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Local Government Compliance with State Planning Mandates: The Effects of State Implementation in Florida

Robert E. Deyle & Richard A. Smith

To cite this article: Robert E. Deyle & Richard A. Smith (1998) Local Government Compliance with State Planning Mandates: The Effects of State Implementation in Florida, Journal of the American Planning Association, 64:4, 457-469, DOI: 10.1080/01944369808976004

To link to this article: https://doi.org/10.1080/01944369808976004

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Deyle, Robert E., & Smith, Richard A. (1998). Local government compliance with state planning mandates: The effects of state implementation in Florida. Journal of the American Planning Association, 64(4), 457-469. https://search-proquest-com.ezproxy.liberty.edu/docview/229720324?pq- origsite=summon

State planning mandates have been used to achieve state policy objectives through the local planning process. Recent research has shown that plan quality is higher both in states with mandates for local planning and in those where state authority to review local plans and enforce mandates is greater. Florida is generally considered to be among the strongest ofthe man- date states. We examine the extent to which eighteen Florida communities comply with state mandates about coastal storm hazards. Compliance with the mandate requirements is highly variable-greater with some mandates than with others; and within mandate categories, local plans vary substantially in compliance. In examin- ing why this variability occurs, we test two sets o f factors: the interpretation and enforcement o f the mandates by the state agency charged with their ad- ministration, and local community conditions. We find evidence that much o f the variation in compliance is attributable to how the planning man- date was implemented by the State Department o f Community Affairs. We show that the state agency has em- phasized some mandate requirements over others, and not necessarily con- sistently over time or across different sub-units o f the agency. We also find weak evidence that some local condi- tions may have influenced plan con- tent in cases where the state agency did not strictly enforce the mandate. We conclude that the extent to which storm hazard planning is included in local plans cannot be attributed solely to the content o f the state’s planning mandate. Our findings have implica- tions for how the effectiveness o f state planning mandates should be mea- sured and interpreted.

Deyle is an associate professor in the Department o f Urban and Regional Planning, Florida State University. His research interests are organizational decision-making in environmental planning and natural resources man- agement. Smith i s a professor in the Department o f Urban and Regional Planning, Florida State University. His research interests are urban growth processes and their effects, including the relationships between growth and coastal storm hazards.

Journal ofthe American Planning Association, Vol. 64, No. 4, Autumn 1998. OArnerican Planning Association, Chicago, IL.

Local Government Compliance with Stat; Planning Mandates The Effects o f s t a t e

~ I i n p k m e n t a h o n in Florida I

L

I Robert E. Deyle and Richard A. Smith

lorida is one of several states that have used planning mandates to prod local governments to address policy issues of importance to the F state (DeGrove 1992). Typically, such mandates direct local govern-

ments to prepare various plans for housing, transportation, and land, to guide local decision-making and development. Local implementation of such programs is neither easy nor automatic, however (May and Williams 1986). Most state planning mandates obligate the community only to address a particular set of issues, without specifying in detail how they are to be resolved. This flexibility “entails an act of faith on the part of the superior governmental unit that its policy goals will be achieved” (Burby and Dalton 1994, 235). The obvious question, then, is whether planning mandates are effective devices for producing plans and policies at the local level that accomplish the goals of higher-level governments. The question is especially critical where the policy issues of concern to the state have very low salience to local governments.

Planning for natural hazards is an issue domain for which the prior- ities of local and higher-level governments notoriously diverge (Rossi, Wright, and Weber-Burdin 1982; May and Williams 1986; Cigler, Stiftel, and Burby 1987; Godschalk, Brower, and Beatley 1989; Berke and Beatley 1993). Several studies, which were based on a comparative survey directed by planning scholar Raymond Burby of the natural hazards elements of local plans in five states, provide evidence that planning mandates can influence the content of local plans and that stronger mandates, backed by statutory authority to review local plans and sanction communities for noncompliance, are associated with higher quality plans (see espe-

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ROBERT E. DEYLE AND RICHARD A. SMITH

cially Berke and French 1994; Burby and Dalton 1994; Dalton and Burby 1994; Berke et al. 1996).

