Nicholas ScoppettaDisaster Planning andPreparedness A Hum.docx

Nicholas Scoppetta
Disaster Planning and
Preparedness: A Human
Story
IN DECEMBER 2 0 0 1 , MAYOR-ELECT MICHAEL
BLOOMBHRG ASKED ME
TO become the city's thirty-first fire commissioner. I had
already
announced that I would leave the Administration for Children's
Services, where I had been commissioner for six years, and was
plan-
ning on leaving government. But, like all New Yorkers, I had
watched in
horror as events unfolded on September 11, 2001, ajid I knew
that the
New York City Fire Department (FDNY) was the hardest hit of
all city
agencies in the attacks. Being asked to help rebuild this storied
New
York institution was an honor, and saying yes was my duty.
Disaster preparedness is at the forefront of the FDNY's mission,
as it is for first responders in cities and towns across the
country. Even
just a passing awareness of current events makes it clear why
disaster
preparedness is so important. At the time this conference was
held,
California was still reeling from some of the worst fires in its
history.
New Orleans had yet to be rebuilt. And for many people in New

York,
the memory of 9-11, our worst disaster, is still painfully fresh.
The New York City Fire Department has been on the ground in
each of those disasters. In addition, in our day to day
operations, the
FDNY oversees fire and life safety for our 8 million inhabitants
and the
millions more who work and visit the city every day. We
respond to all
emergency medical and fire calls in the more than 321 square
miles of
the five boroughs. In 2007 our more than 11,000 firefighters put
out
over 50,000 fires. Our emergency medical technicians and
paramedics
responded to 1.3 million calls.
social research Vol 75 : No 3 : Fall 2008 807
In the last several years we have responded to a wall collapse
and
landslide on a busy highway, two building explosions, a single
engine
plane crashing into a high-rise apartment building, a huge fire at
an
ExxonMobil oil storage facility and a citywide blackout. All of
these crit-
ical situations were handled skillfully by our members with
minimal
loss of life.
In a city this size, literally anything can happen. So how to
manage the monumental task of protecting it? Two elements are

abso-
lutely vital in this equation: capability and flexibility.
Capability is having the necessary tools at our disposal—
including
the most reliable and up-to-date equipment—and placing our
resources
in locations where they vdll be most accessible and effective. It
means
having plans at the ready to deal with the events that are hkely
to occur.
And most important, it means having well-trained first
responders.
The importance of planning and preparedness cannot be over-
stated. But of course plans and preparations alone will not come
to the
rescue in a difficult moment. We must have people who are
capable of
implementing those plans.
We simply do not know what the next major incident is going
to be, and so we must be flexible. We have to be ready for
whatever
happens. It could be a chemical attack. It could be a Category 5
hurri-
cane. It could be another blackout or brovmout. To put it
another way,
we plan for an event; we do not plan for the event.
Of course, the biggest event in the FDNY's history came on
September 11, 2001. It was an event that changed everything for
the
department. And it brought the concept of disaster preparedness
to the
forefront in state and local governments across America as

never before.
Before 9/11, our firefighters were mainly trained to respond
to unintentional acts. While loss of life and unknown dangers
were
always part of the job, it was not until the World Trade Center
attack
in 2001 that the department was faced with the reality of
responding
to an attack deliberately designed to kill thousands upon
thousands of
people. That grim realization was compounded by the terrible
losses
this department suffered that day. The numbers are well known,
but
808 social research
are no less astounding for their familiarity. 343 members were
killed,
vwth a combined 4,400 years of experience—all in the space of
102
minutes. We lost people of every rank: from firefighters straight
out
of our training academy to our highest ranking officers,
including the
chief of the department and the first deputy commissioner. Then
came
the retirements. In 2002, almost 1,300 uniformed members
retired
from the department. In 2003, 700 members retired. Before 9-
11, about
500 people could be expected to retire in a year. In the last 6
years, 50

percent of the department turned over.
I became commissioner on January 1, 2002, three months after
the terrorist attacks. We immediately turned our attention to the
monu-
mental task of rebuilding this great institution, which was at
that time
a department in mourning.
The first step was to get some help in figuring out what went
right
and what went wrong vwth our response on 9-11.1 asked the
renowned
consulting firm McKinsey & Company to analyze our response
to the
attacks, review our operations and procedures, and make
recommen-
dations as to how we could increase our preparedness.
McKinsey produced a comprehensive and detailed report, and in
response to its findings, we set about implementing the
recommenda-
tions, including presenting the FDNY's first ever strategic plan.
McKinsey's report and our strategic plan laid out a road map
for strengthening the department by setting a clear set of
priorities.
September 11 showed us that the rules of the game had changed.
In
response, our priorities had to change as well.
We greatly enhanced the training given to our members of all
ranks, both fire and emergency medical services (liMS). When I
came
to the department, our firefighters spent 13 weeks at our
training acad-

emy before coming on the job. Now, they study and train for 23
weeks.
We have also stepped up our more specialized training. We
trained
more than 3,600 fire and EMS members in advanced ) lazardous
materials
response, which is nearly five times the number we liad before
9-11.
In addition, we devised two advanced-level courses for our offi-
cers: one in conjunction with Columbia University that focuses
on
Disaster Planning and Preparedness: A Human Story 809
management, and another with West Point that focuses on
combating
terrorism. These two programs give our senior members a level
of train-
ing and education unprecedented in the department's history.
One of the key points made in the McKinsey report was the
depart-
ment's need for a technologically sophisticated operations
command
center. In 2006 we opened a $17 million state of the art facility
located
in our headquarters. The New York Gity Fire Department
Operations
Genter (FDOG) gives us unprecedented situational awareness
and the
ability to direct operations remotely. There we have access to
maps,

building records, and information on local infrastructure that
helps
our commanders make informed tactical decisions. The FDOG
has the
capability to receive real-time video feeds so commanders in the
FDOG
can see how the incident is progressing. And it is our critical
point of
contact with city, state, and federal agencies.
There have been several instances when the FDOG proved
critical
to our operations. In May 2007 a fire broke out on the roof of
the build-
ing that housed the leather goods company Goach in Manhattan.
From
the street it looked as though the top fioor and roof were on
fire. Our
video feed showed that the fire was confined to wooden storage
sheds
on the roof This entirely changed our tactics and allowed
firefighters
to quickly suppress the fire.
We made other crucial improvements in technology. Most
impor-
tant, we deployed new handie-talkie radios to the field. These
radios
provide significant advantages over the models that were in use
on
9-11. Our current radios also support many more channels and
use the
ultra-high-frequency (UHF) band, which allows for greater
penetration
in buildings and, crucially, allows for interoperability with
other agen-

cies, including the Police Department, which uses UHF. In
addition, we
developed a system for mobile communication in high-rise
buildings
that consists of handie-talkies, high-powered post radios, and
battahon
car repeaters. In effect, we devised a mobile communications
system
that is similar to the system used by the military that we carry
with us.
We have made improvements to the equipment that we give
our members to improve their safety. Last year we deployed
radiation
detectors and new masks that protect from chemical and
biological
810 sociai research
agents. We also began using new and improved personal safety
ropes
that allow our firefighters a secure way to escape a building
should they
become trapped.
One issue that became glaringly clear after September 11, 2001
was that better coordination and information sharing was needed
between first responder agencies. Until then the FDNY had
functioned
on its own, with little thought given to seeking outside help.
After the
devastating attacks, however, we realized, along with most
other agen-
cies, that cooperation is absolutely vital.

In 2005, Mayor Bloomberg and the Office of Emergency
Management developed a Citywide Incident Management
System,
known as CIMS, a protocol for managing emergencies that
involve
multiple agencies. CIMS defines how citywide emergencies or
large-
scale multiple incidents will be managed, and uses as a template
the
National Incident Management System known as NIMS.
Another major change was our development of Incident
Management Teams. IMTs are made up of emergency
professionals to
respond to and provide support at large-scale events that are
likely to
last more than 24 hours—the kind of event where first
responders can
quickly become overwhelmed.
The FDNY learned how helpful IMTs could be in the immediate
aftermath of 9-11, when the massive recovery operation was
under way
at the World Trade Center. The IMT concept had been
developed by the
United States Forestry Service primarily to deal with natural
disasters.
After the attacks, a Forestry Service Incident Management Team
came to
New York and offered to help the FDNY effort at Ground Zero.
It turned
out they were of enormous assistance with logistics and
planning, keep-
ing our members fed and supplied with everything they needed
and

effectively putting a management imibrella over the recovery
operation.
This was a departure from how things were normally done. As
one chief put it at the time "if you had told us six weeks ago
that
the Forestry Service would be bailing us out, we would've had
you
committed."
We began training our members in Incident Management proto-
col in 2003. Then, in 2005, disaster struck the Gulf states in the
form of
Hurricane Katrina. And when the call for help came from
Louisiana, we
were in a position to respond.
Within 24 hours, we had 350 firefighters medically evaluated,
inoculated, and on their way to New Orleans, including 24
members of
our Incident Management Team. They arrived to find the city in
sham-
bles and the New Orleans Fire Department exhausted and
drained. Our
members were able to help not just put out fires, but also
transport
supplies and establish a command support structure. In total,
650 of
our members were activated for duty in New Orleans—at full
strength,

the entire New Orleans Fire Department had about 700
members.
In October we sent 7 IMT-trained members to Cahfomia to help
the agencies there deal with the fires that were sweeping across
the
state. They were put to work dealing with logistics, making sure
that the
people fighting the fire had all the water, fuel, food, and
sanitary supplies
they needed. In August 2006, we sent a team to forest fires in
Idaho. We
will soon have 150 members trained in this management
specialty.
Here in New York, the department has partnered with multiple
agencies both at drills and tabletop exercises and at real-life
events.
And it has paid off. For example, in July 2007 a 24-inch steam
pipe that
lay underneath a busy street in Midtown Manhattan exploded. A
geyser
of superheated steam and debris burst through the pavement.
Our
response had to be coordinated among several agencies: the
police. Con
Edison, the Department of Health, the Department of
Environmental
Protection, and the Office of Emergency Management. We
successfully
set up a unified command, under a protocol established by the
Cityvdde
Incident Management System.
And, in what was perhaps the most groundbreaking inter-
agency project in our history, in September 2007 we partnered

