The chief executive of Motors Liquidation Co (MTLQQ.PK), the old shell of General Motors that remains in bankruptcy court, is hoping that the company will get court approval for a plan of liquidation by the middle of next year, he said on Thursday.

Al Koch, who was named as GM's chief restructuring officer in June and tasked with winding down the liquidation company in July, said Motors Liquidation would seek approval for the plan in mid next-year, which would allow the company to distribute its holdings of New GM stock and warrants to unsecured creditors.

He said his aim was to have a liquidation plan for the old GM assets confirmed by the court by the middle of 2010. That's our objective, Koch said.

The assets that I have and that my team has to liquidate are pretty challenging, Koch said in comments to the Reuters Restructuring Summit in New York, noting that completing most of the liquidation process could take another five years.

The properties that we have to dispose of are so large, that it's going to be very difficult to find users for them, and many of them have some environmental remediation that's required, he continued.

Motors Liquidation is the shell of General Motors that retained all of GM's old unwanted assets and liabilities after the new GM - renamed General Motors Co - emerged from bankruptcy protection in July by completing a sale of its best assets such as Chevrolet and Cadillac to a new company funded by the U.S. Treasury.

Koch said he expects creditors to file claims of at least $30 billion, but not more than $40 billion against the company, but the estate was left with far fewer assets.

Koch, a turnaround expert with advisory firm AlixPartners who also served as chief financial officer of Kmart through its bankruptcy in 2002 and 2003, said he has assembled his staff of about 50 into three teams focused on Motors Liquidation's real estate, equipment, and environmental issues.

The environmental remediation and legal and regulatory issues associated with that could take as long as 30 years to resolve, Koch said, but he expects the company's hard assets could be disposed of over the next five years.

Koch said the company has about 200 properties, of which about 100 are leased to the New GM for its current use, but will eventually revert back to the old company. Many of the properties are plant sites or landfills which it will have to clean up and the company also has about 5,000 robotic machines and other tools that were left on the properties, Koch said.

Motors Liquidation, however, expects to have difficulty finding buyers for its assets as few auto companies are looking to expand at the moment, Koch said.

There is so much capacity that companies have, that it is unlikely people are going to be looking for significant U.S. capacity, Koch said.

Many properties are expected to be repurposed, Koch said, saying he could see some former plant sites being converted into a transportation hub, or is even likely to arrange for unused land next to a nature conservancy to be donated.

Once claims are filed with the court, and the company is able to distribute its stake in the New GM to unsecured creditors, a sort of liquidating trust could be set up to dispose of the rest of GM's old assets, Koch said.

Any funds it recovers at that point, are likely to flow back to the government, which extended some $50 billion of bailout funding to get GM through the period before and after its bankruptcy, he said.

This is a little bit unusual in that the creditors have no interest in the outcome, Koch said. If there's any money left over it goes back to the U.S. Treasury.

(Reporting by Emily Chasan; editing by Carol Bishopric)

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