus, rates, transportation costs,
          terminal fees, and profits were not revealed.

                                             VIII-22
<pb n="202" />

                             A PROSPECTUS FOR THE

                                 DEVELOPMENT OF A

                                  PHASE I OPERATION
                     MARINE DRY BULK TERMINAL IN
                THE CITY OF LUDINdTON, MICHIGAN

                                             PREPARED FOR

                             TEE CITY OF LUDINGTON AND

                     THE LUDINGTON HARBOR COMMISSION

                              ALL INQUIRIES HELD IN STRICT CONFIDENCE

                                                                       WulLUMS &amp; WORKS, INC.
                                                                                September, 1982

                                                 VTTT-23
<pb n="203" />

                                                                  PROJECT DATA

                     LAND USE INFORMATION

                     Site Area         ............................................................................................  2.5 Acres
                     Land Use                             Type                                        Area                              Percent

                                                          Railroad                                    0.3 acres                            12%
                                                          Open Stockpile                              0.6 acres                            24%
                                                          Open Space                                  1.6 acres                            64%

                                                                                                      2.5 acres                         100%

                     ECONOMIC INFORMATION

                     Dock Improvements
                     Replace One Mooring Bollard                      ........................................................................ $1,000.
                     Repair 25 Feet of Steel Sheetpile cap                       .................................................................  500.
                     Upgrade Existing Fender                  .....................................................................................  500.
                                                                                                                                           $2,000.

                     ANNUAL OPERATING COST ESTIMATE

                     Administration Costs                ........................................................................................ * 2,000.
                     Maintenence and Upkeep of Dock Face (labor and materials)                                         ...................... 1,000.
                     Retirement of Dock Improvement Costs (10 years at 13 %)                                      ..............................  370.

                     Property Rental Costs from C&amp;O Railaroad
                     (assessed at $0.50/ton for an estimated 12,000 tons annually)                                     ...................... 6,000.

                     Annual Estimated Operating Costs                        ................................................................ $9,370.
                     Operating costs per ton for 12,000 tons annually                               ........................................... $0.78

                                                                       VIII-24
<pb n="204" />

                                                                 500

                Duiuth                                               CA
                                                       300

                              a.- s.

                                                                                                                                                                  ve
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                                                                                                       X

         Ludington's northcentral location makes\
         midwest markets easily assessible' by
         truck.

                                                                                                                                               -------------
                                           U,5 10 1t1rvWr-4r--WAW 'ro CAKFO"'Y

                                             wMa                                          I I.-tmistrrams
                                                 4aw                   140AVIN            1        10 =2 T01411
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                                             16 FT. WAIWK POP114                                   OA9454- &amp;VOt fW1F
                                             AT OMOMTIPIL-0 MCK                       a              WiLdPAIVINCO
                                    f'roFJ-= MAKqUFTT5 "KM                                                                   447 F;T. -rO 4A9p%#M-e VWK

                                                      TYPICAL SITE LAYOUT

                                                                                    VT T T -25
<pb n="205" />

           PROSPECTUS                                     This prospectus provides background information on the Ludington, Michigan area, Pere
           OBJECTIVES:                                    Marquette Lake and harbor facilities, and the proposed dry bulk materials terminal. This infor-
                                                          mation is intended as a resource for investors seeking a profitable marine terminal site in Michi-
                                                          gan's western Lower Pennisula.

           GENERAL                                        The community of Ludington, with a 1980 population of 8937, is the commercial center of
           BACKGROUND:                                    Mason County. Manufacturing currently provides over 60 percent of the area's employment.
                                                          Located on the eastern shores of Lake Michigan, Ludington is also a major recreational hub of
                                                          the region. Sport fishing, swimming, boating, hiking, snow skiing, and snowinobiling are among
                                                          the popular outdoor activities that provide year-round enjoyment for both residents and tourists.
                                                          New home construction costs in the Ludington area generally start at $60,000, while older homes
                                                          are also available in favorable locations to fit various lifestyles. The West Shore Community
                                                          College offers residents many special interest courses, training programs, workshops and lec-
                                                          tures.

           HARBOR                                         Ludingtion has a natural deep water year-round harbor which serves a variety of commercial
           FACILITIES:                                    and recreational needs. Presently, approximately two million short tons annually are shipped
                                                          through the harbor. The recently completed $5 million channel improvement project, under the
                                                          guidance of the Army Corps of Engineers, has improved navigation in the port.

           SITE DESCRIPTION                               The land area available at the site is approximately 2.5 acres, located along the northeast shore
           &amp; INFORMATION:                                 of Pere Marquette Lake. The information inside is provided for the typical site layout shown.

           BUSINESS                                       The construction of new commercial facilities may lead the investor to a 50% exemption from
           INCENTIVES:                                    the ad valorem property tax for 12 years, while restoration of obsolete facilities may lead to a
                                                          100% exemption from ad valorem property taxes on the value of the improvements for 12 years.
                                                          These incentives are provided for by Public Act 2 55 of 1978.

           STATE BUSINESS                                 Michigan overhauled its business tax structure in 1976, replacing seven separate taxes with one
           TAXES:                                         tax (known as the Single Business Tax). Businesses locating in Michigan, in effect, pay only
                                                          2.35% in corporate income tax in place of the previous 7.8%. New business investment is re-
                                                          garded under Michigan's tax laws with an immediate 100% write-off for all new personal prop-
                                                          erty capital investments. Michigan is one of only sixteen states that do not levy a tax on inven-
                                                          tories.

           TAX RATE:                                      In Ludington and Pere Marquette Township the 1981 tax rate per $1,000 of equalized valuation
                                                          is divided as follows:

                                                                     Ludington:                                                                     Pere Marquette Township:
                                                                     City  ....................................................... 20.000           Township          ................................................  1.000
                                                                     School    ................................................... 19.300           School      .................................................... 19.300
                                                                     County     ....................................................  4.876         County       .....................................................  4.876
                                                                     Special Voted         .........................................  3.799         Special Voted           ..........................................  3.799

           INFORMATION
           SERVICES:                                      For any of your informational services, please contact by phone or outline your needs and mail
                                                          to one of the following:
                                                                     City Manager                                        Township Supervisor                                      Development Coordinator
                                                                     City of Ludington                                   Pere Marquette Tvrp. Hall                                Mason County Bldg.
                                                                     Municipal Bldg.                                     1671 S. Pere Marquette Rd.                               Ludington, MI 49431
                                                                     Ludington, MI 49431                                 Ludington, MI 49431                                      PH: (616)845-5407
                                                                     PH: (616)845-6231                                   PH: (616)845-1277

                                                          ALL INFORMATION SERVICES PROVIDED AT NO COST TO POTENTIAL INVESTORS.
                                                          YOUR INQUIRY WILL BE PROCESSED IN COMPLETE PROFESSIONAL CONFIDENCE.

                                                                                                                         VIII-26
<pb n="206" />

                              A PROSPECTUS FOR THE
                                  DEVELOPMENT -OF A

                                   PHASE II OPERATION
                     MARINE DRY BULK TERMINAL IN
                 THE CITY OF LUDINGTON, MICHIGAN

                                              PREPARED FOR

                              THE     CITY OF LUDINGTON                   AND

                      THE LUDINGTON HARBOR COMMISSION

                               ALL INQUIRIES HELD IN STRICT CONFIDENCE

                                                                        WILLIAMS &amp; WORKS, INC.
                                                                                 September, 1982

                                                   VIII-27
<pb n="207" />

                                                                      PROJECT DATA

                         LAND USE INFORMATION

                         Site Area        ..........................................................................................   13.8 Acres
                         Land Use                             Type                                          Area                            Percent
                                                              Public Streets                                1.0 acres                            7%
                                                              Open Storage and Facilities                   3.8 acres                          28%
                                                              Green Belt                                    2.3 acres                          16%
                                                              Open Space                                    6.7 acres                          49%
                                                                                                          13.8 acres                        100%

                         ECONOMIC INFORMATION
                         Acquisition Cost            .......................................................................................... $300,000.

                         SITE IMPROVEMENT COSTS

                         New Street          ....................................................................................................... 70,000.
                         Sewer and Water              ............................................................................................. 14,000.
                         Dock Face Improvements                    ............................................................................... 60,000.

                         CONSTRUCTION COSTS

                         Office      ........................................................................................................... $104,000.
                         Garage       ............................................................................................................ 108,000.
                         Parking Lot and Driveways                    ............................................................................ 91,000.
                         Truck Scales           .................................................................................................... 31,000.
                         Landscaping            .................................................................................................... 50,000.
                         Stockpile Covering and Drainage                       ................................................................... 50,000.
                         Total Site Improvement and Construction Costs                                ...................................... $578,000.

                         ANNUAL OPERATING COST ESTIMATE
                         Administration            ................................................................................................ 50,000.
                         Labor      ................................................................................................................. 40,000
                         Retirement of Site Improvement and Construciton Costs
                         (20 years at 13 %)            ............................................................................................ 82,000.
                         Property Rental Costs from C&amp;O Railroad assessed at
                         $0.50/ton for an estimated 64,000 tons annually                              .......................................... 32,000.
                         Operating Expenses (equipment, utilities and supplies)                                   ............................. 15,000.
                         Annual Estimated Operating Costs                         ............................................................. $219,000.
                         Operating costs per ton for 64,000 tons annually                               ...........................................  $3.42

                                                                          VIII-28
<pb n="208" />

                                                          3,0

                                                '00

                                                                     S if-
                                                L-1
                                                    0.

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                                                                                                                                                   A Vnj
                                                 C.@
             Kwom Pty    St. L-                                                                                                      PROPOSED
                                                                                                                                     MARINE DRY BULK TERMINAL

          Ludington's northcentral location makes
          midwest markets easily assessible by
          truck.

                                                                                                7       1 1       7

                                                                                      P&amp;-- V__Mwza T-16 M-7VAT01%. PP-PTH AM FWe-0
                                                                                                                                                     p-r -ro
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                                                           TYPICAL SITE LAYOUT
                                                                                         @T T @T-29
<pb n="209" />

         PROSPECTUS                           This prospectus provides background information on the Ludington, Michigan area, Pere
         OBJECTIVES:                          Marquette Lake and harbor facilities, and the proposed dry bulk materials terminal. This infor-
                                              mation is intended as a resource for investors seeking a profitable marine terminal site in Michi-
                                              gan's western Lower Pennisula.

         GENERAL                              The community of Ludington, with a 1980 population of 8937, is the commercial center of
         BACKGROUND:                          Mason County. Manufacturing currently provides over 60 percent of the area's employment.
                                              Located on the eastern shores of Lake Michigan, Ludington is also a major recreational hub of
                                              the region. Sport fishing, swimming, boating, hiking, snow skiing, and snowmobiling are among
                                              the popular outdoor activities that provide year-round enjoyment for both residents and tourists.
                                              New home construction costs in the Ludington area generally start at $60,000, while older homes
                                              are also available in favorable locations to fit various lifestyles. The West Shore Community
                                              College offers residents many special interest courses, training programs, workshops and lec-
                                              tures. .                                                                                                                                               I

         HARBOR                               Ludingtion has a natural deep water year-round harbor which serves a variety of commercial
         FACILITIES:                          and recreational needs. Presently, approximately two million short tons annually are shipped
                                              through the harbor. The recently completed $5 million channel improvement project, under the
                                              guidance of the Army Corps of Engineers, has improved navigation in the port.

         SITE DESCRIPTION                     The land area available at the site is approximately 13.8 acres, located along the northeast shore
         &amp;INFORMATION:                        of Pere Marquette Lake. The information inside is provided for the typical site layout shown.

         BUSINESS                             The construction of new commercial facilities may lead the investor to a 50% exemption from
         INCENTIVES:                          the ad valorem property tax for 12 years, while restoration of obsolete facilities may lead to a
                                              100% exemption from ad valorem property taxes on the value of the improvements for 12 years.
                                              These incentives are provided forbyPublic Act 255 of 1978.

         STATE BUSINESS                       Michigan overhauled its business tax structure in 1976, replacing seven separate taxes with one
         TAXES:                               tax (known as the Single Business Tax). Businesses locating in Michigan, in effect, pay only
                                              2.35% in corporate income tax in place of the previous 7.8%. New business investment is re-
                                              garded under Michigan's tax laws with an immediate 100% write-off for all new personal prop-
                                              erty capital investments. Michigan is one of only sixteen states that do not levy a tax on inven-
                                              tories.