vdth
the Department of Homeland Security in an intelligence-sharing
proj-
ect that included fire departments from across the country. It is
well
known that it is highly unusual for federal government to share
intelli-
gence reports with local governments. We now receive these
reports—
an indication of just how much that paradigm has changed.
A couple of public misperceptions persist about the FDNY's
response on 9-11. The most prevalent is that chaos and
confusion
812 social research
reigned at the site before the buildings collapsed. While there
were
flaws in the responses of all the emergency agencies, including
the
FDNY, video footage and photographs show that firefighters
and fire
officers acted in a cohesive, disciphned, and professional
manner in
accordance with their training. Moreover, they had received
training
specific to the World Trade Center. Firefighters and fire
officers knew
the buildings well. They even conducted drills in them and
tested the
radio repeater system.
Firefighters, it is often said, are a special breed. And that is no

cliché. They love to fight fires, they crave the action. They are
the last
man out. They are always anticipating "the big one." But no one
in the
department could ever have imagined that "the big one" would
happen
in the way it did.
For the firefighters who responded to the World Trade Center
after the planes hit and who faced the job of rescuing trapped
civilians,
the awesome severity of the situation was immediately and
terribly
clear. Put simply, no one had seen anything üke thi.s before.
Not even
the most senior men with 30 or 40 years on the job. Not even
the two
highest-ranking officers. Chief of Operations Daniel Nigro and
Chief of
Department Pete Ganci.
As they drove across the Brooklyn Bridge together to get to the
burning Trade Center, Chief Nigro said to Chief Ganci: "This is
going to
be the worst day of our lives." Chief Ganci was killed in the
collapse of
the Trade Center towers.
Despite this grim reality, firefighters and fire officers like
Captain Terry Hatton did their job. Terry was a well-respected
officer
in command of one of our elite units. Rescue 1. A fellow
firefighter and
friend recounts that he saw Terry in the command ]5ost set up
in the
North Tower that morning. Terry said: "I love you, brother. This

might
be the last time I see you." They hugged, anticipating the worst,
then
Terry went up into the building. He never made it out.
Another remarkable story is that of Battalion Chief Orio
Palmer.
Chief Palmer—an accomplished athlete and marathon runner—
took
an elevator to the fortieth floor of the South Towei- and from
there
proceeded to the upper floors, on foot, carrying 75 pounds of
equip-
ment, looking for trapped survivors. As he made his way toward
the
massive fire, he methodically radioed crucial information and
warn-
ings about breached walls and nonworking elevators. He
climbed all
the way to the seventy-eighth fioor, just below the impact zone.
There he found numerous bodies and fire. On the tape of his
radio
transmissions, he is heard gasping, shocked at what he sees. He
called
for two hose lines. He realized the fire is too big to put out, but
hoped
to soak down the stairways and get above the firestorm raging
on the
eight fioors above him to rescue people trapped there. He
radioed one

of his officers, who is a few fioors below him, calling for the
hose lines.
The response came back immediately: "we're on our way."
Minutes later the radio falls silent. There is a deafening roar as
91
fioors of steel and concrete collapse, crushing Chief Palmer, his
team,
and hundreds of others.
The poet Emerson wrote "There is properly no history; only
biog-
raphy." I think that, in times of life-threatening crisis, in times
of disas-
ter, the most important protagonists are often ordinary men and
women
who, in the course of their everyday tasks, perform
extraordinary deeds.
Responding to a disaster requires logistical and tactical
planning
and scientific calculation. But disaster response is also a human
story,
a contest between personal will and adversity, and of the human
spirit
challenging terrible odds.
It is the story of people like Chief Ganci, Captain Hatton,
Chief Palmer, and the chiefs who currently direct operations at
the
Department, Chief of Department Sal Cassano, Chief of
Operations Pat
McNally, First Deputy Commissioner Frank Cruthers, and the
thousands
of others who responded to the Trade Center attack, overcame
the stag-

gering losses, and went on to build a stronger, even more
dedicated and
better prepared department.
Our safety, our future, perhaps our very existence may well
depend on such people.
814 social research
349
Problem: Florida’s 1985 Growth Man-
agement Act required the state’s coastal
communities to include policies for two
types of hurricane hazard zones in their
comprehensive plans: to direct populations
away from coastal high hazard areas
(CHHAs) and to maintain evacuation times
within larger hurricane vulnerability zones
(HVZs). State law requires local governments
to initiate measures to implement these
policies within one year of state approval of
the local plan. Have communities complied
with these state mandates?
Purpose: This research aims to determine
the extent to which post-plan residential
development intensities within hurricane
hazard zones conform to the state’s policy

mandate and the degree to which success in
this regard can be explained by the quality
of local plan maps and policies.
Methods: We conducted graphical analysis
of development trends, and undertook quasi-
experimental analysis of pre- and post-plan
residential development inside and outside
CHHAs, as well as analyzing correlations
between plan quality and post-plan resi-
dential development intensity. We also
conducted interviews for case studies.
Results and conclusions: We found
residential exposure to hurricane flood
hazards to have increased substantially in
the majority of 74 municipalities and 15
coastal counties in Florida after the state
approved local comprehensive plans.
Residential development inside CHHAs
did not slow after plans were adopted by
most of these coastal communities. We
found better maps and stronger policies to
be correlated with lower post-plan develop-
The Proof of the Planning
Is in the Platting
An Evaluation of Florida’s Hurricane Exposure
Mitigation Planning Mandate
Robert E. Deyle, Timothy S. Chapin, and Earl J. Baker
O
ver the last several decades, some states have taken back land
use

management authority they traditionally delegated to local
govern-
ments. Such state activism aims to protect public welfare by
minimiz-
ing spillovers from local land use practices on other
communities, protecting
natural resources and public health, and minimizing the public
costs of impru-
dent local decisions. Many states have intervened directly,
adopting and
enforcing state regulations to control the management of solid
waste, waste-
water, and storm water, and to minimize development impacts
on natural and
historic resources. More than a dozen states have employed
what Burby et al.
(1997) call the “comprehensive planning approach” to achieve
such goals.
These states have defined overall policy goals and employed a
variety of statu-
ment intensity, but the policy quality effect,
though not the map quality effect, dis-
appeared after controlling for pre-plan
development intensities. These results may
be due in part to vesting of development
approved prior to adopting the plans, pre-
existing zoning entitlements, and Florida’s
1995 property rights law.
Takeaway for practice: State planning
mandates aimed at managing development
in critical areas are likely to have only
marginal effects because of prior entitlements
and the legal and political inertia of existing

local plan policies and land development
regulations.
Keywords: comprehensive plan imple-
mentation, plan quality, state planning
mandates, hazard mitigation policies, Florida
Research support: Research support was
received from the National Oceanic and
Atmospheric Administration’s Office of Sea
Grant, the Florida Department of Commu-
nity Affairs, and Florida State University’s
DeVoe Moore Center.
About the authors:
Robert E. Deyle ([email protected]) is a
professor of urban and regional planning
at Florida State University. His principal
research concerns plan implementation in
the context of coastal hazards and adaptive
response planning to sea level rise. Timothy
S. Chapin ([email protected]) is an associate
professor of urban and regional planning at
Florida State University. His teaching and
research interests are in the areas of growth
management, comprehensive planning, and
downtown development. Earl J. Baker
([email protected]) is an associate professor of
geography at Florida State University. His
current research focuses on the effects of
hurricane experience on future evacuation
response.
Journal of the American Planning Association,
Vol. 74, No. 3, Summer 2008

DOI 10.1080/01944360802229612
© American Planning Association, Chicago, IL.
74-3 06 323128 Deyle P 7/11/08 9:04 AM Page 349
tory mandates and incentives to foster and enhance the
preparation of local comprehensive plans and their imple-
mentation through development controls and other growth
management measures. Both the direct intervention and
the comprehensive planning approaches have focused on
critical areas that provide public benefits or present hazards
to public welfare, including wetlands, productive coastal
waters, wildlife habitat, scenic areas, historic and archeo-
logical resources, aquifer recharge areas, prime agricultural
soils, floodplains, and other areas exposed to natural hazards
(see, e.g., Washington State Department of Community,
Trade and Economic Development, 2003).
Where states follow the comprehensive planning
approach, achieving state goals depends on two tiers of
implementation: (1) state agencies implementing legislated
state goals and objectives and (2) local governments im-
plementing state agency directives. As Burby et al. (1997)
observe, the outcome of state agency implementation
depends both on the level of effort expended by the agency
and on the style they employ in interacting with local
governments. However, even among the most prescriptive
of the states that mandate local comprehensive planning
(i.e. Florida, Maine, Oregon, Rhode Island, and Vermont),
the reach of state oversight does not extend beyond the
content of the plans adopted by local governments. Thus,
effective local implementation of state goals is determined

by the quality of the plan policies adopted by local gov-
ernments, how local officials translate those policies into
development controls and other growth management
measures, and how they enforce those measures.
We count ourselves among the “logical-positivists”
(Gilg & Kelly, 1997) who believe that implementing
comprehensive plan policies can have a significant impact
on the state of the world and, therefore, that it is useful
to evaluate the extent to which planning goals have been
achieved (Alexander & Faludi, 1989; Burby et al., 1997;
Preece, 1990; Talen, 1996a, 1996b). Toward that end,
this article addresses both plan conformity (whether plan
implementation behaviors or outcomes conform to state
goals), and plan quality (whether better quality plans are
associated with better outcomes).
We pursue these two topics by examining the effec-
tiveness of Florida’s growth management mandates for
mitigating exposure to hurricane hazards by limiting
development in hazardous areas. Vulnerability to natural
hazards is widely recognized as a significant constraint on
the long-term sustainability of human settlements and thus
an important concern of comprehensive planning (Burby,
1998; Burby, Deyle, Godschalk, & Olshansky, 2000;
Burby et al., 1997; Godschalk, Brower, & Beatley, 1989;
May et al., 1996; Mileti, 1999). Continued exponential
growth along the United States’ coasts has increased the
numbers of people and amount of property vulnerable to
the high winds, waves, and storm surge flooding of cata-
strophic coastal storms (Burby, 1998; Godschalk, Beatley,
Berke, Brower, & Kaiser, 1999; Pielke & Pielke, 1997;
The H. John Heinz III Center, 2000).
Growth management strategies such as land develop-