Findings from that comparative state survey, plus other research that contrasts planning outcomes in ju- risdictions governed by coercive state-local planning processes with those from collaborative processes, have led researchers to conclude that strong oversight and sanctions are required to motivate lower-level gov- ernments to pursue desired state policies when the two levels of government disagree o n policy goals and objectives (May and Burby 1996; May et al. 1996). Flor- ida’s state planning mandate is frequently charac- terized as one of the most coercive because of the substantial review powers granted to the agency that administers the mandate, and the ability of the state to impose heavy fiscal sanctions against non- complying communities (Bollens 1992; Innes 1992; Berke and French 1994; Burby and Dalton 1994; May et al. 1996).

The conclusions of these comparative studies in- spired us to extend some earlier work we had done to analyze the effectiveness of the mandates that govern local planning for coastal storm hazards in Florida (Deyle and Smith 1994). We were stimulated in part by noting the limited explanatory power of the com- parative studies, and also by the substantial variation we had found in the extent to which local communi- ties followed Florida’s planning mandates. These findings suggested that other factors besides the attri- butes of a state’s planning mandate may significantly influence the content of local plans.

In this study, a detailed analysis of eighteen county and city comprehensive plans from the coastal area of Florida explores hypotheses about the varied responses of communities to the mandate contained in the state’s 1985 Local Government Comprehensive Planning Act. We assess the compliance of local plans with GO individual state requirements pertinent to coastal storm hazards, from among several hundred requirements in the regulations that govern local plan preparation. Our analysis examines the impacts of both the manner in which the state land planning agency, the Department of Community Affairs (DCA), has implemented the statutory mandate, and the local conditions the communities face.

There are two levels at which plan content can be analyzed: (1) the threshold question of what issues a plan addresses and (2) the more complex question of how a community addresses specific planning issues in its data analysis, goals, objectives, and policies. Our analysis of the coastal storm hazard portion of plans produced in Florida investigates only the first ques- tion. Our findings are evidence of the influence of the agency’s implementation process on the extent to

APA JOURNAL.AUTUMN 1998

which state mandates are complied with and, there- fore, on the ultimate content of local comprehensive plans. We also find some evidence that local condi- tions may affect whether plans address certain issues in cases where the state does not enforce the man- date strictly.

The Peculiar Challenge of Natural Hazards Planning

State and federal governments usually shoulder a substantial proportion of the costs of responding to and recovering from natural disasters. In many recent, presidentially declared disasters, the federal govern- ment has assumed 90 or 100 percent of these costs rather than the 75 percent minimum set forth in the Stafford Act, which governs federal disaster assistance. States such as Florida have often covered the nonfed- era1 share of disaster assistance for local governments. Both federal and state governments, therefore, have a substantial stake in reducing the risks from natural hazards and have pursued various means of encourag- ing local governments to take mitigative actions. For a number of reasons, however, local governments do not show much interest in mitigating natural haz- ards, and especially not through land use planning and development management (Olshansky and Kartez 1998):

. . . [Tlhere is no public constituency, costs are immediate and benefits uncertain, benefits may not occur during the tenure of current elected officials, public safety is not visible, and other public issues are more immediate. (181)

Local governments tend instead to focus o n emer- gency response. Thus, in the case of coastal storms, which are the natural hazard of greatest concern in Florida, what planning was done historically has cen- tered on evacuation and sheltering. To the extent that mitigation was pursued by local governments, it fo- cused on altering the environment (building seawalls, protecting sand dunes) or strengthening the built en- vironment (more stringent building codes), rather than on altering land use types or intensities in haz- ardous areas. This context, then, is one where the interests of the local and the higher levels of govern- ment diverge significantly, and where a planning man- date may be effective for accomplishing state policy objectives.