         TAX RATE:                            In Ludington and Pere Marquette Township the 1981 tax rate' per $1,000 of equalized valuation
                                              is divided as follows:

                                                     Ludington:                                                       Pere Marquette Township:
                                                     city  ....................................................... 20.000 Township  ................................................  1.000
                                                     School   ................................................... 19.300 School  .................................................... 19.300
                                                     County    ....................................................  4.876 County  .....................................................  4.876
                                                     Special Voted      .........................................  3.799 Special Voted  ..........................................  3.799

         INFORMATION
         ,SERVICES:                           For any of your informational services, please contact by phone or outline your needs and mail
                                              to one of the following:
                                                       City Manager                            Township Supervisor                           Development Coordinator
                                                       City of Ludington                       Pere Marquette Twp. Hall                      Mason County Bldg.
                                                       Municipal Bldg.                         1671 S. Pere Marquette Rd.                    Ludington, MI 49431
                                                       Ludington, MI 49431                     Ludington, M! 49431                           PH: (616)845-5407
                                                       PH: (616)845-6231                       PH: (616)845-1277

                                              ALL INFORMATION SERVICES PROVIDED AT NO COST TO POTENTIAL INVESTORS.
                                              YOUR INQUIRY WILL BE PROCESSED IN COMPLETE PROFESSIONAL CONFIDENCE.

                                                                                                   VTTT-in
<pb n="210" />

          COMMODITY DATA

          Results of Bulk Shipping Terminal Contacts for Dry Bulk Terminal

          Background Information

          Sand is not a commodity which could feasibly be brought into a bulk terminal at
          Ludington, since it is a net exporter of sand.    Most contacts indicated they
          owned or were very near by their sand and gravel source.    Among the dry bulk
          commodities which might be feasibly brought into the port are:

          1.   Cement - Would not currently be feasible since the economy and construc-
               tion volume are so depressed. However, cement is currently obtained from
               Muskegon by truck and might feasibly be shipped to Ludington if the demand
               increased (economy improved or a large construction project is begun).

          2.   Seal Coat Chips - Would be feasible to ship in since use is fairly con-
               stant by County Road Commissions, although it is down somewhat during slow.

               economy.

          3.   Road Salt - Same as Seal Coat Chips.

          4.   Crushed Limestone - Is currently being brought into Ludington to two
               locations - Carey Docks and C&amp;O slip 1-1/2 (Laman Asphalt).

          5.   Agricultural Lime - Used as a fertilizer but mainly supplied by sand and
               gravel truckers. Might feasibly be shipped into Ludington.

          Results of Contacts: Total Number of Contacts = 15

          Summary

          A dry bulk terminal should be feasible, particularly since the port is cur-
          rently being used to bring in these items. Again, flexibility is important, as
          with fertilizers, to insure that, as shipping needs vary, the terminal will be
          able to receive a variety of commodities.

                                             VIII-31
<pb n="211" />

                           Appendix A
                  U idington Commodity
                           Flow Survey
<pb n="212" />

    ENGINEERS/PLANNERS/ARCHITECTS/SURVEYORS/GEOLOGISTS/CHEMISTS  611 CASCADE W. PKWY., S.E. P.O. BOX 6510, GRAND RAPIDS. MI 49506  PH:(616)942-9500

                                                             					WILLIAMS &amp; WORKS
                                                             T.O. WILLIAMS, 1961-1941  F.D. WORKS, 1880-1931  W.B. WILLIAMS. l895-1974

                                                                               March 8. 1982

            Dear Sir:

            The City of Ludington,, in cooperation with Pere Marquette Township, Mason County,
            and the Michigan Coastal Management Program, is studying the feasibility of ex-
            panded port utilization. If port expansion is warranted, a general development
            and management plan will be developed. Williams &amp; Works has been retained to
            assist in this project.

            Enclosed is a commodity flow survey which we would appreciate your taking a few
            minutes to fill out. A realistic understanding of your plans and needs is
            fundamental to the success of this study and the improvement of the Port of
            Ludington.

            Please return the completed survey,, to my attention, by March 19, 1982. Thank
            you for your cooperation.

                                                                   Yours truly,

                                                                   WILLIAMS &amp; WORKS

                                                                   David W. Landmann
                                                                   Project Manager

            Copy: Phyllis Ambrose, City of Ludington
                      Gordon Anderson, MDNR Coastal Zone Unit

            /sv
<pb n="213" />

                                LUDINGTON COMMODITY FLOW SURVEY

         INSTRUCTIONS:

         Complete part I once for your company as a whole.
         Complete part II for each different commodity (as distinguished by four-digit
         Standard Industrial Code) shipped or received.

         Leave blank any question which does not apply to your situation.

         Additional comments or questions are encouraged and may be directed to David
         Landmann, Williams &amp; Works, Inc. -- 616/942-9600.

                                            PART I

         A. GENERAL INFORMATION

         FIRM

         ADDRESS

         CONTACT PERSON                              TITLE

         PHONE NUMBER

         Please describe the general nature of your firm's business

         Standard industrial Code (SIC), if known

         Do you wish the responses to this survey to remain anonymous? YES- NO_

         B. PORT SELECTION

         Which port do you use?        Ludington      Other

         Who decides on-the transportation mode?

                         Local Plant Manager               Corporate Headquarters

                        Shipping Agent                     Other

                                               T-1
<pb n="214" />

          Who determines the shipping route or port of entry/exit?

                Local Plant Manager                   Corporate Headquarters

                Shipping Agent                        Other

          In choosing a shipping route or port of entry/exit, what information sources do
          you use?

                Your Port Experience                  Personal Port Visit

                Trade Books or Directories            Recommendation of Agent or Shippers

                Port Advertising or Promotional       Other
                Materials

          Why do you utilize the port(s) that you do?   Please rank the considerations below
          in priority order (1-highest, 2, 3, etc.). ignore those that are not important
          in your selection decision.

              a) Facilities                          b) Staff Services

              c) Security                            d) Consolidation Services

              e) Port Free Time Policies             f) Lack of Port Congestion

              g) Port Charges                        h) Inland Freight Rates

              i) Highway Linkages                    j) Railroad Linkages

              k) Pipeline Linkages                   1) Total Combined Costs

              m) Customs Service                     n) Sailing Schedule

              o) Shipping Lines                      P) Port Reputation

              q) Tradition                           r) Tax Advantages

              s) Last Port of Call                   t) Proximity to Plant/Raw Mat'ls.-

              u) Other

                                                1-2
<pb n="215" />

         C. LUDINGTON'S FACILITIES

         What deficiencies exist at the Port of Ludington?

              Harbor Entrance                       Channel Width/Configuration

              Channel Depth                         Turning Basin

              General Terminal Facilities           Specialized Terminal Facilities

              Administrative Organization           Land Side Expansion Area

              Facilities State of Repair            Inter-Modal Connections

              Security                              Port Reputation

              Rate Structure                        Other

         How many days have you lost to weather?

         What improvements could be made at the Port of Ludington which would benefit/
         increase your usage?

         How much would these improvements increase your tonnage shipped?

                                              1-3
<pb n="216" />

                                               PART II

          A. IMPORTS/EXPORTS

          Commodity (as imported)                                     sic

          Commodity (as exported)                                     sic

          If this commodity is only exported, proceed to Part    IIC.

          B. IMPORTS

                Year                              Tonnage          Origination

                1979

                1980

                1981

                1982 (projected)

                1985 (projected)

                1990 .(projected)

          What is the basis of these projections?

          What changes in technology, regulations, shipping rates, or the like would
          cause these projections to:

          Increase?

          Decrease?

          How confident are you in these projections?          % confident.

                                                TT-1
<pb n="217" />

          Are these imports... (please check one)

               shipped through Michigan?                distributed to Michigan's lower
                                                          peninsula

               remanufactured locally (water            Other
                side)?

          Is this commodity... (please check one)

               a finished product?          an intermediate product?           a raw material?

          How is (will be) this material rece    ived?

                                                   % Currently               % Near Future

                     bulk

                     neo-bulk

                     container

                     break bulk

          In what form is this commodity received?

               gaseous                         liquid                         solid

          C. EXPORTS

               Year                                Tonnage          Destination

               1979

               1980

               1981

               1982  (projected)

               1985  (projected)

               1990  (projected)

          What is the basis of  these projections?

                                                  11-2
<pb n="218" />

          What changes in technology, regulations, shipping rates, or the like would
          cause these projections to:

          Increase?

          Decrease?

          How confident are you in these projections?      % confident.

          Do these exports... (please check one)

              originate from outside Michigan?          originate from Michigan's lower
                                                         peninsula

              originate locally (water side)?           other

          Is this commodity... (please check one)

             ) a finished product?     ( ) an intermediate product?         a raw material?

          How is (will be) this material shipped?
                   bulk                         % Currently            % Near Future

                   neo-bulk

                   container

                   break bulk

          In what form is this commodity shipped?

              gaseous                             liquid                   solid

                                              11-3
<pb n="219" />

                                   LUDINGTON COMMODITY FLOW SURVEY

                                               TABULATION

                                                 PART I

                What port do you use?
                                                    NUMBER

                      Ludington                         2
                      None                              2

                      Other:
                         Escanaba                       1
                         U.S. Atlantic &amp;
                         Gulf Ports                     1
                         Alpena                         1
                         Grand Haven                    1

                         Milwaukee                      2

                         Montreal                       I
                         Charlevoix-St. James           I

                Who decides on the transportation mode?

                                                    NUMBER

                      Local Plant Manager               1
                      Shipping Agent
                      Corporation Headquarters          6
                      Other:
                         Location of Buyer              I
                         Traffic Department;
                         Headquarters, Pittsburgh       1
                         Michigan Department of
                         Management &amp; Budget            I
                         Customers                      2
                         Sales                          I
                         General Manager                1
<pb n="220" />

                 Who determines shipping route or port or entry/ exit ?

                                                    NUMBER

                      Local Plant Manager               1
                      Shipping Agent -
                      Corporation Headquarters          6
                      Other:
                          Location of Buyer             I
                          Traffic Department;
                          Headquarters, Pittsburgh      I
                          Michigan Department of
                          Management &amp; Budget           I
                          Customers   Vessel
                          Carrier                       1

                          Sales                         I

                 In choosing a shipping route or  port of entry/exit, what information
                 sources do you use?

                                                    NUMBER

                      Your Port Experience              5
                      Trade Books/Directories           3
                      Port Advertising                  I
                      Personal Port Visit               3
                      Recommendation of Agent/
                      Shippers                          3
                      Other:
                          Location of Buyer             I
                          Tarriffs                      I

                          Vessel Carrier &amp;
                          Customer                      1

                          Carriers                      I

                          Rate Factors                  I
<pb n="221" />

                 Why do you utilize the ports that you do?

                                                       lst    2nd    3rd     4th or Lower

                 a)  Facilities                          1      2      1           1
                 b)  Staff Services                                    1
                 c)  Security                                          1
                 d)  Consolidation of Services           1             1           1
                 e)  Port Free Time Policies                           1           1
                 f)  Lack of Congestion                         1                  2
                 g)  Port Charges                        1      1
                 h)  Inland Freight Rates                2      3      1           2
                 i)  Highway Linkages                    1      1      1           1
                 j)  Railroad Linkages                   2             1           2
                 k)  Pipeline Linkages                                 1
                 1)  Total Combined Costs                8             2
                 m)  Customs Services                                  1           1
                 n)  Sailing Schedules                   I      I      1           1
                 o)  Shipping Lines                      2             2           2
                 P)  Port Reputation                            1                  1
                 q)  Tradition                                         2
                 r)  Tax Advantages                                    I
                 s)  Last Port of Call                                 1
                 t)  Proximity to Plant/
                     Materials                           1      1                  3
                 u)  Other:
                        Custom  Docks                    I
                        Adequate Service                        I
                        Location                         I
<pb n="222" />

                 What deficiencies exist at the Port of Ludington?

                                                     NUMBER

                       Harbor Entrance
                       Channel Width/Configuration     I
                       Channel Depth                   1
                       Turning Basin
                       General Terminal Facilities
                       Special Terminal Facilities
                       Administrative Organization
                       Land Size Expansion Area
                       Facilities State of Repair
                       Inter-Modal      Connections
                       Security
                       Port Reputation
                       Rate Structure

                       Other:

                          Demand

                 How many days have you lost to weather?

                       NONE OR 1     2 - 3     4     5     6 OR MORE

                                       2
<pb n="223" />

               What improvements could be made at the Port of Ludington which would
               benefit/increase your usage?

                    Various comments made regarding the general economy
                    and shipping rates.

               How much would these improvements increase your tonnage shipped?