ment regulations, capital facilities policies, land acquisition,
and taxation and fiscal policies are frequently advocated as
nonstructural means communities can use to reduce their
vulnerability to natural hazards (Burby, 1998; Burby et al.,
2000; Godschalk et al., 1989; May et al., 1996; Mileti,
1999). However, there have been few rigorous analyses of
these strategies. While a number of studies have analyzed
the quality of the hazard mitigation policies in local
comprehensive plans in Florida and other states (Berke
& French, 1994; Berke, Roenigk, Kaiser, & Burby, 1996;
Brody, 2003; Burby et al. 1997; Deyle & Smith, 1998),
no one has analyzed the extent to which better plans are
associated with better development management outcomes.
We employ a quasi-experimental research design to
assess whether residential development patterns in desig-
nated hurricane hazard zones conformed to state directives
requiring Florida coastal communities to reduce the vul-
nerability of people and property in such areas. In addition,
we use multivariate modeling to measure the extent to
which the content of local comprehensive plans explained
residential density after localities adopted plans to meet the
state mandate. We supplement our empirical analyses with
case studies from a subsample of coastal communities as
well as interviews with state officials who oversaw review
and approval of local comprehensive plan amendments
during the study period. These qualitative inquiries help
to illuminate the stories behind our observations.
Our findings suggest that existing local policies and land
use entitlements fundamentally constrain any alterations
new state policies can make to development patterns. While
some coastal communities have successfully limited devel-
opment in hazardous areas, implementation of the state’s
mandate has been blunted by state and local officials who
perceive political and legal constraints to altering entitle-

ments. Our results do demonstrate that development is
more likely to conform to state goals when maps of future
land use in local comprehensive plans explicitly show
critical areas.
We believe our results apply to a broad range of
comprehensive planning objectives because the following
factors constrain local government conformity with all state
initiatives to influence development management of critical
areas (Burby et al., 1997; May et al., 1996; Olshansky &
Kartez, 1998): (a) weak or absent local political constituen-
350 Journal of the American Planning Association, Summer
2008, Vol. 74, No. 3
74-3 06 323128 Deyle P 7/11/08 9:04 AM Page 350
cies for the state goals; (b) competing local issues of greater
perceived priority; (c) short-term political and fiscal costs of
implementing the state mandate combined with uncertain
future benefits; (d) limited local capacity to implement
state directives; and (e) pre-existing local development
management measures that are perceived as entitlements
to specific land uses and densities.
In the following sections, we briefly summarize both
plan conformity and plan quality research approaches, and
what studies taking these approaches have learned about
implementing hazard mitigation policies. We then present
an overview of the Florida growth management and coastal
planning context, after which we take up each of our plan
implementation questions. In the final section, we explore
the underlying phenomena that may explain our findings
and their implications for future efforts to change local

planning and development management through state
mandates.
Plan Conformity Research
One important segment of plan conformity research
has examined whether the prescription and persuasion
states employ when they mandate planning shapes the
content of local comprehensive plans (Burby et al., 1997).
In a comparative study of five states, Burby and his col-
leagues showed that the natural hazards elements of local
plans were higher quality in states that coupled strong
mandates with formal state review of local plans and the
threat of state sanctions where local governments failed to
comply (see especially Berke & French, 1994; Burby &
Dalton, 1994; and Berke et al., 1996). Related studies have
also shown that state oversight and sanction authority result
in better plan quality (May & Burby, 1996; May et al.,
1996).
Florida appears from these studies to have the most
effective mandate, measured by the comparative quality of
the natural hazards elements of local comprehensive plans.
A study by Deyle and Smith (1998), however, revealed
that there was considerable inconsistency in the quality of
local plans, and that many fell short of complying with the
substance of the state mandate. They attributed this in-
complete and variable conformity to the Florida Depart-
ment of Community Affairs (DCA) according a relatively
low priority to the natural hazard goals of the state growth
management statute, and to differing levels of scrutiny of
draft plans under different agency administrations.
Researchers examining whether plan outcomes conform
to plan policies have focused primarily on behavioral
measures, including subsequent zoning or plan amendments

(Johnston, Schwartz, & Klinkner, 1978; Johnston, Schwartz,
& Tracy, 1984), subdivision approvals (Alterman & Hill,
1978; Johnston et al., 1978), and development permit
issuance (Anderson, 1981; Blacksell & Gilg, 1977, 1981;
British Tourism and Recreation Research Unit, 1981;
Brody & Highfield, 2005; Brotherton, 1992; Curry, 1992;
Gregory, 1971; Keyes, 1986; Moore & Nelson, 1993;
Nelson & Moore, 1996). Two studies are noteworthy
because the authors analyzed actual land use patterns.
Talen (1996a) examined changes in community recreation
facilities following adoption of the recreation element of
the Pueblo, Colorado, comprehensive plan. More recently,
Esnard, Brower, and Bortz (2001) assessed differential
development patterns inside and outside of flood hazard
zones in Nags Head, North Carolina.
One of the principal challenges in conducting plan
and policy implementation research is obtaining sufficient
data to employ a research design that can both demonstrate
that the plan or policy intervention is associated with a
change in behavior or the state of the world, and control
for unmeasured variables that may affect behavior or the
state of the world independent of the plan or policy being
evaluated. The ideal research design is a pretest/post-test
design with control groups (Cook & Campbell, 1979;
Preece, 1990). However, few studies attain this ideal.
Several studies of the impacts of comprehensive plans
have used simple posttest only research designs that exam-
ine land use changes or permit issuance behavior after plan
adoption within a single community or regulatory frame-
work (e.g., Alterman & Hill, 1978; Brody & Highfield,
2005; Johnston et al., 1984; Esnard et al., 2001). Many
researchers have employed cross-sectional designs that
include control groups to compare development activity

inside and outside of regulated areas (e.g., Anderson, 1981;
Blacksell & Gilg, 1977, 1981; British Tourism and Recre-
ation Research Unit, 1981; Burby & French, 1981; Burby
et al., 1988; Nelson & Moore, 1996). However, in these
studies it is possible that different development patterns
observed inside and outside the regulated areas simply
continue practices already occurring, independent of the
adoption of the new policies. Other researchers have used
pretest/posttest designs within single jurisdictions to assess
the impact of plan policies (e.g., Johnston et al., 1978;
Talen, 1996a). These studies, however, cannot rule out the
effects of other factors that may have led to the observed
changes over time.
The exceptions are limited. Three studies of permit
issuance in Great Britain employed pretest/post-test control
group research designs (Brotherton, 1992; Curry, 1992;
Keyes, 1986). More recently, Burby, Salvesen, and Creed
(2006) employed such a design to examine how adopting
Deyle et al.: The Proof of the Planning Is in the Platting 351
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a rehabilitation building subcode affected the issuance of
rehabilitation permits in jurisdictions inside and outside
of New Jersey.
To date, studies of whether plan implementation
behavior and outcomes conform with hazard mitigation
policies have relied principally on subjective data to assess
the effectiveness and impacts of local hazard mitigation
policies and programs (i.e., interviews or surveys of local
planning officials). Findings have been mixed. In a study

of development permits issued in 1978 by a sample of
communities participating in the National Flood Insurance
Program (NFIP), Burby and French (1981) found com-
munities that had already substantially developed their
floodplains were more likely to participate in the NFIP,
but were also more likely to issue higher proportions of
their development permits for construction within 100-year
floodplains. Yet, in a comparative study of 10 communities,
Burby et al. (1988) found evidence that floodplain manage-
ment effectively reduced development in the flood-hazard
area, as 7% of each community’s land area lay within the
100-year floodplain on average, while an average of only
2.2% of the building permits issued over a 10-year period
were granted for new structures within the floodplain. In
contrast, Esnard et al. (2001) found that in 1997, 42% of
the developed property parcels in the coastal town of Nags
Head, North Carolina, lay within the 100-year flood zones
designated under the NFIP.
Plan Quality Research
The second line of plan implementation inquiry has
attempted to ascertain whether or not differences in plan
or land use regulation content are correlated with plan
implementation outcomes. These studies have typically
employed multivariate models that control for other
possible causal variables. Most, however, have used cross-
sectional research designs that do not control for conditions
that preceded the intervention.
Burby and Dalton (1994) examined an intermediate
step in plan implementation, the adoption of land devel-
opment regulations based on plan policies. They found
that communities with higher quality plan policies limiting
development in hazardous areas were more likely to actually
adopt growth management measures for imposing such

limitations.
Findings from studies that attempt to explain imple-
mentation behavior have not provided consistent and
compelling evidence of the efficacy of plan policies. Burby
and French (1981) tested bivariate correlations between the
percentage of building permits issued within floodplains
and the numbers and stringency of floodplain management
regulatory measures employed by flood-prone cities. They
found only weak evidence that more comprehensive and
stronger regulations were associated with less floodplain
development. Brody and Highfield (2005) compared
wetland development permits issued by the state of Florida
and the U.S. Army Corps of Engineers (USACE) within
individual watersheds with future land uses designated in
local comprehensive plans. Contrary to their expectations,
they found that permit issuance was less likely to conform
to future land use designations in watersheds where local
comprehensive plan environmental policies were stronger.
Yet conformity was higher where plan implementation
policies were high quality. In a follow-up multivariate
analysis of these data, Brody, Highfield, and Thornton
(2006) amended these results to support only the link
between implementation policy quality and conformity,
reporting that the quality of environmental policies in local
comprehensive plans had no significant relationship with
whether wetland permits conformed to local land use
designations.
Berke et al. (2006) found that the design and structure
of a plan may mediate the influence of plan policies on
development outcomes. In a study of storm water manage-
ment permits issued by district councils in New Zealand,
they found that permit conditions were more likely to
reflect plan policies where the quality of plan design and

structure was higher.
Nelson and French (2002), on the other hand, exam-
ined the relationship between plan quality and a measure
of physical outcomes. They applied a plan quality scoring
method to assess the effects of comprehensive plan seismic
safety elements on subsequent earthquake damage in
California. Using multivariate models that controlled for the
exposure and vulnerability of housing stock to earthquake
ground shaking and earthquake intensity, they found that
levels of residential damage after the 1994 Northridge
earthquake were lower in those communities whose seismic
safety elements had higher quality scores.
Taken as a whole, this literature has yielded the rather
humble conclusion that “Plans can matter!” (Burby &
Dalton, 1994; exclamation point in the original). This
research suggests that the substantive quality of plan policies
has at best a modest influence on the development out-
comes they are designed to shape. The recent analysis by
Berke et al. (2006), however, suggests that plan design and
structure may also affect plan implementation success. We
next describe the Florida state planning mandate context
within which our study is set.
2008, Vol. 74, No. 3
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The Florida Growth Management
and Coastal Planning Context
Florida’s growth management planning mandate