The Effectiveness of Planning Mandates

Burby and his colleagues conducted several analy- ses of the effects of state planning mandates, using

LOCAL GOVERNMENT COMPLIANCE WITH STATE PLANNING MANDATES

data from a comparative study of the natural hazards components of local plans produced in five states- California, Florida, North Carolina, Texas, and Wash- ington (Berke and French 1994; Burby and Dalton 1994; Dalton and Burby 1994; Berke et al. 1996). All four analyses demonstrated that the presence of a state mandate significantly influenced the hazard planning components of local plans, and that the stronger mandates had more effect. However, the plans analyzed in these studies scored relatively low on the scales used in each study to measure plan quality.’ In the Berke and French study, for example, mean scores (on a scale of 0 to 1) for the inclusion of hazards goals ranged from 0.30 to 0.38 for communities plan- ning under state mandates in California, Florida, and the coastal region of North Carolina. The highest mean score by state on Burby and Dalton’s 5-point index of plan quality was 1.6 for communities in Florida.

Besides the relatively low scores, these studies showed high variation in quality among the plans pro- duced under mandates. Thus, for example, the stan- dard deviations of the plan quality scores shown by Berke et al. were generally higher for the mandated communities than for the non-mandated communi- ties. This variation is also reflected in the relatively low explanatory power of the multivariate models used to explain plan content-adjusted R2 values ranged from 0.22 to 0.40 in Burby and Dalton, and from 0.19 to 0.28 for non-mandate and mandate localities, respec- tively, in Berke et al.

These results strongly suggest that other factors beyond the legal content of the state planning mandate are at work. If mandates are truly effective, local plans, at a minimum, should address the specific issues detailed in the state planning mandate. That is the focus of our analysis of local governments’ compliance with Flori- da’s planning mandates o n coastal storm hazards. In the following sections we briefly characterize Florida’s planning mandate, describe the compliance patterns of the local plans we reviewed, and then define and analyze several hypotheses in an attempt to explain these patterns.

Florida’s Coastal Hazard Planning Mandate

Florida’s planning mandate, which derives from the 1985 Local Government Comprehensive Planning Act (Chapter 163, Florida Statutes), specifies that all cities and counties must prepare and adopt local com- prehensive plans and have them approved by the state Department of Community Affairs (DCA). The plan- ning mandate is both broad and detailed. Plans are

required to include eight major elements: (1) capital improvements; (2) future land use; (3) traffic circula- tion; (4) sanitary sewer, solid waste, drainage, potable water, and aquifer recharge; (5) conservation of natu- ral resources; (6) recreation and open space; (7) hous- ing; and (8) intergovernmental coordination. In addition, all coastal communities are required to com- plete a coastal management element that addresses ten separate planning objectives, two of which spe- cifically concern coastal storm hazards.

Administrative regulations adopted by DCA (Chapter 9J-5, Florida Administrative Code) detail the specific issues each plan must address with individual goals, objectives, and policies. (Figure 1 lists the 60 in- dividual 9J-5 mandates concerned with coastal storm hazards.) The specific content of the goals, objectives, and policies, however, is not specified. Thus communi- ties are free to choose how to meet each mandate in their individual plans.

Local governments were required to submit their draft plans to DCA for review according to a schedule that spanned four years: 1988-1991. DCA reviewed the plans in two stages. Teams of planners conducted line-by-line reviews of the draft plans against the ad- ministrative requirements. They itemized each plan’s deficiencies and made suggestions for revisions. The review teams’ recommendations were themselves re- viewed, and often amended, by senior staff in the agency. Jurisdictions then had 60 days to revise and adopt their comprehensive plans, after which DCA conducted a “compliance” review. The formal decision to find the plan in compliance, and if appropriate, to impose sanctions for noncompliance, was then made by the State Administration Commission, consisting of the Governor and the Cabinet.

How Have Florida’s Communities Complied with the State’s Mandates?