                    Various comments made regarding the general economy
                    and shipping rates.
<pb n="224" />

                                                PART I I

                 A. IMPORTS/EXPORTS
                                                    NUMBER

                     Commodity As Imported
                        Bulk Ice Control
                        Salt                           1
                        Woodpulp, Newsprint            I
                        Limestone
                        Components

                                                    NUMBER
                     Commodity As Exported

                        Iron Ore Pellets

                        Dead Burned
                        Magnesite
                        Sand
                        Buckwheat, Peas,
                        Birdseed
                        Appliances                     I
                        Frozen Fruit
<pb n="225" />

                 B. IMPORTS

                      TONNAGE                                  ORIGINS
                                                        U.S.         CANADA/
                    Year:  1979                       MID WEST       MEXICO

                        0 -  10,000
                 +10,000  -  20,000
                 +20,000  -  30,000
                 +30,000  -  40,000
                 +40,000  -  50,000
                 +50,000  -  60,000
                 +60,000  -  75,000
                 +75,000  -

                    Year:    1980

                        0 -  10,000
                 +10,000  -  20,000
                 +20,000  -  30,000
                 +30,000  -  40,000
                 +40,000  -  50,000
                 +50,000  -  60,000
                 +60,000  -  75,000
                 +75,000  -

                    Year:    1981

                        0 -  10,000
                 +10,000  -  20,000
                 +20,000  -  30,000
                 +30,000  -  40,000
                 +40,000  -  50,000
                 +50,000  -  60,000
                 +60,000  -  75,000
                 +75,000  -

                    Year:    1982

                        0 -  10,000
                 +1-0,000 -  20,000
re               +20 000  -  30,000
                 +30:000  -  40,000
                 +40,000  -  50,000
                 +50,000  -  60,000
                 +60,000  -  75,000
                 +75,000  -
<pb n="226" />

                         TONNAGE                                ORIGINS

                                                        U.S              CANADA/
                       Year:   1985                   MID WEST           MEXICO

                           0 - 10,000
                    +10,000  - 20,000
                    +20,000  - 30,000
                    +30,000  - 40,000
                    +40,000  - 50,000
                    +50,000  - 60,000
                    +60,000  - 75,000
                    +75,000  -

                       Year:   1990

                           0 - 10,000
                    +10,000  - 20,000
                    +20,000  - 30,000
                    +30,000  - 40,000
                    +40,000  - 50,000
                    +50,000  - 60,000
                    +60,000  - 75,000
                    +75,000  -
<pb n="227" />

                Are these imports . . .              NUMBER

                      shipped through Michigan?
                      distributed to Michigan's
                      lower Peninsula?
                      remanufactured at waterside?     1
                      utilized locally?

                 Is this commodity . . .
                                                     NUMBER

                      a finished product?
                      an intermediate product?
                      a raw material?                  2

                 How is/will be this material be received?

                                               CURRENTLY.

                                    0 - 25%    26 - 50%    51   75%   76 - 100%

                      Bulk                                               2
                      Neo-Bulk
                      Container

                      Break Bulk

                                                  FUTURE

                                     0 - 25%   26 - 50%    51   75%   76 - 100%

                      Bulk                                               2
                      Neo-Bulk

                      Container

                      Break Bulk

                In what form is this commodity received?
                                                   NUMBER
                     Gaseous
                     Liquid
                     Solid                           3
<pb n="228" />

                   C.   EXPORTS

                        TONNAGE                          DESTINATION
                                          U.S.  EAST    EUROPE/U.S.S.R.     S. AMERICA

                        Year:  .1979
                          0   -10,000
                    +10,000   -20,000
                    +20,000   -30,000                           1
                    +30,000   -40,000
                    +40,000   -50,000
                    +50,000   -60,000
                    +60,000   -75,000
                    +75,000   -

                        Year:   1980
                          0   -10,000
                    +10,000   -20,000
                    +20,000   -30,000
                    +30,000   -40,000
                    +40,000   -50,000
                    +50,000   -60,000
                    +60,000   -75,000
                    +75,000   -

                        Year:   1981
                          0   -10,000
                    +10,000   -20,000
                    +20,000    30,000
                    +30,000    40,000
                    t40,OOO    50,000
                    +50,000    60,000
                    +60,000    75,000
                    +75,000

                        Year:   1982
                          0   -10,000
                    +10,000   -20,000
                    +20,000   -30,000
                    +30,000   -40,000
                    +40,000   -50,000
                    +50,000   -60,000
                    +60,000   -75,000
                    +75,000   -
<pb n="229" />

                       TONNAGE                        DESTINATION
                                       U.S. EAST     EUROPE/U.S.S.R.     S. AMERICA

                       Year: 1985
                         0 -10,000
                  +10,000  -20,000
                  +20,000  -30,000
                  +30,000  -40,000
                  +40,000  -50,000
                  +50,000  -60,000
                  +60,000  -75,000
                  +75,000  -

                       Year: 1990
                         0 -10,000
                  +10,000  -20,000
                  +20,000  -30,000
                  +30,000  -40,000
                  +40,000  -50,000
                  +50,000  -60,000
                  +60,000  -75,000
                  +75  000 -
<pb n="230" />

                What is the basis of these projections?

                                                   NUMBER

                      Historic Use                    1
                      Discussion With Shippers        1

                What changes in techno,logy, regulations, shipping rates, or the like
                would cause these projections to:...

                                                   NUMBER
                      INCREASE.;
                         In Paved Road Mileage        1
                         Rail-Water, Rail-
                         Intermodal Rate
                         Reductions                   I

                         Steel Business Increase

                         Construction
                         More Competitive Rates       1

                      DECREASE:
                         Regulation Prohibiting
                         Sodium Chloride

                         Steel Business Decrease      I

                How confident are you in these projections?
                                                   NUMBER

                      100% - 90%                      1
                       89% - 80%                      2
                       79% - 70%
                       69% - 60%
                       59% - 50%
                       49% or less
<pb n="231" />

                 What is the basis of these projections?

                                                    NUMBER
                      Economic Forecasts,
                      Test Competition
                      Estimates

                 What changes in technology, regulations, shipping rates, or the
                 like would cause these projections to:
                      INCREASE:                     NUMBER
                         New Source of Foundry
                         Sand                          I

                         Better Port Facilities        I

                      DECREASE:

                 How confident are you in these projections?

                                                    NUMBER

                      100% - 90%

                       89% - 80%
                       79% - 70%                       1

                       69% - 60%

                       59% - 50%                       1

                       49% or less

                 Are  these exports                 NUMBER

                      originated outside
                      Michigan?                        2
                      originated from Michigan's
                      Upper Peninsula?
                      originated locally (water        3
                      side)?
<pb n="232" />

                                                    NUMBER

                      Other:
                        lower Peninsula?                2

                        several states?

                  Is this commodity . .
                                                    NUMBER

                      a finished product?               1
                      an intermediate product?          2
                      a raw material?                   3

                  How is/will be this  material be received?

                                                CURRENTLY

                                    0   25%   26 - 50%    51   75%   76 - 100%
                      Bulk                        1                     3

                      Neo-Bulk
                      Container                   1                     2
                      Break Bulk      2                                 1

                                                  FUTURE

                                    0   25%   26  - 50%   51   75%   76 - 100%

                      Bulk

                      Neo-Bulk

                      Container
                      Break Bulk

                  In what form is this commodity reci   eved?

                                                     NUMBER

                      Gaseous
                      Liquid
                      Solid                             5
<pb n="233" />

        LUDINGTON CZM SURVEY MAILING LIST

          335 -
        A. Lindberg &amp; Sons, Inc.
        560 Mather Ave.
        Ishpeming, MI 49849

          276 - Albert Meeusen
        A&amp;C Carriers, Inc.
        2909 E. Laketon Ave,
        Muskegon, MI 49442

            1 - Brian D. Gibbon
        Abitibi Paper Co. Ltd
        P.O. Box 2990
        Thunder Bay, Ontario, Canada

            2 - H.G.E. Portch
        Abitibi Paper Co. Ltd
        Toronto-Dominion Center
        Toronto, Ontario, Canada

            3 - J.E. Wilbee
        Abitibi Paper Co. Ltd
        408 University Avenue
        Toronto, Ontario, Canada

            4 - M.H. Brown
        Agrico Chemical Co.
        P.O. Box 750
        Saginaw, MI 48606

            5 - D.W. Newbauer
        Agrico Chemical Co.
        P.O. Box 522, Saginaw Term.
        Carrollton, MI 48724

            6 -
        Air Express International Agency
        29300 Goddard Road
        Romulus, MI 48174

            7 - Ralph J. Nero
        Airco Alloys &amp; Carbide
        3801 Highland Avenue
        Niagara Falls, NY 14305

            8 - Benjamin Bigelow
        Albumina Supply Co.
        82 Beaver Street
        New York, NY 10005

            9 - Ronald W. Hawkins
        Alcoa Company of America
        Alcoa Building
        Pittsburgh, PA 15219
<pb n="234" />

         LUDINGTON CZM SURVEY MAILING LIST                                              2

            10 - Warren Steckmert
         Alcoa Steamship Co.
         17 Battery Place
         New York, NY 10004

            11 - Kurt Konodi-Floch
         Alltransport Inc.
         300 South Wacker Drive
         Chicago, IL 60606

            12 - Eric F. Tiegerman
         Alox Corporation
         3943 Buffalo Avenue, Box 556
         Niagara Falls, NY 14303

           293
         Alpena Aggregate, Inc.
         7590 Weiss Road
         Alpena, MI 49707

           294
         Alpena County Road Commission
         1400 N. Bagley
         Alpena, MI 49707

            13
         Altransco
         4461 West Jefferson
         Detroit, MI 48209

            14 - Niels H. Christensen
         Am-Can Transport Inc.
         P.O. Box 412
         Westmont, IL 60559

            15
         Amerford International Corp.
         27130 Trolley Industrial
         Taylor, MI 48180

           295
         American Aggregates Corporation
         Drawer 160
         Greenville, OH 45331

            16 - John P. Martell
         American Can Company
         American Lane
         Greenwich, CT 06830

            17 - Ed Hora
         American Can Company
         P.O. Box 702
         Neenah, WI 54956
<pb n="235" />

         LUDINGTON CZM SURVEY MAILING LIST                                                   3

            18 -
         American Marine Supply
         15 Ferris Street
         Highland Park, MI 48203

           260
         American Mexican Petroleum Corp.
         123 N. Northwest Highway
         Park Ridge, IL 60068

            19 - Leonard C. Kropp
         American Motors Cop.
         14250 Plymouth Road
         Detroit, MI 48232

            20 -
         American President Line
         24800 Northwestern SU400B
         Southfield, MI 48075

            21 - Louis E. Ervin
         American Steamship Co.
         Marine Tower
         Buffalo, NY 24203

            22 - Alex Greten
         Amerlux Steel Products Co.
         100 Park Avenue
         New York, NY 10017

            23 -
         Amerny Shipping Agency
         1 World Trade Center, #2743
         New York, NY 10048

           261 - L. F. Schnake
         Amoco Oil Co./Fertilizer District
         200 East Randolph Dr., MC 3303
         Chicago, IL 60680

            24 - John J. McDonough
         Anaconda Company
         25 Broadway
         New York, NY 10004

            25
         Anchor Line/Chester, Blackburn
         1 Word Trade -Center, #1067
         New York, NY 10048

            26 -
         Anderson Steamship Agency
         23400 Michigan Avenue
         Dearborn, MI 48214
<pb n="236" />

         LUDINGTON CZM SURVEY MAILING LIST                                                  4

            35 -                                                                                      I
         Anglo Dutch Shipping/World Shipping
         13530 Michigan; Room 210
         Dearborn, MI 48136

            27 - Norman D. Hilger
         Ansul Company
         One Stanton Street
         Marinette, WI 54143
            28 -                                                                                      I
         Anticost Shipping Co.
         800 Dorchester Blvd.
         Montreal, Quebec, Canada

            29
         Arctic Line/Int'l Great Lakes Ship'g
         4461 West Jefferson
         Detroit, MI 48209
           333 -                                                                                      I
         Arenac County Road Commission
         116 Bridge Street
         Omer, MI 48749

            31
         Argentine Line/Shipping Ltd
         410 St. Nicholas Street
         Montreal, Quebec, Canda
            32 -                                                                                      I
         Armada Line/Tolmar Int'l
         20600 Eureka Road
         Taylor, MI 48180

            30
         Artic Steamship Line/March Ship'g Ltd
         400 Craig Street West
         Montreal, Quebec, Canada

            33 - William T. Pierce
         Associated Coat. Transport
         90 West Street
         New York, NY 10006

            34 -
         Associated Container Transport
         410 St. Nicholas Street
         Montreal, Quebec, Canada
            36 -                                                                                      I
         Atlantic Coast Agencies
         17 Battery Place North
         New York, NY 10004
<pb n="237" />

         LUDINGTON CZM SURVEY MAILING LIST                                                 5

            37 -
         Atlantic Container Line
         80 Pine Street
         New York, NY 10005

            38 -
         Atlantic Container Line
         465 St. Johns Street
         Montreal, Quebec, Canada

            39
         Atlantic Line &amp; Nav/Azure Agencies
         PO Box 127
         Detroit, MI 48218

           262 - C. P. Oonk
         Atlantic Richfield Co./Michigan-West
         1134 Post Ave.
         Hollandy Michigan 49423

            40
         Atlantica Line/Shipping Limited
         410 St, Nicholas Street
         Montreal, Quebec, Canada

            41
         Atlanttrafik Express/March Ship'g Ltd
         400 Craig Street West
         Montreal, Quebec, Canada

            42 -
         Azure Agencies, Inc.
         P.O. Box 127
         Detroit, MI 48218

           296 -
         B&amp;K Sand &amp; Gravel
         Route #1
         Wallace, MI 49893