(Florida Growth Management Act, 1985a) offers fertile
ground for exploring plan conformity and plan quality
implementation questions because it is a highly prescriptive,
top-down system in which state laws and regulations set
out very explicit requirements governing the scope of local
comprehensive plan goals, objectives, and policies (Ben-
Zadok, 2005; Chapin, Connerly, & Higgins, 2007; Pelham,
2001). Local governments are required both to adopt local
plans that conform to state rules and to implement the
policies in those plans through local land development
regulations. Research on plan implementation in Florida
is facilitated by the state’s review and reporting procedures,
which have resulted in a central record-keeping system that
allows tracking changes in local plan policies over time.
The first comprehensive plans developed under
Florida’s 1985 planning mandate were adopted by local
governments and approved by the Florida DCA between
1988 and 1991.1 However, most local governments in the
state had comprehensive plans in place prior to the 1985
act, because an earlier statute (Local Government Compre-
hensive Planning Act, 1975), required local governments
to adopt plans in conformance with it by 1979 (Pelham,
2007). Many of these local governments already also had
zoning ordinances in place when they crafted their revised
comprehensive plans in the late 1980s and early 1990s.
The 1985 act required local governments to enact land
development regulations (LDRs) and to take other initia-
tives to implement their plan policies (Florida Growth
Management Act, 1985b). Where existing LDRs, including
zoning ordinances, were at odds with policies in the new
plans, local governments were required to amend the
LDRs accordingly (Florida Growth Management Act,
1985c). Thus, implementation of new comprehensive plan
policies occurred over several years as LDRs were brought

into conformance with the plans following approval by
DCA. In addition, most local governments have subse-
quently made periodic, piecemeal amendments to their
comprehensive plans, as well as completing mandated
synoptic plan updates on a seven-year cycle (Florida Growth
Management Act, 1985d). These amendments are reviewed
by DCA for conformity with the state statute and regulations
(Florida Growth Management Act, 1985e).
Regulations adopted by DCA (Requirements for
Coastal Management Goals, Objectives, and Policies Rule,
2007), require coastal counties and municipalities to
include objectives and policies in their comprehensive
plans that limit development in and direct populations
away from “coastal high-hazard areas” (CHHAs) and
maintain or reduce evacuation times within “hurricane
vulnerability zones” (HVZs). The state statute initially
allowed local governments flexibility in defining CHHAs
(Florida Growth Management Act, 1985a, §7). A subse-
quent amendment to the statute (Law of May 11, 1993)
changed the minimum CHHA definition to the evacuation
area for a Category 1 hurricane.2 An HVZ is defined by
state rule as the area that would be evacuated for a Category 3
hurricane (Definitions Rule, 2007).
In the next section, we examine whether or not residen-
tial development that has occurred in coastal communities
since local plans following the 1985 state law were approved
is consistent with these mandates.
Plan Conformity: Has the World
Changed as It Should?
We used county property appraiser data to analyze
residential land use change at the parcel level inside and

outside of hurricane hazard zones in 89 coastal jurisdictions
to assess how well post-plan residential development has
conformed to this planning mandate. We addressed three
plan outcome questions:
1. How did residential land use change within the
hurricane hazard zones of coastal communities in
Florida following approval of local comprehensive
plans by DCA?
2. How did those land use changes affect the exposure
of people and property to hurricane flooding?
3. To what extent did land use changes differ inside
and outside the communities’ CHHAs before and
after approval of local comprehensive plans?
Three hypotheses inform this research. The first is
based on Deyle and Smith’s (1998) finding of significant
variation in local governments’ compliance with the state’s
mandate to include hazard mitigation policies in local
comprehensive plans. That study leads us to expect to
find that the exposure of people and property to hurricane
flooding increased substantially in some coastal communities
after they adopted comprehensive plans, despite the state
mandate. Secondly, if the state’s mandate was effective in
the aggregate, we would expect to find that residential
development intensity decreased in CHHAs after local
comprehensive plans were approved. Finally, we would
also expect residential growth rates inside CHHAs, where
plan policies should limit residential development, to be
lower than outside of these zones.
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In the following sections we summarize how we
measured our key concepts. For a more detailed account
of our methods, see Chapin, Deyle, and Baker (2008).
Measuring Residential Land Use Before
and After Plan Adoption
We used county property appraiser tax roll data and
digital property parcel polygons to compare the 2002
residential land use within a community’s hurricane hazard
zones with that in the same area in the year the local com-
prehensive plan was approved by DCA.3 At the time this
study was conducted, 2002 was the most recent year for
which the necessary data were available.
Communities are required to adopt land development
regulations to implement their plan policies within one
year of approval of their comprehensive plans by DCA.
We therefore defined properties as developed pre-plan if
their improvements were built in the year of plan approval
or earlier. Parcels with improvements built after the year
of plan approval we designated post-plan. This approach
accounts for the expected lag in plan implementation after
the adoption and approval of the local plan.
Measuring the Exposure of People and
Property to Hurricane Flooding
We defined three measures of exposure to hurricane
flooding for each jurisdiction: number of residential units,
2002 market value of residential property improvements,
and total population.

We counted all parcels for which land use was coded
as single family residential, mobile home, condominium,
or cooperative as having one residential unit.4 We obtained
data on the number of units in multi-family residential
structures (e.g., duplexes and apartment complexes), motels,
and hotels from the Florida Department of Business and
Professional Regulation, which licenses multi-family resi-
dential properties in the state. We also counted properties
in nonresidential uses if they had homestead exemptions,
which Florida grants only to properties occupied by per-
manent residents. Thus, our total number of residential
units for each municipality was the sum of these three
components.
To estimate the approximate market value of property
improvements, we used the values assessed by county
property appraisers for each parcel, subtracting land value
from total just value, with the latter typically being 85% of
the assessor’s determination of the true market value of a
property. We refer to this remaining value as the just value
of improved property.
We defined total population as the sum of tourist and
nontourist residents, summing both for each jurisdiction.
We used occupancy rate estimates from regional hurricane
evacuation studies to calculate the number of people
associated with tourist units (hotels and motels) during
the peak season. We applied tract-specific 2000 census
occupancy rates to the total of 2002 nontourist residential
units in each census tract, and then multiplied by the
average household size for the tract to estimate the number
of nontourist residents by census tract.
Measuring Land Use Changes Inside and
Outside CHHAs

To differentiate residential land use patterns both over
time (pre- and post-plan approval) and in space (inside and
outside CHHAs), we defined the base year of the pre-plan
time period for each jurisdiction so that the post-plan and
pre-plan time intervals were of equal length. Thus, for ex-
ample, if a community’s comprehensive plan was approved
in 1989, the length of the post-plan period would be 13
years (1989–2002). The base year for the corresponding
pre-plan period would be 1976. We compared development
patterns inside and outside each community’s CHHA
because the state plan mandate explicitly calls for limiting
development within CHHAs. Once we had determined
the above parameters for each jurisdiction, we calculated
growth rates inside and outside the CHHA for each exposure
measure: number of residential units, just value of improved
property, and people.
Sample Selection
A total of 35 counties and 158 municipalities in
Florida are required to include specific policies to mitigate
hurricane hazards in their comprehensive plans. Our sample
includes 15 counties (see Figure 1) and 74 municipalities
within those counties. We excluded jurisdictions for which
2002 tax roll or property parcel polygon data were unavail-
able. We also excluded jurisdictions with unreliable land
use coding, comprehensive plans approved after 1991,
extensive coastal redevelopment, or other circumstances
that made them atypical, and those that had no vacant land
within their CHHAs in 1995. The resulting sample provides
good coverage of the geographic and socioeconomic varia-
tion among the state’s coastal jurisdictions. The counties
we include constitute 36% of the total 2000 population
of the 35 coastal counties in Florida and 41% of the area.
The 1990–2000 average population growth rate for our

sample was 26%, which is nearly identical to the average
of 27% for all 35 coastal counties (U.S. Census Bureau,
2001).
2008, Vol. 74, No. 3
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Plan Conformity Results
To discover whether comprehensive plan policies
influenced residential development inside hurricane hazard
zones, we first look at our sample in the aggregate, and
then examine land use change trends and patterns for the
individual communities in our sample.
Aggregate Changes in Exposure to
Hurricane Flood Risks
As shown in Table 1, despite the state’s hazard miti-
gation mandates, there was substantial residential growth
within the CHHAs and HVZs of the 89 coastal local
governments in our study between when local plans
were approved and 2002. We calculated an approximate
increase of 153,000 new residential units in both types
of hurricane hazard zones combined. If we assume other
Figure 1. Sampled and excluded Florida counties.
Included in sample

Excluded from sample
Noncoastal areas
74-3 06 323128 Deyle P 7/11/08 9:04 AM Page 355
coastal counties in the state grew at the same rate, approx-
imately 425,000 new residential units would have been
built in hurricane hazard zones statewide between the
year of plan approval and 2002.5 Based on our method
of assigning people to residential units, the associated
population increase in both types of hazard zones in the
communities in our sample would be more than 345,000
people. The corresponding increase in just value of resi-
dential improved property would be nearly $30 billion.
Extrapolation to all 35 coastal counties yields estimates of
approximately 958,000 new residents and $80 billion in
just value of new residential structures in hurricane hazard
zones over this time period.
These figures do not suggest significant success in
attaining the state’s broad legislative goal of “protect[ing]
human life in areas that are subject to destruction by
natural disaster” through the implementation of local
comprehensive plan policies (Florida Growth Management
Act, 1985f). Nonetheless, it is possible that the vulnerability
of people and property to hurricane flooding is less than it
might otherwise have been in the absence of the state’s
hurricane hazard mitigation planning mandate.
Changes in Hurricane Flood Exposure
Patterns in Individual Coastal Communities
To further explore this apparent failure in local im-

plementation of the state planning mandate, we narrow
our focus to examine changes in the temporal and spatial
residential development patterns within 58 individual
coastal communities in our sample that have land both
inside and outside their local CHHAs.6 We do so because
of the explicit state mandates to limit development inside
CHHAs and direct populations away from those areas.
We present here two additional analyses: a comparison of
trends in annual development levels, measured as numbers
of new residential units inside and outside of CHHAs
between 1960 and 2002, and a two-dimensional comparison
of median residential growth rates inside and outside of
CHHAs before and after plan approval.
We observed three different patterns in our comparison
of annual development trends. First, we found in some
cases what appeared to be a rising trend inside the CHHA
after plan approval, while the number of new residential
units built outside the CHHA began to decline and dropped
below the level inside the CHHA (see, e.g., Figure 2).
Second, in some cases after plan approval the patterns
inside and outside of the CHHA were roughly parallel
(see, e.g., Figure 3). Third, we found cases where the
trends diverged after plan approval: the numbers of new
residential units inside the CHHA declined while the
numbers outside increased (see, e.g., Figure 4).
These findings provide additional evidence that the
majority of communities did not effectively implement
policies to direct residential development away from
CHHAs. We classified 23% of the communities as ex-
hibiting an increase in new residential units after plan
approval that was distinct from the observed pattern outside
the CHHA. In these cases it appears that communities
have not only failed to direct development away from the