            43
         B&amp;K Shipping Agency
         465 St. Johns Street
         Montreal, Quebec, Canada

            44 -
         Baltic Steamship/March Shipping Ltd
         400 Craig Street West
         Montreal, Quebec, Canada

            45 - Harry K. Barr
         Barr Shipping Company
         44 Beaver Street
         New York, NY 10004
<pb n="238" />

         LUDINGTON CZM SURVEY MAILING LIST                                                6

            46 - Edward Ladd
         Beaver Island Boat Co.
         Charlevoix, MI 49720

           299 -
         Bedrock Aggregates
         4225 W. Columbia Road
         Mason, MI 48842

           300 -
         Beeman Trucking &amp; Bulldozing Co.
         Route #1
         Grawn, MI 49637

            47 - Freuland
         Belgian Line Inc.
         5 World Trade Center
         New York, NY   10048

            48 - Shadi  L. Katyal
         Bemis Company  Inc.
         800 Northstar  Center
         Minneapolis, MN 55402

            49 - Michael B. Tillander
         Bendix Corporation
         Bendix Center
         Southfield, MI 48076

            50 - Richard S. Bennett
         Bennett, R.S. &amp; Co.
         6869 W. Grand River Avenue
         Lansing, MI 48901

           301
         Bichler Gravel &amp; Concrete Co.
         Box 263
         Escanaba, MI 49829

            51 - Louis F. Gallina
         Black &amp; Geddes, Inc.
         11 Broadway
         New York, NY 10004

            52

         400 Craig Street West
         Black Sea Canada/March Ship'g Ltd

         Montreal, Quebec, Canada

            53 - Ms. Margaret Buchmann
         Blue Line Coal Co.
         975 Hansen Road
         Green Bay, WI 54304
<pb n="239" />

         LUDINGTON CZM SURVEY MAILING LIST                                                 7

            54 - Reford
         Blue Star Line/Robt Reford Co, Inc.
         221 St. Sacrement Street
         Montral, Quebec, Canada

           302 -
         Blumke Excavating Co., Inc.
         Box 126A
         Alanson, MI 49706

            55 - James A. Lehnen
         BMV Manufacturing Co. Ltd
         Whalley St; PO Box 130
         Milverton, Ontario, Canada

            56 - James J. Wagner
         Boland &amp; Cornelius
         Marine Trust Bldg
         Buffalo, NY 14203

           263 - Leo V. Dalton
         Boron Oil Company
         1872 Guild Hall Building
         Cleveland, Ohio 44115

            57
         Braemar Shipping Ltd
         1 Westmount Square
         Montreal, Quebec, Canada

            58 - Don Brent
         Brent Manufacturing, W.D., Ltd
         Elmbank Road
         Malton, Ontario, Canada

            59 - Emlen G. Hare
         Breton Agencies Ltd
         PO Box 2290
         Halifax, Nova Scocia,, Canada

           304 -
         Brewers City Dock, Inc.
         24 Pine Avenue
         Holland, MI 49423

            6o -
         British Steel Corp./Kerr Steamship
         1420 Parklane Towers East
         Dearborn, MI 48126

           307 -
         Brownell Sand &amp; Gravel Co.
         14020 Morley Road
         Manitou Beach, MI 49253
<pb n="240" />

         LUDINGTON CZM SURVEY MAILING LIST                                             8

            61 - F.D. Fountain
         Budd Company
         Corporate Office
         Troy, MI 48084

            62 - Joseph S. Baranoski
         Budde &amp; Westermann
         350 Broadway
         New York, NY 10013

           340 -
         Budzen Cement Products, Inc.
         Route #1
         Paw Paw, MI 49079

            63 - Ron Bublick
         Bultema Marine Transportation
         559 E. Western Ave, Box 728
         Muskegon, MI 49443

            65
         Canada Orient Line
         637 Craig Street West
         Montreal, Quebec, Canada

            66
         Canada Pacific Steamship
         Place DU Canada
         Montreal, Quebec, Canada

            67 - F.A. Bennett
         Canada Steamship Line
         7 Port Street East
         Port Credit, Ontario, Canada

            68
         Canada Steamship Line
         759 Victoria Square
         Montreal, Quebec, Canada
            69 -                                                                                 I
         Canfreight Containers
         300 St. Sacrement Street
         Montreal, Quebec, Canada

            70 - B.R. Carney
         Carborundum Int Sales
         PO Box 337
         Niagara Falls, NY 14302

            71 - Bruce Weinardt
         Cargill
         Maumee, OH
<pb n="241" />

         LUDINGTON CZM SURVEY 14AILING LIST                                                  9

            72 -
         Carson M. Simon &amp; Co.
         209-211 Chestnut St,
         Philadelphia, PA 19106

           308 -
         Cash &amp; Carry Gravel Co.
         P. 0. Box 1105A
         Holland, MI 49423

           309 -
         Caspian Construction Co.
         100 W, Caspian
         Caspian, MI 49115

            73 -
         Cast North America Ltd
         East Tower, #521
         Rolling Meadows, IL 60008

            74
         Cast North America Ltd
         PO Box 1954 A
         Detroit, MI 48232

            75 -
         Cast Ship Services/Hasserodt Marine
         28430 Swan Island Dr.
         Grosse Ile, MI 48138

            64 - Jim Mueller
         CCI Forest Product
         Iron Mountain, MI 49801

            76 - David LeBoeuf
         Cedar River Lumber Co
         PO Box 151
         Powers, MI 49874

            77 - William Kreckman
         Champion International
         2250 Wabash Avenue
         St. Paul, MN 55114

           310 -
         Champion, Inc.
         105 E. "A" Street, P. 0. Box 490
         Iron Mountain, MI 49801

           311 -
         Cheboygan Cement Products, Inc.
         702 Lafayette Avenue
         Cheboygan, MI 49721
<pb n="242" />

         LUDINGTON CZM SURVEY MAILING LIST                                                    10

            78 -                                                                                       I
         Cherry Central Co-op
         415 Munson Avenue
         Traverse City, MI 48684

            79
         Christensen Canada Afr Line
         465 St. Johns St.
         Montreal, Quebec, Canada

            80 - Donn B. Whitmer
         Chrysler Corporation
         PO Box 1976
         Detroit, MI 482  88

           264 - Charles L. Dunlap
         Clark Oil &amp; Refining Corp.
         8530 W. National Ave.
         Milwaukee, Wisconsin 53227

            81 - D.J. McKay
         Clarke Transport Canada
         1155 Dorchester Blvd West
         Montreal, Quebec, Canada

            82 - Don Ryan
         Cleveland Cliffs Iron
         Empire Mine
         Ishpeming, MI
           290 -                                                                                        "I
         Cleveland-Cliffs Iron Co.
         504 Spruce St.
         Ishpeming, MI 49849

           312 -
         Click Sand &amp; Gravel
         P. 0. Box 273
         Port Huron, MI 48079
           278 -                                                                                        a
         Coastal Tank Lines, Inc.
         215 E. Waterloo Road
         Akron, OH 44319

           313 -
         Coit Avenue Gravel Company, Inc.
         4772 Coit Avenue, N.E.
         Grand Rapids, MI 49505
           314 -                                                                                        I
         Concrete Services, Inc.
         W. Front Street
         Traverse City, MI 49684
<pb n="243" />

        LUDINGTON CZM SURVEY MAILING LIST

            84
        Constallation Navigation
        233 Broadway
        New York, NY 10007

            83 - Nelson VanLeeuwen
        Construction Aggregates Corp.
        PO Box 342
        Grand Haven, MI 49417

           315 '-
        Construction Aggregates Corp.
        P. 0. Box 68
        Ferrsburg, MI 49409

           316 -
        Contractors Gravel Co.
        Box 83
        Sparta, MI 49345

            85 - James V. Guthrie
        Cottman Company
        300 Water Street
        Baltimore, MD 21203

            86 -
        Coughlin, F.X. Co.
        28451 Wick Road
        Romulus, MI 48174

            87 -
        Cymeon Shipping Co.
        25 Broadway, #514
        New York, NY 10004

          282 - D. M. Mitchell
        D. M. Mitchell Transport Co.
        3501 Wyoming Avenue
        Dearborn, MI 48120

            88 - Don Kirt
        D&amp;B Furniture Outlet
        1300 38th Avenue
        Menominee, MI

            89
        Dafra Line/Stevenson-Kerr Corp
        29 Broadway
        New York, NY 10006

            90 - Joseph Grabowski
        Del-Mar Inc.
        1681 Columbus Road
        Cleveland, OH 44113
<pb n="244" />

         LUDINGTON CZM SURVEY MAILING LIST                                              12

            91
         Delta Steamship Lines
         1 World Trade Center
         New York, NY 10048

            92 - H. George Miller
         Diamond Crystal Salt
         St. Clair, MI 48079

            93 - T.J. Cloghesy
         Domtar Newsprint Sale
         940 Sun Life Building
         Montreal, Quebec, Canada

          305 -
         Don Britton, Inc.
         1480 Westwood Road
         Marquette, MI 49855

            95 - J.P. Dubreuil
         Dubreuil Borthers Ltd
         Dubreuilville, Ontario Canada

            94 - Marshall Bonier
         Dubreuil Brothers Ltd
         530 Cathguard Street
         Sault Ste. Marie, Ontario

          318
         Dunbar Sand &amp; Gravel
         P. 0. Box 246
         Cadillac, MI 49601

            96 - William A. Dempsey
         Dundee Cement Co.
         Dundee, MI 48131

          317
         Earl Dubey &amp; Sons
         Route #3
         Alpena, MI 49707

            97 - William Austin
         East Jordan Iron Works
         East Jordan, MI 49727

            98 - Joseph P. O'Donn 11
         Eastman Kodak Company
         Lake Avenue
         Rochester, NY 14650
<pb n="245" />

         LUDINGTON CZM SURVEY MAILING LIST                                                   13

            99 - James E. Bowles
         Emerson Electric Co.
         1821 13th Street
         Menominee, MI 49858

           100 - Werner E. Scholtz
         Ernst Russ-North America
         One North LaSalle St
         Chicago, IL 60602

           101 -
         Eurolakes Tanker Line/Hasserodt Mar
         28430 Swan Island Drive
         Grosse Ile, MI 48138

           102 -
         Eurolakes Tanker Line/Hurum Ship'g
         300 St. Sacrement Street
         Montreal, Quebec, Canada

           163
         Express Forwarding Co.
         28420 Highland Road
         Romulus, MI 48174

           104 - Ms. Melinda Otto
         Exxon Minerals Co.
         300 South Lake Avenue
         Crandon, WI

           105 - Robert   Russell
         Exxon Minerals   Co.
         655 Washington; PO Box  813
         Rhinelander, WI 54501

           106 -
         Federal Comm/Navig Ltd-
         Stock Exchnge Twr/Victoria Sq
         Montreal, Quebec, Canada

           107 - James E. Roberts
         Federal Lime &amp; Stone
         Huron Lime Plant
         Huron, OH 44839

           108 -
         Finnlines/Boise-Griffin SS Co
         1 World Trade Center, 38th Flr
         New York, NY 10048

           319
         Fischer Gravel Co.
         2604 S.-Snyder Road
         Wellston, MI 49689
<pb n="246" />

         LUDINGTON CZM SURVEY MAILING LIST                                                  14

           109 - Richard C. Hanel
         Footner &amp; Company Inc
         33 Rector Street -
         New York, MY 10006

           110 - Allen A. Moody
         Ford Motor Company
         The American Road
         Dearborn, MI 48121

           111 - Richard Haupt
         Ford Motor Company
         One Parklane Blvd, JJE200
         Dearborn, MI 48126

           11@ - Arnold L. Sabin
         Foreston Coal Co.. Inc
         353 Fifth Ave
         New York, NY 10016

           320 -
         Fox Valley Construction Co.
         Box 1274, 103 W. College Ave.
         Appleton., WI 54911'

           113 - Albert Gani
         Francosteel Corp.
         757 Third Ave
         New York, NY 10017

           114 - Richard J. Sherry
         Freight Traffic Service
         12878 Farmington Road
         Livonial MI 48   150

           115 -
         French Paper Company
         Box 729
         Niles, MI 49120

           116 -
         Furness, Withy &amp; Co., Inc.
         5 World Trade Center, #7411
         New York, NY 10048

           117 -
         Gdynia America Line
         1 World Trade Center
         New York, NY 10048

           306
         Gene Brow Construction Co.
        'P. 0. Box 5
         Seney, MI 49883
<pb n="247" />

        LUDINGTON CZM SURVEY MAILING LIST                                               15

          118 - A. Pearson
        General Mills Inc.
        9200 Wayzata Blvd
        Minneapolis, MN 55440

          119 - Earl R. Wiseman
        General Motors Corp.
        30007 VanDyke Avenue
        Warren, MI 48090

          120 - Frank J. Weckerle
        General Motors Corp.
        Chevrolet Division
        Buffalo, NY 14240

          121 - Donald J. Prause
        Georgia Pacific Corp.
        308 Huron Street
        Grayling, MI 49738

          122 - P.J. Sullivan
        Gerber Products Co.
        Fremont, MI 49412

          123 - Maurice Pelletier
        Go-Pell Engineering
        1035 Boul. Ste-Anne
        Beauport, Quebec, Canada

          124 - C.T. Lee
        Goodyear Tire &amp; Rubber
        4315 Airwest, S.E.
        Kentwood, MI 49508

          125 - D.F. Brain
        Goodyear Tire &amp; Rubber
        1144 East Market Street
        Akron, OH 44305

          127
        Grace Line/March Shipping Ltd
        400 Craig Street West
        Montreal, Quebec, Canada

          128 -
        Grand Colombiana/United Liners Agcy
        465 St. Johns Street
        Montreal, Quebec, Canada

          129 - Dominick Chiappone
        Great Lakes Carbon Co
        Electrode Division
        Niagara Falls, NY
<pb n="248" />

         LUDINGTON CZM SURVEY MAILING LIST                                              16

           130 - Mario Signorelli
         Great Lakes Container
         103 Erieside-Avenue
         Cleveland, OH 44114

           131 - David A. Healy
         Great Lakes Motor Shipping
         PO Box 2886
         Livonia, MI  48151

           126
         Great Lakes Transcaribbean/Tolmar
         20600 Eureka Road
         Taylor, MI 48180,

           135 - Robert W. Freske
         Great Plains Associated Ltd
         123 Marmont Street; Box 358
         Niles, MI 49120

           132 - Robert Vanderheyden
         Green Bay Packaging
         PO Box 1107
         Green Bay, WI 54305

           133 - R.G. Olson
         Green Giant Company
         Le Sueur, MN 56058

           321
         Gronlund Gravel Co.
         Route #2, Box 28
         Bear Lake, MI 49614

           134 - Alan B. Williams
         GSW Limited
         Box 5273, Terminal A
         London, Ontario, Canada

           265 - W. J. Berghoff
         Gulf Oil Company - U.S.
         P. 0. Box 29165
         Columbus, Ohio 43229

           136 - Sven Hubner
         Guthrie-Hubner, Inc.
         Board of Trade Bldg
         Duluth, MN 55802

           137 - Lawrence O'Connor
         Hanna Mining Co.
         100 Erieview Plaza
         Cleveland, OH 44114
<pb n="249" />

        LUDINGTON CZM SURVEY MAILING LIST                                                17

           291
        Hanna Mining Co./Groveland Mine
        Star Route 1, Box 131
        Iron Mountain, MI 49801

           138 -
        Hapag/Lloyd/Russ/Montral Shipping
        360 St. James Street
        Montreal, Quebec, Canada

           139 - Joe Karas
        Hardy Salt Company
        1501 Main Street
        Manistee, MI 49660

           140
        Hasserodt Marine Agency
        28430 Swan Island Drive
        Grosse Ile, MI 48138

           141
        Hellenic Line/World Shipping, Inc.
        .13530 Michigan; Room 210
        Dearborn, MI 48136

           297 -
        Henry Balkema Sand &amp; Gravel
        7758 Kilowatt Dr.
        Kalamazoo, MI 49001

           142 - Larry Eckert
        Hercules (Cent. Reg)
        Oakbrook, IL

           143 - Lee Allen
        Hickman, Williams &amp; Co
        100 Rannaissance Plaza #1875
        Detroit, MI

           144 - Richard W. Lambrecht
        Hickman, Williams &amp; Co.
        40 Port Avenue
        Monroe, MI 48161

           322
        Hodgkiss &amp; Douma, Inc.
        P. 0. Box 311
        Petoskey, MI 49770

           145 - William J. Cochran
        Hooker Chemical Corp.
        Chemicals &amp; Plastics
        Niagara Falls, NY 14302
<pb n="250" />

         LUDINGTON CZM SURVEY MAILING LIST                                                  18

           146
         Hurum Shipping/Trade Co.
         300 St. Sacrement. Street
         Montreal, Quebec, Canada

           147 -
         I.M.C. Industries Group/Azure Agncy
         PO Box 127
         Detroit, MI 48218

           266 - J-. F. Swain
         Industrial Fuel &amp; Asphalt Corp.
         566 Market Avenue, S.W.
         Grand Rapids, 141 49502

           148 - James P. Dwyer
         Industrial Minerals of Canada
         7 King Street East
         Toronto, Ontarioa, Canada

           149 - A.J., Jr. Cayia
         Inland Lime &amp; Stone Co.
         Div. of Inland Steel Co.
         Gulliver, MI 49840

           334
         Inland Lime and Stone Co.
         Gulliver, MI 49840
           292 -                                                                                      I
         Inland Steel Co./Sherwood Mine
         P. 0. Box 232
         Iron River, MI 49935

           151 -
         International Great Lakes Shipping
         Ill East Wacker Drive
         Chicago, IL 60601

           152 - P. Norman Ness
         International Milling-Co., Inc.
         Minneapolis, MN

           150 - Paul B. St. Onge
         International Mineral &amp; Chemical Co.
         Old Orchard Road
         Skokie, IL 60076

           153 - William J. O'Meara
         International Multifoods
         1300 Investors Bldg
         Minneapolis, MN 55402
<pb n="251" />

        LUDINGTON CZM SURVEY MAILING LIST                                                   19

           157 - Thomas P. Monahan
        International Salt Co.
        614 Superior Ave, #1414
        Cleveland, OH 44113

           154 - Frank J. McGinley
        International Standard Electric Co.
        50 Church Street
        New York, NY 10007

           156 - Harry J. Delay
        International Talc Co., Inc.
        90 West Street
        New York, NY 10006

           155 - Irving Lichter
        Interntional Steel Products
        233 Broadway
        New York, NY    10007

           158
        Irish Shipping Ltd/Shipping Ltd
        410 St. Nicholas Street
        Montreal, Quebec, Canada

           159
        Japan Line Services
        1 World Trade Center, #2867
        New York, NY 10048

           303
        John Boerman Sand &amp; Gravel
        Route 4
        Allegan, MI 49010

           160 - Kurt H. Waldm nn
        Jones &amp; Laughlin Steel Co.
        15 Court Street
        Buffalo, NY 14202

           161
        K Line
        465 St. Johns Street
        Montreal, Quebec, Canada

           323 -
        K&amp;V Gravel Company
        403 Cherokee Drive
        Fremont, MI 49412

           162 - James S., Jr. White
        Kendall Refining Company
        Bradford, PA 16701
<pb n="252" />

         LUDINGTON CZM SURVEY MAILING LIST                                              20

           163
         Kerr Steamship Co., Inc.
         1420 Parklane Towers East
         Dearborn, MI 48126

           164 - Jon.D. Counts
         Kimberly-Clark Corp.
         Neenah, WI 54956

           324
         Koboski Coal Company, Inc.
         114 Washington Street
         Petoskey, MI 49770

           267 - Don Price
         Koch Fuels, Inc.
         P. 0. Box 128
         Ferrysburg, MI 49409

           268 - D. C. Horton
         Koch Fuels, Inc.
         P. 0. Box 307
         Green Bay, WI 54305

           165 - Edward McKendry
         Koppers Company, Inc.
         PO Box 129
         Peshtigo, WI 54157

           166
         Kuehne &amp; Nagle, Inc.
         6170 Middlebelt Road
         Romulus, 141 48174

           167 - Charles D  Parmelee
         Lake Ontario Cement
         King Street
         Toronto, Ontario, Canada
           325 -                                                                                 I
         Lake Sand and Gravel Co.
         P. 0. Box 829
         Baldwin, MI 49304

           168 - Robert Rotundo
         Lake-Link Transportation Corp.
         Ontonagon, MI 49953

           269 - Edward Fleischman
         Lakeside Refining Co.
         Box 909
         Kalamazoo, MI 49005
<pb n="253" />

        LUDINGTON CZM SURVEY MAILING LIST                                              21

          169 - Karl, P.E. Hauser
        Levy, Edward C. Company
        8800 Dix Avenue
        Detroit, MI 48209

          279 - Lewis C. Johnson
        Liquid Transport, Inc.
        2000 E. Superior Street
        Alma, MI 48801

          170 - Edward N. Locke
        Locke, Edward N.
        P.O. Box 488
        Marquette, MI 49855

          171 - Randy Anzalone
        Louisiana-Pacific Corp.
        Hayward, WI

          172 - Leonard J. Russ
        Luria Brothers &amp; Co., Inc.
        4446 Main Street
        Buffalo, NY 14226

          277 - Peter R. Gout
        M. L. Ashbury, Inc.
        1100 S. Oakwood
        Detroit, MI 48217

          173 -
        Maersk Line/Robt Reford Co., Inc.
        221 St. Sacrement Street
        Montreal, Quebec, Canada

          174 -
        Manchester Liners/Mardell Shipping
        333 West Fort; Suite 1806
        Detroit, MI 48226

          270 - W. R. Gravius
        Marathon Oil Co./Wholesale Sales
        26400 Lahser Road
        Southfield, MI 48034

          175 - Brian A.H. Cartwright
        Maritime Coastal Cont.
        634 Barrington Street Tower
        Halifax, Nova Scotia, Canada

          280
        McKinley Trucking Co.
        Carson City, MI 48811
<pb n="254" />

         LUDINGTON CZM SURVEY MAILING LIST                                              22

           176 - Gerald R. Gould
         Head Paper
         Publishing Paper Division
         Escanaba, MI 49829

           177 -
         Medlakes Service/Montreal Shipping
         360 St. James Street
         Montreal, Quebec, Canada

           178 - Donald Estebo
         Menominee Paper Co.
         P.O. Box 300
         Menominee, MI 49858

           179 -
         Mexican Line/Smith &amp; Johnson
         11 Broadway
         New York, NY 10004

           180 - Charles Duffrin
         Michigan Handle &amp; Block
         PO Box 8
         Wallace, MI 49893

           281
         Michigan Transportation Co.
         3601 Wyoming Ave.
         Dearborn, MI 48120

           181 - James A. Calvey
         Mid-Continent Coal
         5031 Turney Road
         Cleveland, OH 44125

           182 - William L. Cook
         Minneapolis Grain Exchange
         400 South 4th Street, #652
         Minneapolis, MN 55415

           271 - E. W. Thompson
         Mobil Oil Corp./Lansing Dist. Office
         P. 0. Box 1330
         East Lansing, MI 48823

           183 -
         Montreal Shipping Ltd
         360 St. James Street
         Montreal, Quebec, Canada

           184 - William E. Brandt
         Morton Salt Company
         110 North Wacker Drive
         Chicago, IL 60606
<pb n="255" />

        LUDINGTON CZM SURVEY MAILING LIST                                              23

          185 - Alex C. Little
        Murray &amp; Robinson, Ltd
        11 King Street West, #1400
        Toronto,- Ontario, Canada

          186 -
        Nahrgang, V.G., Co.
        155 West Congress Street
        Detroit, MI 48226

          187 - Richard Harris
        National Gypsum Co.
        National City, MI

          188 - Robert J. Eaton
        National Gypsum Company
        325 Delaware Avenue
        Buffalo, NY 14202

          189 -
        Nebam Line/International Great Lakes
        4461 West Jefferson
        Detroit, MI 48209

          190 - J. Leonard
        Nestle Company, Inc.
        100 Bloomingdale Rd.
        White Plains, NY 10605

          191 - Ms. Ava Sauer
        Nettles &amp; Company, Inc.
        9801 West Higgins Road, #416
        Rosemont, IL 60018

          192 - Bernard S. Costello
        New England Shipping Agency
        177 State Street
        Boston, MA 02109

          193 - Stanely W. Gordon
        New York International Sales
        347 Fifth Avenue
        New York, NY 10016

          194 - Ray L. Falkner
        Niagara of Wisconsin
        Materials Manager
        Niagara, WI 54151

          195
        Nordana Line/Barber Steamship Line
        17 Battery Place
        New York, NY 10004
<pb n="256" />

         LUDINGTON CZM SURVEY MAILING LIST                                                 24

           298 -
         Norman Bartlett Sand &amp; Gravel
         Route #3, Box 86
         East Jordan, MI 49727

           196 - Edward Fox
         North Star Steel Co.
         3000 East Front Street, B 1200
         Monroe, MI 48161
           284 -                                                                                    I
         Northwood Oil Co.
         P. 0. Box 4.08
         Cheboygan, MI 49721

           336 -
         Onaway Stone Co., c/o Cherryland Cut Stone Co.
         Route 4, Box 529
         Traverse City, MI 49684

           197 - Martin J. O'Doherty
         Ontario Paper Company
         Thorold, Ontario, Canada

           198 - Richard A.  Trampe
         Pabst Brewing Company
         917 West Juneau Avenue
         Milwaukee, WI 53201

           199
         Pacific Star Line
         1155 Dorchester Blvd West
         Montreal, Quebec, Canada

           200 - Seymour K. Padnos
         Padnos Iron &amp; Metal Co.
         River Avenue at Bayside Drive
         Holland, MI 49423