CHHA, but they have allowed it to increase relative to areas
outside the CHHA. In 57% of our sample, communities
exhibit parallel patterns inside and outside the CHHA. In
these cases, there is no evidence of differential growth
management controls inside and outside the CHHA. We
saw evidence in 20% of our sample, however, that com-
munities may have implemented policies that resulted in
a decline in new residential units inside their CHHAs
relative to areas outside the CHHAs.
We turn now to a formal test of whether or not post-
plan residential growth rates within CHHAs were signifi-
cantly different from those that occurred prior to plan
approval in the early 1990s, and whether the pre-plan/
post-plan pattern inside CHHAs differed significantly from
that observed within areas outside the CHHA. We employ
a Mann-Whitney-Wilcoxon test of differences in medians
because none of the variables is normally distributed.7
Table 2 presents the four-way comparison.
All else being equal, we would expect slower residential
growth rates within CHHAs after plan approval than before
if coastal communities were effectively implementing
policies to limit growth within CHHAs. Table 2 shows
this to be the case (a drop from 67% to 14%). The Mann-
Whitney-Wilcoxon test reveals the difference to be statis-
tically significant at better than the 99% confidence level.
Further examination of Table 2 shows, however, a similar,
statistically significant decline in the median growth rate
for numbers of residential units built outside of CHHAs.
2008, Vol. 74, No. 3
Table 1. Aggregate changes in residential hurricane exposure

inside
CHHAs and HVZs between plan approval year and 2002.
Extrapolation
Our sample to entire state
Exposure parameter (n = 89) (n = 193)
Residential units 152,697 425,000
Total population 345,766 958,000
2002 just value of residential
improved property $29 billion $80 billion
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Figure 2. Numbers of residential units built in unincorporated
Gulf County by year and location.
0
50
100
150
200
250
300

1960 1965 1970 1975 1980 1985 1990 1995 2000
Year
N
u
m
b
er
o
f
U
n
it
s
Inside CHHA
Outside CHHA
Year
Figure 3. Numbers of residential units built in the city of
Niceville by year and location.
0
25
50

75
100
125
150
175
200
225
1960 1966 1972 1978 1984 1990 1996 2002
Year
N
u
m
b
er
o
f
U
n
it
s

Inside CHHA
Outside CHHA
Year
Comp plan
adopted
Comp plan
adopted
74-3 06 323128 Deyle P 7/11/08 9:04 AM Page 357
This parallel trend both inside and outside of CHHAs
may be evidence that the post-plan approval decline within
CHHAs was due to broader phenomena such as the overall
impacts of comprehensive plan implementation independent
of policies directed specifically at CHHAs, or limited
supplies of vacant land, reduced rates of population growth,
or slower economic growth. It is very likely that the supply
of vacant residential land declined over this time period. In
addition, the population growth rate in these 15 counties
was substantially greater between 1980 and 1990 (45%
increase) than between 1990 and 2000 (25%; U.S. Census
Bureau, 2001). Thus, the observed declines in numbers of
new residential units after plan approval may not reflect
the direct impacts of plan implementation.
Table 2 also shows that the median growth rates inside
and outside of CHHAs were not significantly different
prior to the approval of local comprehensive plans (67%
versus 77%). However, the median post-plan growth rate
inside CHHAs after plan approval was significantly lower

than that outside CHHAs (14% versus 28%). Thus, it
appears that some factors above and beyond those affecting
the whole jurisdictions may have been at work during the
post-plan-approval period. It is possible, for example, that
there were greater constraints on the vacant land supply
inside the CHHAs than outside, or that other factors may
have contributed to these observed differences.
We therefore designed a variable to control for the
supply of vacant land at the start of each analysis period:
growth density. We defined growth density as the number
of new residential units built within an analysis period
divided by the acres of vacant land suitable for residential
development at the start of the analysis period. We coded
parcels as available for residential development if they were
designated by the county property appraiser as vacant
residential land or unimproved agricultural land with no
primary residence. We also assumed that parcels coded as
residential in the final year of the pre-plan period or in
2002 were vacant residential land prior to the year in which
the current residential structure was built.
Table 3 presents the results of a pre-plan/post-plan
comparison of growth densities inside and outside of
CHHAs. Here we see a significantly different pattern than
in Table 2. Median growth densities inside CHHAs were
significantly higher than those outside CHHAs before plan
approval. This no doubt reflects the greater development
pressure inside CHHAs. However, Table 3 also reveals that
this pattern did not change significantly in the post-plan
environment when communities should have been reducing
development densities inside CHHAs. In fact, the compar-
isons show the median growth density inside CHHAs after
plan approval to be higher than pre-plan, although the
difference just barely fails the significance test at the 90%

2008, Vol. 74, No. 3
Figure 4. Numbers of residential units built in unincorporated
Sarasota County by year and location.
0
500
1000
1500
2000
2500
3000
3500
1960 1965 1970 1975 1980 1985 1990 1995 2000
Year
N
u
m
b
er
o
f

U
n
it
s
Inside CHHA
Outside CHHA
Year
Comp plan
adopted
74-3 06 323128 Deyle P 7/11/08 9:04 AM Page 358
level. The median post-plan growth density is slightly lower
than pre-plan outside CHHAs, but the difference is not
statistically significant.
Thus, with a control for the vacant land supply, the
story told by simple growth rates is contradicted. It appears
that in the aggregate, residential development patterns
inside CHHAs after plan approvals were not consistent with
the state’s mandate to adopt and implement comprehensive
plan policies limiting development in such areas.
Plan Quality: Does Plan Content
Make a Difference?
In this section we contribute to the second line of

plan implementation research by employing bivariate and
multivariate statistical analyses to assess whether or not
better local comprehensive plans are associated with more
limited residential development of the available vacant land
inside CHHAs. The specific hypothesis we test is that
communities whose comprehensive plans have the following
attributes will exhibit lower post-plan residential growth
densities inside their CHHAs than those communities
whose plans do not:
1. more restrictive CHHA definitions,
2. maps of the CHHA, and
3. stronger policies limiting vulnerability of populations
inside CHHAs.
Research Design
We undertook two levels of statistical analysis to test
the influence of our measures of plan quality on post-plan
growth density: (1) correlation analyses using Kendall’s
tau-b, and (2) regression analyses based upon the results
of the bivariate correlation analyses. In addition to our
experimental plan quality variables, we specified a set of
control variables for the multivariate analyses.
We employed the bivariate correlation analyses to test
the basic relationships between our plan quality variables
and post-plan growth density. Given the relatively small
number of cases to which the regressions were applied (76),
it was important that we be parsimonious with respect to
the number of independent variables included in the
models. Thus, we also used the correlations to identify the
most promising, least-correlated control variables. We
utilized the non-parametric Kendall’s tau-b statistic as our
correlation measure because our plan quality variables are

ordinal and because several of our control variables and our
dependent variable exhibit non-normal distributions.8 The
ordinal nature of our plan quality variables and concerns
about normality also led us to transform the dependent
variable from raw growth density values to ranked values.9
Plan Quality Variables. For each of the 76 local
jurisdictions in our sample that included land both inside
and outside a CHHA, we conducted a content analysis of
the coastal element of the comprehensive plan that was
approved by DCA in the late 1980s to early 1990s, as
well as that which was in effect in 2002.10 Each plan was
independently scored by two evaluators who compared
scores for each variable and resolved any differences
through negotiation.
The content analysis focused on the following three
components of the local comprehensive plans: the CHHA
definition; mapped representation of the CHHA; and the
state’s mandated growth management policies to limit public
expenditures within the CHHA, direct populations away
from the CHHA, and maintain evacuation times within the
HVZ. We scored the CHHA definition and each of the
growth management policies on a scale of 0 to 3 as follows:
0 = no definition/policy in evidence;
1 = definition/policy that mirrored the state mandate;
2 = definition/policy that was somewhat more restrictive
than the state mandate; and
Table 2. Median rates of growth in residential units before and
after
comprehensive plan approval inside and outside of CHHAs (n =