           201
         Panocean Bulk Carrier/Patton S'ship
         26300 Northwestern Highway
         Southfield, MI 48076

           202 -
         Parcel Tankers Inc./Hasserodt Marine
         28430 Swan Island Drive
         Grosse Ile, MI 48138

           203 - Brian A. Galvin'
         Park Gate Iron/Steel
         I North LaSalle Street
         Chicago, IL 60642
<pb n="257" />

        LUDINGTON CZM SURVEY 14AILING LIST                                                25

           204
        Patton Steamship Agency
        26300 Northwestern Highway
        Southfield, MI 48076

           205 -
        Peninsula Fruit Exchange
        2955 Kroupa Road
        Traverse City, MI 49684

           272 - Charles G. O'Donn 11
        Penn oil Co./Grand Rapids District
        7893 Foxwood
        Richland, MI 49084

           206 - Edward E., Jr. Rodgers
        Pennzoil Company
        Executive Offices
        Oil City, PA 16301

           273 -
        Phillips Petroleum Co.
        909 Mayfair Road
        Wauwatosa, WI 53226

           208 - Howard Collier
        Pillsbury Company
        PO Box 128
        Morral, OR 43337

           216 - E.J. Bedor
        Pillsbury Company
        Agri-Products Division
        Minneapolis, MN

           209 - Richard K. Krawze
        Pine River Lumber Co.
        Long Lake, WI 54542

           210 -
        Polish Ocean Line/Int'l Grt Lakes Shp
        4461 West Jefferson
        Detroit, MI 48209

           211 - Robert H. Allen
        Presque  Isle Corp.
        Box 426  (Stoneport)
        Alpena,  MI 49707

           337
        Presque  Isle Corp.
        P, 0. Box 426
        Alpena, MI 49707
<pb n="258" />

         LUDINGTON CZM SURVEY MAILING LIST                                              26

           285 - Ms. Verna Priebe
         Priebe Transport Co.
         1207 Broad Street
         St. Joseph, MI 49085

           212 - Douglas Deitrich
         Procter &amp; Gamble
         502 Eastman Avenue
         Green Bay, WI 54301

           213 - Robert M. Burke
         Procter &amp; Gamble Co_
         Buying and Traffic
         Cincinnati, OH

           214
         Protos Shipping Ltd
         407 McGill Street
         Montreal, Quebec, Canada

           215
         Quaker State Oil Refinery
         Export Manager
         Oil City, PA 16301

           283
         Ray Molder, Inc.
         8300 Beech-Daly Road
         Taylor, MI 48180

           286 -
         Refiners Transport and Terminal Corp.
         445 Earlwood Ave.
         Oregon, OH 43616

           287
         Rex Transportation Co.
         1520 N. Woodward Ave., Suite 207
         Bloomfield Hills, MI 48013

           21.7 - E.J. Sullivan
         Robin Hood Flour Mills
         Montreal, Quebec,.Canada

           218 - Donald G. Castonguay
         Rothesay Paper Corp.
         Traffic Manager
         St.John,New Brunswick,Canada

           219 - Richard S. Baibak
         Saginaw Bay Trading Co.
         245 South Main Street
         Frankenmuth, MI 48734
<pb n="259" />

         LUDINGTON CZM SURVEY MAILING LIST                                                 27

           220 - C. Sabinsky
         Saguenay Shipping Ltd
         1060 University Street
         Montreal, Quebec, Canada

           221 - Richard Sarenac
         Sarenac Shipping Co.
         647 West Virginia Street
         Milwaukee, WI 53204

           326 -
         Schworm, Inc.
         P. 0. Box 162, M-37 South
         Traverse City, MI 49684

           327
         See's Sand &amp; Gravel, Inc.
         4500-31 Mile Road
         Romeo, MI 48065

           222 - Art Kitzeas
         Serv-Best Foods
         Highland Park, IL

           274 - R. W. Sherwood
         Shell Oil Company/Milwaukee Dist.
         3505 North 124th St.
         Brookfield, WI 53005

           223 - Wm. J. McLaughlin
         Shipping Limited
         410 St. Nicholas Street
         Montreal, Quebec, Canada

           328 -
         Shook Paving Company
         8281 Snows Lake Road
         Greenville, MI 48838

           224 -
         Showa Line/Clark Transport Canada
         1155 Dorchester Blvd, West
         Montreal, Quebec, Canada

           225 -
         Sidemar Navigation/World Shipping
         13530 Michigan; Room 210
         Dearborn, MI 48136

           329 -
         Sievert Brothers, Inc.
         200 E. River Street
         Manistee, MI 49660
<pb n="260" />

         LUDINGTO N CZM SURVEY MAILING LIST                                                28

           226 - William G. Benisch
         Spencer Kellogg Division
         120 Delaware Avenue
         Buffalo, NY 14240

           227 - Richard D. Anderson
         Standard Alliance Ind.
         1211 West 22nd Street, 1008
         Oak Brook, IL 60521

           228 - William Gagner
         Standard Milling Co.-
         Standard Elevator &amp; Grain
         Buffalo, NY

           229 -
         Stanek &amp; Sons, Inc.
         9378 Co. Road 633; PO Box 253
         Traverse City, MI 49684

           288 -
         Stang Tank Lines
         P. 0. Box 257
         Menominee, MI 49858

           230 - Stanley J. Stewart
         Steelmet, Inc.
         1204 Grant Building
         Pittsburgh, PA 15219

           231 - Patrick J. Fox
         Stroh Brewery Co.
         909 East Elizabeth Street
         Detroit, MI 48226

           232
         Surinam Line/Hansen &amp; Tidemann
         1 World Trade Center, #1627
         New York, NY 10048

           233 - Rheinberger
         Swift &amp; Company
         Chicago, IL

           275 - S. Tolbert
         Texaco, Inc.
         630,E. "B" Street
         Iron Mountain, MI   49801
           234 -                                                                                     I
         Texas Transport &amp;  Terminal
         71 Broadway
         New York, NY 10006
<pb n="261" />

        LUDINGTON CZM SURVEY MAILING LIST                                              29

          235 - Sam T. Boleware
        The Ohio River Company
        1045 Evans Road
        Flossmoor, IL 60422

          236 - Hugh R. Murchie
        Total Petroleum, Inc.
        13544 West Bayshore Drive
       'Traverse City, MI 49684
          338
        U. S. Steel Corporation
        Limestone Operations
        Rogers City, MI 49779

          237 - Harry Ainsworth
        U.S. Gypsum
        Alabaster, MI

          244 - Fred A. Hopfinger
        U.S. Plywood Corporation
        1160 Scottsville Road
        Rochester, NY 14624

          245 - Arnold E. Busse
        U.S. Steel Corporation
        1000 E. 80th Place, #617
        Merrillville, IN 46410

          246 - N.V. McLean
        U.S. Steel Corporation
        3001 West Big Beaver Road
        Troy, MI 48084

          247 - Duane G. Rohrer
        U.S. Steel Corporation
        Cedarville Plant
        Cedarville, MI 49719

          248 - W.R. Ransom
        U.S. Steel Corporation
        400 Missabe Building
        Duluth, MN 55802

          249 - D.T. VanZandt
        U.S. Steel Corporation
        600 Grant Street
        Pittsburgh, PA 15230

          238 - Vincent G. Wilson
        Union Carbide Corp.
        270 Park Avenue
        New York, NY 10017
<pb n="262" />

         LUDINGTON CZM SURVEY MAILING LIST                                             30

           239 - Phil Iverson
         United Block Company
         Arcade, NY 14009

           240 - Keith Eccles
         United Sierra
         80 Coehill Drive, Apt. 105
         Toronto, Ontario, Canada

           241 - Ms. Wendy Lenfield
         Upjohn Company
         Kalamazoo, MI

           242 - Robert D. Fischl
         Upper Peninsula Shipbldg
         Foot of River Street
         Ontonagon, MI 49953
           243 -                                            -                                    I
         Uruguayan Line./B&amp;K Shipping Agency
         465 St. Johns Street
         Montreal, Quebec,.Canada

           339 -
         Van Deusen Stone Co.
         234 S. Huron Road
         Au Gres, MI 48703
           289 -                                                                                 I
         Wagoner Transportation Co.
         755 E. Hackley Ave.
         Muskegon Heights, MI 49444

           250 - Wayne, C. Johnson
         Walter C. Best, Inc.
         Chardon, OH 44024

           251 - Zenon Baranski
         Ward Hydronics, Inc.
         11600 Genesee Street
         Alden, NY 14004

           252 - R.D. Waterman
         Waterman Fruit Producers
         North Road
         Ontario Center, NY 14520

           253 - Frank Barry
         Welch Grape Juice Co.
         General Traffic Manager
         Westfield, NY 14787
<pb n="263" />

        LUDINGTON CZM SURVEY MAILING LIST                                               31

          330
        Wexford Gravel Co.
        300 Haynes St.
        Cadillac, MI 49601

          254 - Bruce Karnes
        Whirlpool Corporation
        Benton Harbor, MI 49022

          255 - R.G. Dodge
        Wickes Corp, Michigan Bean
        1741 North Niagara, PO Box 2069
        Saginaw, MI 486.05

          331 -
        Wiggins &amp; Sons
        Merritt, MI 49667

          256 - Joseph H. Carollo
        Windsor Detroit Bridge Line
        4461 West Jefferson Street
        Detroit, MI 48209

          257 - Huberto Platz
        Wisconsin Electric
        Milwaukee, WI

          332 -
        Wolverine Gravel Co.
        3790 Puite, S.W.
        Grandville, MI 49418

          258 - Howard A. Lambka
        World Shipping Inc.
        13530 Michigan Ave., #210
        Dearborn, MI 48126

          259 -
        Y.S. Line/Texas Transport &amp; Ter.
        71 Broadway
        New York, NY 10006
<pb n="264" />

                                Appendix B
           Feasibility Data &amp; Calculations
<pb n="265" />

                                                  APPENDIX B

                       FEASIBILITY DETERMINATION CALCULATIONS, DATA, AND SOURCES

           SECTION I. LOCAL PLANT DEVELOPMENT CALCULATIONS AND DATA

           A.    Hydraulic Cement Production

                 Production volume is 4,000,000 barrels/year or 750,000 tons/year (one
                 barrel = 376 lbs)

                                                   TABLE B-1
                                    Breakdown-of Operating Costs for a
                                Typical 4,000,000 barrel/year Cement Plant

                                                                              Plant Cost
                                  Item                       Symbol           Per Barrel

                      Labor                                    L                  .$0.76
                      Fuel                                     F                  0.68
                      Power (electrical)                       P                  0.59
                      Miscellaneous Supplies                   S                   '0.57
                      Maintenance &amp; Materials                  M                  0.34
                      Supervision &amp; Overhead                   0                  0.28
                      Depreciation Expense                     D                  0.71

                      TOTAL                                                       $3.93

                                                   TABLE B-2
                                     Locality Cost Adjustment Factors

                            Labor (A 1)     Electrical  (A P) Materials   (Am)   Depreciation   (A d)
                city        Adjustment       Adjustment         Adjustment           Adjustment

           Chicago              1.01              1.21              0.94                  0.97
           Grand Rapids         0.99              1.25              0.96                  0.97
           Lansing              0.93              0.88              0.90                  0.91
           Ludington            0.86              1.25              0.89                  0.87
           Milwaukee            1.03              0.87              1.02                  1.02
           Traverse City        0.79              1.25              0.88                  0.83

           Calculation of Manufacturing Costs (MFG):
                 MFG = (L x A,) + F + (P           x A     + S + (M x A         + 0 + (D x A
           Sample calculation for Chicago:

                 MFG = (0.76 x 1.01) + 0.68        + (0.59 x 1.21) + 0.57 + (0.34 x 0.92)
                            + 0.28 + (0.71 x       0.97)

                 MFG = $4.02/barrel

                                                      B-1
<pb n="266" />

                                                  TABLE B-3
                                         Cement KFFGCosts by Cities

                                                                        $/CWT
                                                 $/Barrel             (100 lbs)

                       Chicago                    4.02                  1.07
                       Grand Rapids               4.04                  1.07
                       Lansing                    3.71                  0.99
                       Ludington                  3.84                  1.02
                       Traverse City              3.76                  1.00

           Raw Material Requirements:

           To produce one ton of cement requires approximately:

                 1.2 tons of limestone
                 0.4 tons of clay
                 0.027 tons of gypsum

           Calculation of Costs to Transport Raw Materials (T raw):

                 T raw      ($/ton-mile) x (miles to limestone source) x 1.2
                                  20
                          + ($/ton-mile) x (miles to clay source) x 0.04
                                  20
                          + ($/ton-mile    x (miles to gypsum source) x 0.027
                                  20

           T raw is expressed in terms of $/CWT of finished cement-product.

           Costs per ton-mile versus distance are developed from actual quotes and statis-
           tics   for various commodities transported on various routes and distances.
           Table B-4 contains data used to compute T raw.          T raw is computed using the
           least  expensive transportation mode for each raw material.

           Sample calculation for T raw for Chicago:
                 T raw      (.20)   x 60 x 1.2          =  0.72
                              20
                            (.28)   x 10 x 0.4'         =  0.06
                              20
                            J.28)   x 10 x 0.027        =  0.004
                              20
                                             T raw         0.78 for Chicago

                                                  TABLE  B-5
                                          T raw, $/CWT   of Cement

                            Chicago                                          0.78
                            Grand Rapids                                     0.78
                            Lansing                                          0.58
                            Ludington                                        0.54
                            Traverse City                                    0.73
                                                      B-2
<pb n="267" />

                                                                                           TABLE B-4

                                                                              Transportation Distances and Costs
                                                                                 Per Ton/Mile for Raw Materials

                                                       Limestone                                         Clay                                      Gypsum
                                              By Truck -        By Rail          WaTe-rborne                By Truck                            By Truck             By Rail
                                                    $/Ton-           $/Ton:,          $/Ton-                      $/Ton-                               $/Ton-              %/Ton-
                               Source       Miles    Mile    Miles     Mile   Miles     Mile    Source Miles       Mile         Source        Miles     Mile       Miles    Mile

          Chicago           LaPorte, IN       60     .20       60      .20       -              Local     10       .28     Local               10

          Grand Rapids      Bellevue, MI      60     .20       60      .20       -              Local     10       .28     Local               10       .28                   -

          Lansing           Bellevue, MI      35     .24       -       -         -      -       Local     10       .28     Grand Rapids        65       .20           65      .20

          Ludington         Charlevoix, MI 140       .11       140     .055      126    .08     Local     10       .28     Grand Rapids        95       .15           95      .15

          Traverse City     Charlevoix, MI 50        .22       -       -         -      -       Local     10       .28     Grand Rapids       140       .11          140      .055
<pb n="268" />

           B.    Pulp and Paper Production

                 Pulp Production

                 Production volume is 900 tons/day of bleached kraft pulp

                                                 TABLE B-6
                                   Breakdown of Operating Costs for a
                                    Typical 900  ton/day SBK Pulp Mill

                                                                          Plant Cost Per
                                 Item                       Symbol          Ton of  Pulp

                      Raw Materials
                        (Pulpwood and chemicals)             M                 $152
                      Energy                                 E                   36
                      Labor                                  L                   49
                      SG&amp;A                                   S                   10
                      Capital and Related                    D                   88
                      Profit                                 P                   89

                      TOTAL                                                    $424

                 Locality cost adjustment factors used are given in Table      B-2, except power
                 (energy) adjustment was not applied.

                 Calculation of Manufacturing Cost (MFG)
                      MFG      (M x Am) + E + (L x A,) + SG&amp;A + (D x Ad) + P
                 Sample calculation for Chicago:

                      MFG = (152 x 0.94) + 36 + (49 x 1.01) + 10 + (88 x 0.97) + 89
                      MFG = $413/ton of pulp

                                                 TABLE B-7
                                        Pulp MFG Cos-t-s--Fy Cities

                                                             $/ton             $/cwt
                                                             Pulp              Pulp

                      Chicago                                $413              $20.65
                      Grand Rapids                           $415              $20.75
                      Ludington                              $389              $19.45
                      Milwaukee                              $430              $21.50
                      Traverse City                          $381              $19.00

                 Calculation of Costs to Transport Raw Materials (T raw):

                 To produce 1 ton of pulp requires approximately 2.5 tons of wood chips.
                 T raw     ($/ton-mile) x (miles to wood source) x 2.5
                                 20

                                                    B-4
<pb n="269" />

                T raw is expressed in terms of $/cwt of pulp.
                Costs for transporting wood from source in Escanaba,* Michigan to the
                locations by various modes are given in Table B-8.           T raw i s computed
                using the least expensive transportation mode for each location.

                                                 TABLE B-8
                                                  T_
                                          T raw, /cwt of Pulp

                                                                            Mode of
                                                       $/cwt            Transportation

                     Chicago                           1.54             Waterborne
                     Grand Rapids                      3.24             Rail or truck
                     Ludington                         1.22             Waterborne
                     Milwaukee                         1.38             Waterborne
                     Traverse City                     1.20             Waterborne

                Calculation of Costs to Transport Finished Product     (SBK Pulp)
                to Markets (T fin)

                It is assumed pulp will be marketed to paper mills     in major midwest cities
                in proximity to Lake Michigan in proportion to population. The breakdown
                of this market is as follows:

                                                                         Approximate
                                                                             %-of
                                             1978 Po'Pulation            -Market

                     Chicago                     7,030,000                    70
                     Grand Rapids                  585,000                      5
                     Lansing                       458,000                      5
                     Milwaukee                   1,417,000                    15
                     Madison                       319,000                      5

                     TOTAL                       9,809,000                   100

                Formula to compute T fin; (in    terms of $/cwt of pulp)
                T fin       (distance to Chicago)         X (  $/ton-mile)   x 0.70
                                                                   20
                        +   (distance to Grand Rapids)    x    ($/ton-mile)  x  0.05
                                                                   20
                        +   (distance to Lansing)         X    ($/ton-mile)  x  0.05
                                                                   20
                        +   (distance to Milwaukee)       X    ($/ton-mile)  x  0.15
                                                                   To-
                        +   (distance to Madison)         X    ($/ton-mile)  x  0.05
                                                                   20

                T fin   +   Total

                The data for calculation of T fin is contained in Table B-9.

                                                     B-5
<pb n="270" />

                                               TABLE B-9

                           TRANSPORTATION DISTANCES AND   COSTS PER TON-MILE
                               FOR WOOD CHIPS FROM ESCANABA, MICHIGAN

           PULP                     BY TRUCK               BY RAIL             WATERBORNE
           PRODUCTION AREA     Miles $/Ton-Mile      Miles $/Ton-Mile       Miles $/Ton-Mile

           Chicago              315      0.082         320     0.07          274     0.045

           Grand Rapids         370      0.070         370     0.07           -         -

           Ludington            340      0.070         350     0.07          130     0.075

           Milwaukee            225      0.105         230     0.07          200     0.055

           Traverse City        250      0.080         270     0.07          120'    0.080

                                                   B-6
<pb n="271" />

                                                                 TABLE B-10

                                                 TRANSPORTATION DISTANCES AND COSTS FOR

                                               TRUCK TRANSPORTATION OF PULP TO MARKET AREAS

                                     Chicago          Grand Rapids           Lansing           Milwaukee            Madison
                                           $/Ton-              $/Ton-             $/Ton-              $/Ton-              $/Ton-
            Plant Location      Distance    Mile    Distance    Mile   Distance    Mile    Distance    Mile    Distance    Mile

            Chicago               Local     0.27      175       0.10      2iO      0.09        85      0.17      140       0.11
                                (20 mi.)

            Grand Rapids          175       0.10      Local     0.27        65     0.20      260       0.08      315       0.07
                                                    (20 mi.)

            Ludington             235       0.08        95      0.15      160      0.10      320       0.07      375       0.07

            Milwaukee               85      0.17      260       0.08      295      0.07      Local     0.27        75      0.18
                                                                                           (20 mi.)

            Traverse City         310       0.07      140       0.11      170      0.10      395       0.07      450       0.06
<pb n="272" />

                Sample calculation of T fin for Chicago:
                            T fin = (20 x    0.27      x 0.7       =  0.19
                                               20
                                     + (175 x  0.10    x 0.05      =  0.04
                                                 20

                                               0 09
                                                 6@
                                     +  210 x w  20    x 0.05      =  0.05
                                     + (85 x 0.17      x 0.15      =  0.11
                                               20
                                     + (140 x  0.11    x 0.05      =  0.04
                                                 20                   -

                                                       T fin       =  0.43

                                                 TABLE B-11
                                            T fin, $/cwt Pulp

                                     Chicago                        0.43
                                     Grand Rapids                   0.87
                                     Ludington                      0.97
                                     Milwaukee                      0.'65
                                     ,Traverse City                 1.12

           C.   Agricultural Chemical Production

                Fert'ilizer plant (13-11-12 grade) with production volume of 400 tons/day
                or roughly 100,000 tons/year.

                                                 TABLE B-12
                                      Breakdown of Operating Costs
                                      (A Typical 400 ton/day Plant)

                                                                           Plant
                              Item                  Symbol               Cost/ton

                        Raw Material                  RM                 $ 42.24
                        Utilities &amp; Labor             UL                   21.12
                        Depreciation                  D                  -42.24

                        TOTAL                                            $105.60

                                                     B-8
<pb n="273" />

                                                TABLE B-13
                                   Locality Cost Adjustment Factors
                                            Utilities &amp; (A Ul)       Depreciation (Ad)
                                            Labor Adjustment            Adjustment

                    Chicago                       1.17                     0.97
                    Detroit                       1.19                     1.04
                    Grand Rapids                  1.19                     0.97
                    Lansing                       0.89                     0.91
                    Ludington                     1.17                     0.87
                    Madison                       0.87                     0.87
                    Milwaukee                     0.90                     1.02
                    Traverse City                 1.16                     0.83

                Calculation of Manufacturing Costs (MFG)
                MFG = RM + (UL x Aul) + (D x A         d)
                Sample calculation for Chicago

                MFG = 42.24 + (21.12 x 1.17) + (42.24 x 0.97)

                MFG = 107.92

                                                TABLE B-14
                                           MFG Costs by Cities

                                                       $/ton              $/cwt

                           Chicago                     107.92             5.40
                           Detroit                     111.30             5.57
                          -Grand Rapids                108.35             5.42
                           Ludington                   103.70             5.18
                           Milwaukee                   104.33             5.22
                           Traverse City               101.80             5.09

                Calculation of Costs to   Transport Finished  Product (13-11-12 Grade)
                Fertilizer to Market (T   fin)

                It is assumed that the fertilizer will        be marketed in Mason, Oceana,
                Manistee, Newaygo, Lake, Wexford, Missaukee, Osceola, Clare, and Mecosta
                Counties.

                Big Rapids (Mecosta County) was selected as a representative wholesale
                market.

                The calculation of (T fin) is given in Table B-15.

                                                     B-9
<pb n="274" />

                                                    TABLE B-15
                                   Transportation -Distances and Costs for
                                        Fertilizer to Big Rapids Market
                                                    By Railroad

                                                                                        Total
                                                    Distance           Cost             T fin
                        Plant Location              (mile-SI       ($/ton-mile)        ($/ton)
                        Chicago                       230               .09            $20.70
                        Detroit                       195               .11             21.45
                        Grand Rapids                    55              .13               7.15
                        Ludington                       60              .13               7.80
                        Milwaukee (via Kewaunee
                        and Ludington)                250                 G9            22.50
                        Traverse City                   80              .13             10.40

            SECTION II. REGIONAL SHIPPING TERMINAL          DEVELOPMENT

            Dry Bulk Terminal - Phase 1 Operation (for existing dry bulk commodity flows)
            ,(Limited to inert aggregates only)

            Limestone:     Currently, the north end of the dock, is being used by Laman
            Asphalt; continue to reserve this        area for their use.      Remainder of limestone
            to be placed at south end.

            Typical Barge Characteristics (for        self-unloaders):

            Boom Length     varies from 50 to 200 feet (typ      ical 150)
            Capacities     vary from 1000 to 8000     tons (typical 2000)
            Length    varies from 100 to 300 feet (typical 200)
            Draft    varies from 8 to 20 feet (typical 12)

            Booms on self-unloaders will not reach across US-10.             This area could be used
            as "long-term" storage for materials moved across the road by loaders or
            reserved-for future use.

            Annual Quantities (from direct contacts):

            Limestone

                  Laman Asphalt - 2 barge loads x 2000 tons/barge           4000 tons
                  Other - 8-10,000 tons

            Stockpile Areas Required:

            Limestone -

                  Laman Asphalt - Allocate area for storage of 1 barge load, or 2000 tons
                  Angle of repose for limestone is 350
                  Tan 350 = 0.70, slope is about 1 on 1.5.
                  For a rectangular pile - width = 45 feet , height = 15 feet
                  Cross sectional area = 15 feet x 22.5 feet = 340 square feet

                                                        B-10
<pb n="275" />

                Pile length:

                    2000 ton x 23 cf/ton x 1.12 gross/net ton
                                    340 sf                           150

                Length = 150 feet; minimum area = 150 x 45 = approx. 7000 square feet

                Other Limestone - Allocate the area at the south end of the dock.         This
                area is approx. 17,000 square feet

                For rectangular pile - width    75 feet, height = 25 feet
                Cross sectional area = 25 feet x 37.5 feet = 940' square feet
                Pile length = 250 feet

                Available storage area:

                          940 sf x 250 sf = 235,000 cf
                          235,000 cf     approximately 10,200 ton's
                          23 cf/ton

                This area could stockpile the remainder of the total annual volume, or 4-5
                barge loads.