58).
Mann-
Before After Whitney-
plan plan Wilcoxon
Location approval approval p
Inside CHHA 67% 14% <0.0002
Outside CHHA 77% 28% <0.0002
Mann-Whitney-Wilcoxon p 0.1867 0.0003
Table 3. Median residential growth densities before and after
comprehensive plan approval inside and outside of CHHAs (n =
58).
Mann-
Before After Whitney-
plan plan Wilcoxon
Location approval approval p
Inside CHHA 2.06 2.20 0.1075
Outside CHHA 1.35 1.23 0.2514
Mann-Whitney-Wilcoxon p <0.0002 <0.0002
74-3 06 323128 Deyle P 7/11/08 9:04 AM Page 359
3 = definition/policy that was far more restrictive than
the state mandate.
For the CHHA map variable, we assigned a score of 0
if the CHHA was not represented on any map in the plan
and a score of 1 if it did appear there on a map. We defined

a separate dichotomous variable indicating whether the
CHHA was depicted on the future land use map (FLUM).
In contrast to most states, under Florida’s growth manage-
ment law, the FLUM, and accompanying policies in the
future land use element of a community’s comprehensive
plan legally bound the development rights of property
owners.11
Unlike some studies that have investigated the role of
plan quality on outcomes resulting from plan implemen-
tation over a multi-year study period (Brody & Highfield,
2005; Brody et al., 2006; Nelson & French, 2002), our
study investigated the effects of initial, as well as current,
plan quality, knowing that plan content can change signifi-
cantly over time. We also tested the influence of individual
plan components rather than an overall index of plan
quality, as other plan implementation studies have done.
This allowed us to determine whether specific policies,
definitions, and mapping approaches were effective at
limiting development within the CHHA. Table 4 presents
an overview of these plan quality variables.
Figures 5 and 6 compare the distributions of local plan
quality scores for the initial plans approved by DCA and
the plans in 2002. Consistent with the findings of Deyle
and Smith (1998), these figures demonstrate that initial
plan quality was decidedly mixed. However, by 2002,
quality had improved for each of the plan content variables,
and the number of local governments not meeting the state
hazard mitigation requirements had fallen substantially. In
2002, some 10–12 years after initial plan approval, more
than 80% surpassed or met the state minimums for the
definition requirement and each of the policy mandates.
Control Variables. While the plan quality variables are
of primary interest, we also developed a number of variables

to control for alternative explanations of observed differences
in post-plan growth density (see Table 5). We included two
variables to control for the amount of vacant residential
land within the CHHA where development might be
constrained by state and federal regulatory policies: the
percentage of vacant land inside the CHHA in wetlands
and the percentage of vacant land inside the CHHA in
federal Coastal Barrier Resource System (CBRS) units.
We also included two additional variables to control for
local planning and fiscal conditions: average annual per
capita planning expenditures, which could reflect the ability
of local planning efforts to meet state mandates; and the
average percentage of annual local government own-source
revenues derived from ad valorem taxes, which could
influence the incentive to permit development at higher
densities and in areas less suitable for development.
A third set of variables controls for hurricane experience
and hurricane response issues. We controlled for recent
hurricane histories, both before and after plan adoption,
on the assumption that communities with more recent
experience with more damaging hurricanes would be more
likely to limit residential development within their CHHAs.
We also included measures of unmet shelter demand and
worst-case evacuation clearance times at the time of com-
prehensive plan adoption, theorizing that jurisdictions with
greater unmet shelter demand or longer clearance times
would be more likely to limit development within hurricane
hazard zones.
Our final set of control variables attempts to control
for market conditions at the time the original comprehen-
sive plan was approved by the state. We used two measures
of population growth between 1980 and 1990 as proxies
for real estate demand on the assumption that higher demand

would stimulate more development pressure inside CHHAs:
net county population change and county population
growth rate. We also included the pre-plan residential
2008, Vol. 74, No. 3
Table 4. Plan quality variables determined both for the initial
plan
approved by DCA and for the plan in use in 2002.
Name Description
CHHA definition quality CHHA definition present in the
comprehensive plan
CHHA map in comp plan Map depicting the CHHA present in
the
comprehensive plan
CHHA mapped on FLUM CHHA depicted on the future land use
map in the comprehensive plan
Limit public expenditures Quality of policies in the
comprehensive
in CHHA plan that limit public expenditures
subsidizing development inside the
CHHA
Direct populations away Quality of policies in the
comprehensive
from CHHA plan that direct population
concentrations away from the CHHA
and/or limit development inside the

CHHA
Maintain evacuation times Quality of policies in the
comprehensive
plan that maintain or reduce hurricane
evacuation times inside the HVZ
74-3 06 323128 Deyle P 7/11/08 9:04 AM Page 360
growth density inside the CHHA as a measure of pre-plan
development conditions.12
Plan Quality Results
Our correlation analyses revealed that none of the
2002 plan quality variables was significantly associated
with post-plan residential growth density inside CHHAs.
However, as shown in Table 6, three of the original plan
quality variables were associated with lower post-plan
growth densities: existence of a CHHA map in the com-
prehensive plan, mapping the CHHA on the future land
use map (FLUM), and the strength of policies directing
populations away from the CHHA. Only three of our
control variables were significantly correlated with post-plan
residential growth density, and, therefore, were included in
the regression models: percentage of vacant land in the
CHHA covered by wetlands (Kendall’s tau-b = −0.25,
p = 0.00), percentage of county shelter demand remaining
unmet at time of plan adoption (Kendall’s tau-b = −0.15,
p = 0.10), and pre-plan residential growth density inside
the CHHA (Kendall’s tau-b = 0.29, p = 0.00).
Not surprisingly, the existence of a CHHA map in the

comprehensive plan was highly correlated with the measure
of the depiction of the CHHA on the FLUM. We used
the latter variable in the regression models because of its
stronger correlation with the dependent variable. As
shown in Table 7, single-variable models with this variable
(Model 1) and the variable measuring the strength of
policies directing populations away from the CHHA
(Model 2) regressed on post-plan residential growth den-
sity rank yielded results comparable to the Kendall’s tau-b
correlations. Those local communities that depicted the
CHHA on their FLUMs and those with stronger policies
for directing populations away from the CHHA had the
Figure 5. Distributions of local plan definition and policy
quality variables as initially approved and in 2002.
0%
10%
20%
30%
40%
50%
60%
70%
80%

90%
100%
Pe
rc
en
t
of
c
om
m
u
n
it
ie
s
Initial
approved
plan
CHHA definition
quality
Definition and policy quality variables
P

er
ce
n
t
o
f
co
m
m
u
n
it
ie
s
Limit public
expenditures in CHHA
Direct populations
away from CHHA
Maintain
evacuation times
2002
plan
Initial
approved

plan
2002
plan
Initial
approved
plan
2002
plan
Initial
approved
plan
2002
plan
0%
10%
20%
30%
40%
50%
60%
70%

80%
90%
100%
Exceeds the mandate Meets the mandate Absent
74-3 06 323128 Deyle P 7/11/08 9:04 AM Page 361
desired planning outcome: lower post-plan growth densities
inside their CHHAs.13
When pre-plan growth density inside the CHHA is
controlled for, the explanatory power of the models in-
creases substantially. The adjusted R 2 values increase from
0.05 and 0.03 to 0.22 and 0.15 (see Models 3 and 4). The
CHHA map variable remains significant (Model 3) with
the addition of the pre-plan growth density control, but
the policy quality variable is no longer significant (Model
4). The other two control variables are also significant
when added to Models 1 and 2 (not shown), but their
effects are subsumed by the pre-plan growth density rank
variable in the fully specified model (Model 5).
Discussion
Our findings present a somewhat mixed picture of the
impact Florida’s hazard mitigation planning mandate has
had on residential development in areas prone to hurricane
flood damage. Our post-plan residential development
indicators (Table 1) reveal that residential units, associated

population, and the market value of new residential struc-
tures increased very substantially within these hazard zones.
When we look more closely, we find trends in post-plan
residential development in a majority of communities that
suggest a lack of constraint on growth inside CHHAs.
We find that the post-plan median growth rate inside
CHHAs was significantly less than both the pre-plan
median growth rate inside CHHAs and the post-plan
median growth rate outside CHHAs (Table 2). However,
when we control for the supply of vacant land suitable for
residential development at the outset of each analysis
period (Table 3), we find additional evidence that coastal
communities have failed, in the aggregate, to limit resi-
dential development inside their CHHAs after the state
approved their comprehensive plans in the late 1980s and
early 1990s.
2008, Vol. 74, No. 3
Figure 6. Distributions of local plan CHHA map quality
variables as initially approved and in 2002.
0%
10%
20%
30%
40%
50%

60%
70%
80%
90%
100%
Pe
rc
en
t
of
c
om
m
u
n
it
ie
s
Map quality variables
P
er
ce

n
t
o
f
co
m
m
u
n
it
ie
s
CHHA mapped on FLUM
Initial
approved plan
2002 plan
CHHA map in comprehensive plan
Initial
approved plan
2002 plan
0%
10%

20%
30%
40%
50%
60%
70%
80%
90%
100%
Present Absent
74-3 06 323128 Deyle P 7/11/08 9:05 AM Page 362
Our statistical analyses of the influence of plan quality
on residential development (Tables 6 and 7) provide
evidence that showing CHHA boundaries on the FLUM
in a community’s comprehensive plan is associated with
lower post-plan residential growth densities inside CHHAs,
independent of previous growth patterns, plan policy
quality, or state or federal regulatory constraints on the
supply of vacant residential land. However, the plan quality
coefficient is no longer significant when the pre-plan
growth density control variable is added to the model.
One possible interpretation is that communities that were

already limiting development within areas susceptible to
hurricane flooding prior to the enactment of the state’s
1985 growth management legislation were more likely to
adopt stronger policies for limiting development inside
CHHAs in their post-1985 comprehensive plans.
These findings invite questions about why the state’s
mandate and its implementation by local governments
should have had such marginal effects. Here we suggest
some possible explanations based on the circumstances
faced by many coastal communities, supplemented by
insights gleaned from structured telephone interviews with
state officials and with local planning officials in a sample
of 12 case study communities chosen for variety in com-
posite plan quality scores14 and post-plan growth densities.
These interviews focused on determining the underlying
reasons for the level of post-plan residential development
in each community.
Table 5. Overview of control variables.
Name Description Source
Percentage of CHHA vacant land in wetlands Percentage of
vacant land inside the CHHA covered by wetlands Calculated
by authors
Percentage of CHHA vacant land in CBRS units Percentage of
vacant land inside the CHHA covered by Coastal Calculated by
authors
Barrier Resource System units
Per capita planning expenditures Average annual per capita
planning expenditures Florida Department of

Financial Services
Percentage of revenue from property taxes Average annual
percentage of community’s own-source revenues Florida
Department of
derived from ad valorem taxes Financial Services
Pre-plan hurricane history Average intensity of all hurricanes to
pass within 65 nautical Calculated by authors
miles during the pre-plan period weighted by relative damage
and
number of years prior to plan adoption of most recent hurricane
Post-plan hurricane history Average intensity of all hurricanes
to pass within 65 nautical miles Calculated by authors
subsequent to plan adoption weighted by relative damage and
average of number of years between plan approval and all
hurricanes
Percentage of shelter demand unmet at plan Percentage of
county shelter demand remaining unmet at time of Regional
Hurricane
adoption plan adoption Evacuation Studies
Evacuation time at plan adoption Estimate of worst-case
evacuation clearance time at time of comp Regional Hurricane
plan adoption Evacuation Studies
1980–1990 county population increase Net county population
increase between 1980 and 1990 U.S. Census Bureau
1980–1990 county population growth rate Rate of increase in
county population between 1980 and 1990 U.S. Census Bureau
CHHA pre-plan growth density Pre-plan residential growth
density inside the CHHA Calculated by authors