          Cost  Estimate for Dry Bulk Terminal    Phase I Operation (inert aggregates only)-

          Minimal Dock Face  Improvements:

          Including the following

                Replacement of one (dislodged) mooring bollard                    $ 1,000
                Replacement of 25 feet of steel sheetpile cap (dislodged)               500
                Minor upgrading of fender system (rub.ber tires)                        500

                TOTAL IMPROVEMENT COSTS                                           $ 2,000

          Estimation of Operating Costs

                All equipment and. personnel to perform loading and unloading operations
                will be supplied by the terminal users.     The only operating cost will be
                administrative (to perform record and bookkeeping tasks), and labor
                involved in minor maintenance of the rubber tire fender system.*

                Oper ating Costs (annual)

                Administrative                                                    $2,000
                O&amp;M labor and materials                                             1,000
                Debt retirement of improvement costs - 10 yrs @ 13%-                  370
                Land lease costs - assessed on the basis of 50c/ton and
                  assuming 10,000 tons/yr                                           5,000

                TOTAL                                                             $8,370

               It is assumed existing staff will be able to assume these duties.

                                                  B-11
<pb n="276" />

          Dry Bulk Terminal - Phase 2 Operation

          Materials with the most shipping potential (currently)

               Crushed stone (mostly limestone)
               Seal coat chips
               Rock salt

          Pit-run sand and gravel do not currently appear to be feasible commodities to
          ship into Ludington, as they are so abundantly available locally.

          Sources of the Materials:

          Limestone and seal coat chips are available from mines in the upper LQwer
          Peninsula and Upper Peninsula.   Rock salt is available in the Detroit area and
          is also shipped from the Gulf Coast.     Thus, these materials are located such
          that water transportation is feasible, particularly in light of the fact that
          both seal coat chips and limestone are now brought into Ludington, and salt
          into Manistee occasionally.

          Projected Annual Quantities:

          Crushed Limestone:    From phone conversations with County Road Commission
          empro-yees, the annual use of limestone varies quite a, bit, but a minimum amount
          of 25,000 cubic yards is typical.     Several local contractors also reported a
          typical annual use of about 5,000 tons.

               6 counties x 25,000 cy x 1.17 ton/cy                        176,000 ton
               10 local contractors x 5,000 tons                            50,000 ton

               TOTAL ESTIMATED ANNUAL CONSUMPTION                          226,000 ton

          Assuming that a terminal in Ludington would capture 50% of this requirement,
          the annual volume through the terminal would be approximately   100,000 tons.

          Seal Coat Chips

          Typical annual use of seal coat chips reported by County Road Commissions is
          1,500 tons

                    6 counties x 1,500 tons -= 9,000 tons

          For a 50% market share, the annual volume would be 4,50  0 tons.

          Rock Salt

          Typical annual use of rock salt by County Road Commissions is 1,500 tons.

                     6 counties x 1,500 tons = 9,000 tons

          For a 50% market share, the annual volume would be 4,500 tons.

          Proposed Bulk Terminal Facilities:

          The bulk terminal would provide open storage for half of the annual volume of
          commodities, or

                                                 B-12
<pb n="277" />

                    50,000 tons limestone
                     2,500 tons seal coat chips
                     2,500 tons rock salt

          Space Requirements:

          Assuming a 1:2 slope for piled material (angle of repose) and pile height of 50
          feet, cross-sectional pile area is:
                    50 ft x 2 x 50 ft -   2,500 sq.ft.
                            2

          Limestone:
                    50,000 tons x 23 cu.ft./ton =   460 ft (length of pile)
                            2,50U-s-q.ft.

          Salt and Seal Coat Chips:
                    2,500 tons x 30 cu.ft./ton x 2 = 60 ft (length of both piles)
                              2,500 sq.ft.

          Total Open Storage Area Required (doubled to allow for access, office building
          and garage):

                    (460 ft + 60 ft) x 100 ft x 2 = 104,000 sq.ft.

                              or approximately 2.5 acres

                                                B-13
<pb n="278" />

           Equipment and Facilities Required:

                     Office - approximately 1,000 sq.ft.
                     Garage - approximately 2,500 sq.ft.
                     Truck Scales
                     Wheel Loader
                     Parking Lot - approximately 1800 sq.ft. or 200 sq.yd.

                                              Cost Estimate
          Site Improv ement Costs           Dry Bulk Terminal
                New Street                            1400 lf  @ $50/lf            $ 70,000

                Sewer - connect to existing
                on Foster St.                          500 lf  @ $20/lf               10,000

                Water - relocate hydrants              200 lf  @ $20/lf                4,000

                Minor dock face improvements           600 lf  @ $100/lf              60,000

          Construction Costs

                Office                                1600 sf  @ $65/sf             $104,000

                Garage                                3600  sf @ $30/sf              108,000

                Parking lot &amp; misc. paving
                  Lot and drive                       6900  sf
                  Drive to garage                     3000  sf
                  Truck loading area                  6900  sf
                                                     16,800 sf @ $5/sf                84,000

                Weigh station                          350  sf @ $20/sf                 7,000

                Truck scales and remote
                reading system                        Lump  Sum                       31,000

                Stockpile covering and
                drainage                              Lump  Sum                       50,000

                Landscaping for Greenbelt            50,000 sf @ $1/sf                50,000

                                                                                    $578,000

                                                    B-14
<pb n="279" />

          Calculation of the Annual Fee - Phase II Operation

          Operating Expenses
               Salaries                                                        $90,000
               Utilities                                                        10,000
               Supplies and Equipment O&amp;M                                        5,000
               Property rental from C&amp;O Railroad
                 Assessed at $0.50/ton for an
                 estimated 100,000 tons annually                                50,000
          Debt Retirement
               $578,000 @ municipal bond rate of   13.0% for 20 years           82,000

          TOTAL           1                                                   $237,000

          Cost per ton (for 100,000 tons annually) = $2.37

          Cost of Limestone Delivered to Ludington:

               Cost of limestone (market price) in Ludington is approximately $18/ton

          Transportation costs:

               Barge from Alpena

                    250 miles x 4t/ton-mile = $10.00/ton

               Cost to truck to market (assume 35 miles average distance)

                    20 miles x 25t/ton-mile = $5/ton
               Fee ($/ton) that t@rminal could charge:

                    $18/ton    market price
                    -10        barge delivery cost, FOB (including material cost)
                    - 5        inland trucking
                    T-3/ton

                                                  B-15
<pb n="280" />

           Liquid Bulk Petroleum Terminal

           Annual consumption of petroleum products in the six-county area is shown in the
           following tables.

                                     Annual Consumption by Fuel Type for 1980 (1000 gals)
                                       Motor            Kerosine        #2 Fuel          Diesel
                 County              Gasoline        01 Fuel   Oil)       Oil             Fuel-'

                 Lake                  2,203              119               171            -0-
                 Manistee             11,744              636            5,694             285
                 Mason                13,616              419            3,063            1,976
                 Oceana                7,394              248            1,273             850
                 Osceola               7,771              560            1,517             158
                 Wexford              12,029            1,085            2,290             128

                 TOTAL                54,757            3,067            14,008           3,397

                                                                 50%    -     -25%           10%
                                  Total 1980 Consumption      of total     of total       of total
               Fuel Type         (TO-0-0--ga-I-)  (barrels)   (barrels)    (barrel-SI      (barrels)

           Motor Gasoline           54,757      1,303,700      651,900       325,900       130,400
           Kerosine
            (#1 Fuel Oil)           3,067           73,000       36,500       18,300          7,300
           #2 Fuel Oil              14,008        333,500      266,800        83,400         33,400
           Diesel Fuel              3,397           80,900       40,400       20,200          8,100
           TOTALS                   75,229      1,@91,100      895,600       447,800       179,200

           1.    Average gas service station size from our work for 4-Star Service Station.

                 From service station data, average storage by fuel type:

                            Regular                  35%
                            No Lead                  25%
                            Premium                  25%
                            Remainder                15%  (fuel oil, range oil, and diesel fuel)

           2.    Average tank truck   size: 10,000     gallons

           3.    Average railroad tank car size:      40,000 gallons

                                                       B-16
<pb n="281" />

          4.   Average tank barge size:

               From Greenwood's Guide -
                     Powered Tankers    # of ship tanks range from 4 to 27
                                        net tonnage ranges from 12 to 10,000
                     Tank Barges        # of tanks range from 3 to 16
                                        capacity ranges from 6,300 to 142,000 bbls
                     Average of "typical" size appears to be 20,000 bbl capacity
                     with ten (10) tanks
                          Overall Length - approximately 230 feet
                          Draft - approximately 12 feet

          Balance Sizes with Volumes:

          Hinterland area yearly consumption of fuels is 1,791,100 barrels.
                     50% of market share = 895,600 bbls
                     25% of market share = 447,800 bbls
                     10% of market share = 179,200 bbls

          Storage Requirements:

          One of the controlling factors on sizing of terminal facility might be winter
          weather restrictions.   For a two-month storage requirement:

                              25% Share

                          447,800 bbl/yr
                           74,600 bbl/2 mos

          Storage requirements by type of   fuel
                     Gasoline         54,300 bbl
                     Kerosine          3,050 bbl
                     #2 Fuel Oil      13,900 bbl
                     Diesel Fuel       3,350 bbl

            Tanks and sizes to meet above   requirements
               Gasoline
                  Regular                 2 - 15,000  bbl
                 No-Lead  &amp; Premium       3 - 12,000  bbl
               Kerosine                   1 -   6,000 bbl
               #2 Fuel Oil                1 -  12,000 bbl
               Diesel Fuel                2 -   6,000 bbl

          This allows for  some rotating  of storage  capacity if necessary.

          Assuming a 25% market share, the average    month's requirements are 37,300 bbls.

          For an average tank barge capacity of 20,000 bbl, this would require approx.
          2 barge deliveries/month.

                                                   B-17
<pb n="282" />

           If 50% of product is trucked to destination and 50% by rail, then:
                     80 truck loads/month
                      3 truck loads/day
                     20 rail cars/month
                      1 rail car/day

           If a typical gas station sells 600,000 gal/yr, or 50,000 gal/mo, the port could
           supply 30 gas stations.

           Cost Structure:

           for 15% Profit -    $782,000/yr ON and Debt Retirement
                               $117,300/yr Profit

                           Operating Fees                        Fee Structure
                     Market             Gallons                  for 15% Profit
                     Share             Per Year              $/Gallon      VGallo-n

                      50%             37,529,000              0.0240        2.40
                      25%             18,764,500              0.0479        4.79
                      10%              7,505,800              0.1198       11.98

                     Operating Expenses                                   Cost/Year

                     Salaries: Administration                             $ 50,000
                                Operators                                   60,000
                     Utilities and electric                                 25,000
                     Misc. supplies                                           5,000
                     Maintenance and equipment repair                       15,000
                     Capital facilities: retirement                        627,000
                                                                           $782,000

           Construction Cost Estimate
                     Office (1200 sf @ $65/sf)                          $   78,000
                     Service Building (1600 sf @ $30/sf)                    48,000
                     Parking and Loading Area
                       (17,750 sf @ $5/sf)                                  89,000
                     Truck Loading Racks                                    40,000
                     Tanks and Appurtenances
                          24,000 bbl - 2 @ $400,000                        800,000
                          15,000 bbl - 4 @ $300,000                       1,200,000
                           7,000 bbl - 3 @ $175,000.                       525,000
                     Concrete Tank Foundations
                          (3,500 cy @ $250/cy)                             875,000
                     Earthwork for Dikes
                       (4,150 cy @ $101cy)                                  42,000
                     Piping and Pumps                                      104,000
                     Fencing (2,600 lf @ $12/lf)                            31,200
                     Gates (2 @ $3,500 each)                                  7,000
                     Foam Extinguishing System                              40,000
                                                              TOTAL      $4,407,000

                                                  B-18
<pb n="283" />

                                              DATA SOURCES

          1.    1982 Means Construction Cost Data (Unit Prices)

          2.    1982 Means Square Foot Costs

          3.    1982 Dodge Guide to Public Works and Heavy Construction

          4.    1982 Dodge Construction Syst  ems Cots

          5.    1982 Dodge Manual for Building Construction Pricing and Scheduling

          6.    1981 Commodity Year Book, Commodity Research Bureau, Inc. 1981

          7.    Process Plant and Equipment Cost Estimation, O.P. Kiharbanda, 1979

          8.    Manufacturing:   A Study of Industrial Location; E. Willard Miller, 1977,
                Pennsylvania State University

          9.    Domestic Transportation Practice, Theory and Policy Sampson - Farris, 1971

          10.   Plant Location, Leonard C. Yaseen, 1956, American Research Council, Inc.

          11.   Wood Energy, Michel      L.   Hiser, Proceedings of Governor William G.
                Milliken's Conference, November 29, 1977.

                                                    B-19
<pb n="284" />

                                             This document was prepared in part
                                           through financial assistance prov;!4ed _kv
                                          the Coastal Zone Manapement Act of 1972
                                    administered by the Office of Coastal Zone Management
                                       National Oceanic and Atmospheric Administration

                                                                                  3 6668 14102-5488--
</text>
</doc>