Table 6. Kendall’s tau-b correlations of post-plan growth
densities with
original plan quality variables (n = 76).
Plan quality variables Coefficient Significance
CHHA definition quality −0.04 0.64
CHHA map in comp plan −0.17 0.08c
CHHA mapped on FLUM −0.20 0.03*
Limit public expenditures in CHHA −0.06 0.47
Direct populations away from CHHA −0.16 0.07c
Maintain evacuation times −0.10 0.23c
cp < 0.10 *p < 0.05
74-3 06 323128 Deyle P 7/11/08 9:05 AM Page 363
Possible Constraints on Limiting
Development Inside CHHAs
A literal interpretation of the state’s mandate to include
policies to “limit development in” and “direct populations
away from” CHHAs could imply stopping development
altogether in such areas or, at the very least, reducing the
densities allowed in such areas in the future land use element
of the plan and the corresponding zoning districts. Almost
one quarter (16) of the 77 communities in our sample that
have land inside a CHHA have no land outside a CHHA.
For these communities to comply with the state’s require-
ment to limit development inside CHHAs and direct
populations away from these areas would require them

to impose moratoria on their own growth.
Marlene Conaway (personal communication, October
2006), former chief of comprehensive planning in the
Division of Community Planning of DCA, told us that the
agency position was to prevent increases in allowable
densities inside CHHAs when reviewing proposed plan
amendments. The state was aware that absolute prohibitions
on residential development could raise questions of takings
in state and federal courts or trigger the state’s property
rights statute, and recognized that it was clearly infeasible
for local governments to buy out all undeveloped properties
inside CHHAs. This pragmatic approach to reviewing
amendments is consistent with the relatively low priority
DCA accorded requiring initial plan policies to conform
to hurricane hazard mitigation mandates (Deyle & Smith,
1998). However, former and current directors of the Di-
vision of Community Planning, Valerie Hubbard (personal
communication, February 2006) and Charles Gauthier
(personal communication, December 27, 2007), maintain
that this approach has prevented substantial increases in
residential densities inside CHHAs.
Hubbard noted that many coastal communities whose
maximum allowable zoning densities were higher than the
as-built densities when their comprehensive plans were
approved under the 1985 act experienced pressure to
permit higher density residential development inside their
CHHAs. In coastal communities with substantial quantities
of vacant land at the time their new comprehensive plans
were approved, property owners lobbied for increasing the
allowable densities. In spite of the state mandate to direct
development away from CHHAs, many local governments
were hesitant to down-zone property because of the Bert

2008, Vol. 74, No. 3
Table 7. Regression results for post-plan residential growth
density rank (n = 76).
Variables Model 1 Model 2 Model 3 Model 4 Model 5
Percentage of CHHA vacant land in wetlands −0.00
Std. error 0.00
Sig. (2-tail) 0.12
Percentage of shelter demand unmet at plan adoption −11.42
Std. error 8.28
Sig. (2-tail) 0.17
CHHA mapped on FLUM −24.01* −25.32* −25.89*
Std. error 11.74 9.97 10.19
Sig. (2-tail) 0.03 0.13 0.01
Direct populations away from CHHA −3.87c −1.64 −0.22
Std. error 2.15 2.14 2.10
Sig. (2-tail) 0.07 0.45 0.92
CHHA pre-plan growth density rank 0.43 ** 0.40 ** 0.35**
Std. error 0.11 0.12 0.12
Sig. (2-tail) 0.00 0.00 0.00
Adj. R 2 0.05 0.03 0.22 0.15 0.23
F 0.03 0.08 0.00 0.00 0.00
cp < 0.10 *p < 0.05 **p < 0.01
74-3 06 323128 Deyle P 7/11/08 9:05 AM Page 364

Harris Act (1995), the state’s property rights law (Weaver,
2000). The Bert Harris Act requires local governments to
negotiate with and, if necessary, compensate landowners
where regulations noticed for adoption or adopted after
May 11, 1995, “inordinately burden” private property.
As of 2004, two years past the end of our study period,
numerous claims under the act had been settled out of
court under a required pre-suit procedure, but few cases
had been litigated in the state’s circuit courts of appeal
(University of Florida College of Law Conservation Clinic,
2004). Thus, there remained considerable uncertainty about
the true legal constraints and potential costs the act imposed
on local governments (Weaver, 2000). Three local planning
officials we interviewed mentioned this as influencing their
communities’ decisions about residential development
densities inside the CHHA.
Even where communities attempted to follow both the
letter and the spirit of the mandate to mitigate hurricane
hazards by reducing allowable densities inside CHHAs on
their FLUMs, the state’s vesting policy may have limited
their abilities. Under the vesting provisions of the state
growth management statute (Florida Growth Management
Act, 1985g) once a development “agreement” is issued by
a local government, that development is governed by the
local laws and policies in force at the time the agreement
is issued. Subsequently adopted laws and policies can only
be applied to a vested development where “[t]hey are not
in conflict with the laws and policies governing the de-
velopment agreement and do not prevent development
of the land uses, intensities, or densities in the develop-
ment agreement,” unless the local government makes an
affirmative finding after a public hearing that one of several
circumstances applies.

The ramifications of this vesting provision are influ-
enced by the structure of the development industry in the
state. In many parts of Florida, residential development is
undertaken by large real estate firms that build large-scale
projects in bursts of activity that respond to market con-
ditions. As a result, where a developer holds vested land
entitlements on a property, a community can add hundreds
or thousands of new residential units within a very short
period of time, generating spikes in local development
activity that are linked to land use approvals made many
years previously.
The state does not maintain a central database of
vested developments, nor do most communities have
readily available records of such information. Our interviews
revealed, however, that vesting was a significant factor in
dictating post-plan densities inside the CHHAs of 7 of the
12 case study communities. In an effort to assess the rep-
resentativeness of the survey findings, we examined the
residential development trend graphs to look for evidence
that vesting may have played a role in determining the
residential development patterns that occurred after plan
approval. Spikes in the numbers of new residential units
that deviate substantially from the general development
trend after plan adoption may indicate construction in
such vested developments. Figure 7 illustrates such a
pattern. Following this approach, we found evidence of
possible vesting impacts within the CHHAs of 16 (26%)
of the 61 communities in our sample that have land both
inside and outside of a CHHA.15 This proportion, which
is only half what our interviews suggested, is likely a lower
bound for vesting, because in some cases vested develop-
ments are built out more slowly, producing a less obvious
spike in the development trend graph.

What the Planners Tell Us
The case study interviews, as well as correspondence
and interviews with DCA Community Planning Division
staff (W. Banning, personal communication, October 2,
2006; M. Conaway, personal communication, October
2006; V. Hubbard, personal communication, February
2006), revealed that most communities had zoning ordi-
nances in effect before local adoption and state approval of
comprehensive plans pursuant to the 1985 mandate. With
few exceptions, the planners we interviewed reported that
the densities allowed in those land development regulations
were incorporated in the future land use and coastal elements
of their post-1985 comprehensive plans. In three cases, Palm
Beach Shores, Brevard County, and Hernando County,
allowable densities were low to begin with. In several other
communities, including Cape Canaveral, Panama City
Beach, Venice, and Vero Beach, allowable densities were
fairly high at the outset and have remained so.
However, several of the case study communities
employed growth management strategies that contributed
to lower post-plan growth densities inside their CHHAs.
For example, Hernando County engaged in significant
efforts to acquire land for conservation purposes, much of
which was inside the CHHA, while Pasco County bought
land inside the CHHA with the explicit intention of
limiting development there. Brevard County down-zoned
property within a significant portion of its CHHA because
of evacuation clearance time concerns unrelated to specific
state planning mandates. DCA staff report that several other
communities not included in our sample intentionally
reduced allowable densities inside their CHHAs at the time
they fashioned their original post-1985 plans (C. Gauthier,
personal communication, December 27, 2007).

In contrast, other local governments started with
relatively weak coastal elements. The St. Johns County
74-3 06 323128 Deyle P 7/11/08 9:05 AM Page 365
1990 plan lacked a policy explicitly directing population
concentrations away from the CHHA, and pre-plan allow-
able densities inside the CHHA were as high as 15 units
per acre. A plan amendment adopted in 2000 reduced
those densities to as little as 8 units per acre; however, the
county has only recently begun to revise its zoning ordinance
to reflect the lower densities in their amended future land
use element. The City of Melbourne has very high plan
quality scores and, while the 1988 comprehensive plan
reportedly reduced the maximum allowable densities to
some degree, they remain high at 10 units per acre.
The story is somewhat more complicated in other
places. Growth densities inside Okaloosa County’s CHHA
increased substantially between the pre-plan period (1.72
units per acre) and the post-plan period (4.22 units per
acre). Much of the county’s CHHA lies along the eastern
end of Santa Rosa Island, an area referred to locally as
Okaloosa Island, where the land was deeded to the county
by the federal government in the 1940s with the stipulation
that it be used for public purposes. As a result, until re-
cently, all private development in the Okaloosa Island area
has been done under long-term leases governed by a set of
covenants. These covenants pre-date the county’s 1990
comprehensive plan and were reflected in the maximum

allowable densities contained in the plan. The remaining
portion of the county’s CHHA lies east of the City of
Destin. In this area, maximum allowable densities range
from 4 to 25 units per acre. These are largely consistent
with zoning that was in place at the time the plan was
adopted, although the county did down-zone some areas
in 2000.
Rural, conservative Gulf County’s plan quality is
largely the result of a stipulation agreement imposed by
DCA in 1992 that mandated stronger plan policies. How-
ever, the county’s very low growth densities appear to be a
function of relatively little development pressure prior to
2002 and the fact that roughly 90% of the county’s vacant
residential land inside the CHHA lies within wetlands.
Conclusions
Taken as a whole, our findings suggest that local
implementation of Florida’s planning mandate to limit
development within hurricane hazard areas has had limited
impact on coastal residential development densities. We
find that in the aggregate, residential development inside
CHHAs has continued at roughly the same intensity as
2008, Vol. 74, No. 3
Figure 7. Numbers of residential units built in City of Destin by
year and location.
0
100
200

300
400
500
600
700
800
1979 1981 1983 1985 1987 1989 1991 1993 1995 1997 1999
2001
Year
N
u
m
b
er
o
f
U
n
it
s
Inside CHHA

Outside CHHA
Year
Comp plan
adopted
74-3 06 323128 Deyle P 7/11/08 9:05 AM Page 366
before the approval of plans adopted under the state’s 1985
growth management legislation. Our findings also indicate
that plan quality has had only marginal impacts on devel-
opment, with little evidence that higher quality compre-
hensive plan policies generated more desirable planning
outcomes. The one exception, however, is our finding that
showing the critical area boundary, the CHHA, on the
future land use map, is associated with lower residential
development densities inside the CHHA after plan approval.
Our statistical models and our case studies suggest that
in general, higher quality comprehensive plan policies
reflected existing practice at the time plans were adopted
pursuant to the 1985 state mandate rather than signaling
change. Local comprehensive plans generally served to
reinforce development patterns that existed at the time of
plan preparation rather than altering them. Interviews
with state officials suggest that the state continued to give
relatively low priority to enforcing the state mandate, as
documented by Deyle and Smith (1998), only holding
the line at the status quo when reviewing subsequent
comprehensive plan amendments. DCA officials maintain,
however, that the agency has staved off substantial increases
in CHHA density that have been sought through plan

amendments. Our analysis of plan quality shows that the
content of coastal elements improved over time, but that
the higher quality plans in effect in 2002 do not explain
the post-plan residential development patterns observed
up to that year.
The bald evidence of substantial increases in the num-
bers of people and the amount of property at risk within
Florida’s hurricane hazard zones suggests a general failure of
local and state implementation. However, a more nuanced
view seems appropriate when these findings are placed in the
context of state vesting policies, the fact that allowable densi-
ties had been established in many communities prior to the
adoption of the post-1985 comprehensive plans, and the
political and legal hurdles to altering these entitlements.
For practitioners, our findings suggest that state
mandates designed to alter development practices in critical
areas through adopting and implementing local compre-
hensive plan policies that depart from existing practice may
have marginal effects because of the legal and political
inertia of previously adopted plans, policies, and regulations.
While the planning process established by the 1985 Florida
Growth Management Act called for the development of
local comprehensive plans that would shape land develop-
ment regulations, in practice the reverse often occurred.
In almost all of our case study communities, the allowable
densities in the future land use element of the compre-
hensive plan simply reflected the densities of the zoning
ordinance at the time the plan was created. Most coastal
communities made very few changes to their allowable
development densities, even given the state mandate to
adopt policies limiting development inside CHHAs.
The news is not all bad for proponents of compre-

hensive planning, however. Our case studies and interviews
with state officials revealed that some communities sur-
mounted these obstacles to reduce development intensity
inside their CHHAs through down-zoning and land
acquisition. The state’s plan amendment review process
also may have contributed to the progressive improvement
of plan quality. While many of the initial comprehensive
plans had key shortcomings in their hurricane hazard
definitions and mitigation policies, we found substantial
improvements in these provisions by 2002. Given time for
their implementation, these changes are likely to be mani-
fest in better conformity with the state’s goals of reducing
vulnerability to hurricane flooding. We also found that
communities whose comprehensive plans depict the CHHA
on the future land use map were more likely to have limited
residential development within that critical area. This
finding underscores the importance of maps as instruments
for displaying and implementing plan policies, particularly
those showing critical areas. Clearly, more research is
required to investigate and document the utility of maps
as a tool for implementing plan policies, but these findings
suggest that visual representations of policies were more
effective at yielding desirable development outcomes than
relying solely on descriptive policies.
For planning scholars, our findings draw attention to
the importance of controlling for pre-existing conditions
when testing the impacts of planning interventions on plan
outcomes. We show that for some plan quality variables,
apparent correlations between plan content and post-plan
land use trends did not persist after controlling for pre-plan
land use trends. We also show that convenient assumptions
about plan content stability may be flawed. We found
substantial changes in plan quality between initial plan
approvals in the late 1980s and early 1990s and the year
2002. We also found that policies in the initial plans pro-

vided better explanations of post-plan approval development
patterns than did policies in place at the end of the post-
plan approval study period. Unraveling changes in plan
content is tedious, but in Florida it can be done relatively
easily because of the requirement for state review of major
comprehensive plan amendments. An interesting question
that invites further research is the extent to which the
Florida DCA has effectively prevented increases in the
vulnerability of coastal populations and property to hurri-
cane flooding by challenging proposed comprehensive plan
amendments that would be inconsistent with the required
policies to direct development away from CHHAs.
74-3 06 323128 Deyle P 7/11/08 9:05 AM Page 367
Whereas Burby and Dalton (1994) concluded that
“Plans can matter!” our work, along with that of Berke et
al. (2006), suggests some modification to this conclusion,
namely that well-designed plans can matter. However, this
study also highlights the challenges of inducing changes in
longstanding local development management practices,
especially where pre-existing policies and regulations are
perceived as having conferred development entitlements
on property owners.
Acknowledgments
This research was conducted under the auspices of the Florida
Sea
Grant College Program with support from the National Oceanic
and
Atmospheric Administration, Office of Sea Grant, U.S.
Department of

Commerce, Grant No. R/C-P-26. Additional funding was
provided by
the Florida Department of Community Affairs and the DeVoe
Moore
Center at Florida State University. We are deeply indebted to
four
cohorts of graduate research assistants whose enthusiasm and
diligence
made this work possible: Michelle Freeman, Daniel Harris, Alex
Joyce-
Peickert, Ramona Madhosingh, Nicholas Martinez, Brandie
Miklus,
John Richardson, Audrey Smith, Preeti Solanki, Lara Mae
Webster, and
Chris Whittaker. We also wish to acknowledge the helpful
suggestions
of six anonymous reviewers.
Notes
1. The Department of Community Affairs is the state agency
that was
tasked with reviewing and certifying that all local
comprehensive plans
meet the state’s minimum standards. This process began in
1988,
although most local comprehensive plans were certified in 1990
and
1991.
2. Hurricane intensity is typically measured using the five-level
Saffir-
Simpson scale based on wind speed and storm surge height.
Category 1
hurricanes are characterized by wind speeds between 74 and 95
miles
per hour and storm surge heights of 4 to 5 feet above mean sea
level.

A category 5 hurricane has wind speeds in excess of 155 mph
and storm
surge heights in excess of 18 feet.
3. Land use codes reported by county property appraisers in
Florida for
vacant parcels reflect the appraiser’s judgment of highest and
best use.
Thus, they are influenced by the zoning of the parcel as well as
uses of
adjacent parcels.
4. In most Florida counties property appraiser parcel maps
include
separate “parcel” polygons for each condominium or
cooperative unit
to provide a geographic reference for their unique ownership.
5. This estimate is based on the proportion of total 2000
population in
the 35 coastal counties that is accounted for by the 15 counties
in our
sample (36%). This extrapolation implicitly assumes that our
sample is
also proportionately representative of the spatial extent of
CHHAs and
HVZs throughout the state.
6. A total of 61 jurisdictions from our sample of 89 coastal
communities
have land both inside and outside a CHHA. We could not
construct
complete pre-plan data for 3 of those communities, thus the
sample
analyzed here is 58. An additional 16 communities are
completely
contained within their CHHAs, that is, they have no land
outside their
CHHAs. The remaining 12 communities have no land inside a
CHHA,

but have some land inside an HVZ that would be flooded by a
category
3 hurricane.
7. The Mann-Whitney-Wilcoxon test (or simply the Mann-
Whitney
test or Wilcoxon test) is used with ordinal data, or data that are
not
normally distributed, to determine whether or not two
independent
samples can be assumed to come from the same population
(Conover,
1980; Garson, 2008). Ranks are assigned to each observation
from the
combined samples. The statistic tests whether the ranks of the
individual
observations are randomly distributed between the two samples.
Shapiro-Wilk tests for each of the variables are significant at
the 99.9%
level, indicating that their values are not normally distributed.
8. Shapiro-Wilk test results were significant at the 99.9% level.
9. This transformation captures rank-order statistical
relationships
comparable to those employed by the Kendall’s tau-b test.
Although
the rank transformation sacrifices information about the
variable, loss
of statistical power in regression is not usually a consequence,
and the
transformation generally ensures a normal distribution of error
terms
(Hettmansperger, 1978; Iman & Conover, 1979).
10. Copies of original comprehensive plans were obtained from
the
archives of the Florida Department of Community Affairs. We
ascer-

tained what the plan content had been in 2002 by comparing
current
comprehensive plan content with the original plans and, where
the
current plans contained different language, using the DCA
library of
comprehensive plan amendments to determine when relevant
plan
content was amended.
11. A Florida community’s FLUM details the jurisdiction’s
desired land
use mix and land use intensities over the planning horizon of
the com-
prehensive plan. All local land development regulations,
including zoning,
as well as individual development orders, must be consistent
with the
land uses, densities, and intensities set forth in the
comprehensive plan
(Florida Growth Management Act, 1985c). While the
comprehensive
plan does not establish entitlements in the manner of the zoning
ordinance (Board of County Commissioners of Brevard County
v. Snyder,
1993), the future land use element and FLUM define the
parameters
that must govern the zoning ordinance and other land
development
regulations.
12. We recognize that these models are not fully specified, as
evidenced
by the low adjusted R2 values reported in Table 7. Although we
have
included constraints upon developable land (acreage in wetlands
and
CBRS units) and accounted for the amount of developable land

in our
dependent variable, ideally we would also control for variations
in
development costs (e.g., land costs and construction costs).
However,
these data were not readily available for the counties included
in the
analysis. We also acknowledge that our development demand
proxies
would not capture shifts in the location of development demand
that
may have occurred in the early 1990s.
13. All else equal, a community with the CHHA shown on their
FLUM
would exhibit a growth density rank 24 positions lower than one
without
it, while a difference of one point on the quality of the local
policy
directing populations away from the CHHA would lower a
community’s
rank by roughly four positions.
14. Composite plan quality score was computed by averaging
the plan
scores for the original comprehensive plan and the 2000
comprehensive
plan for each jurisdiction. These scores were derived from an
aggregate
of the assigned values for four plan items: CHHA definition,
CHHA
map, a policy for limiting public expenditures in the CHHA, and
a
policy for directing populations away from the CHHA.
15. We were able to assess development patterns after plan
approval for
evidence of vesting in the full set of 61 sampled jurisdictions
with land

inside and outside of a CHHA.
2008, Vol. 74, No. 3
74-3 06 323128 Deyle P 7/11/08 9:05 AM Page 368
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