We evaluated compliance with the mandates listed in figure 1 by reviewing the coastal elements of the final, state-approved comprehensive plans prepared by nine counties and nine cities across the state: Jackson- ville Beach, Jacksonville-Duval County, St. Augustine, Flagler County, Palm Bay, Brevard County, West Palm Beach, Palm Beach County, Key West, Monroe County, Cape Coral, Lee County, the City of Sarasota, Sarasota County, Apalachicola, Franklin County, Panama City Beach, Bay County. We selected the jurisdictions to provide a representative sample of communities, with a balance of different local conditions that might be expected to influence the content of plan elements concerned with coastal hazards. We used the following

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R O B E R T E. DEYL13 AND IUCHAKII A. StvlITH

I. INVENTORY AND ANALYSIS MANDATES A. Inventory of Existing Land Uses within the Coastal Area (FAC

9J5.012(2)(a)) 1. existing land uses 2. conflicts among shoreline uses 3. need for waterdependenl sites 4. areas in need of redevelopment 5 . economic base in relation to future land use element 6. maps showing existing land use and waterdependent uses

B. Hurricane Evacuation Planning Inventory and Analysis (FAC 9JS.O12(2)(cXI)) [aU evacuation] 1. hurricane vulnerability zone 2. number of persons requiring evacuation 3. number of persons requiring public shelter 4. number of shelter spaces available 5 . evacuation routes 6. transportation and hazard constraints on evacuation routes 7. evacuation times 8. impact on evacuation from anticipated population density 9. impact on evacuation from special needs of the elderly,

10. analysis of local government measures to maintainlreduce

C . H a r d MiligOriOn and Post-Disaster Redevelopment Inventory and Analysis (FAC 9J5.012(2)(@(21 and (3))

handicapped. and hospitalized

evacuation times

1. identify coastal high-hazard area (CHHA) [hazard

2. existing and proposed land use in CHHA [hazard

3. Structures with history of repeated damage [post-storm

4. coastal/shore protection structures [bazard mitigation] 5 . measures to reduce exposure through relocation [post-

6. measures to reduce exposure through structurai

7. measures to reduce exposure through public acquisition

mitigation]

mitigation]

redevelopment]

storm redevelopment]

modification [post-storm redevelopment]

[post-storm redevelopment] D. Beach and Dune Qsrern Inventory and Analysis ( F A C

9J5.012(2)(~)(2) and (0) [all beach and dune systems] 1. beach and dune coditions 2. past trends in erosion and accretion 3. effects of shore protection structures 4. existing/potential beach renourishment areas 5 . measures that could protecthestore dunes

E. Coastal Infrastructure Inventory and AMlySiS ( F A C 9J5.012(2)(e)(2),(3), and (h)) [aU coastal infrastructure] 1. infrashucture in CHHA 2. potential for relocating threatened infrastructure 3. demand, capacity, and area served 4. future needs for facilities 5 . funding sourceslphasing in of needed improvements

11. GOALS, OBJECTIVES. AND POLICIES MANDATES A. Gwls (FAC 91-5.012(3)(a))

I . restricting development activities that damagddestroy

2. protecting human life [evacuation; hazard mitigation;

3. limiting public expenditures in areas subject to destruction

coastal resources [beach and dune system]

post-stom redevelopment]

[coastal infrastructure] B. Objectives (FAC 9J-S.O12(3)(b))

1. protectionlrestoration of beaches and dunes [beach and dune system]

2. limiting public expenditures that subsidize development in CHHA, except for restoration/ enhancement of natural resources [coastal infrastructure]

3. directing population concernrations away from CHHAs [hazard mitigation]

4. maintaining or reducing hurricane evacuation times [evacuation]

5 . preparing postdisaster redevelopment plans to reduce exposure to hazards [post-stonn redevelopment]

C . Policies (FAC 9J-5.012(3)(~)) 1. restoration/cnhanccment of beach and dune systems [beach

and dune systems] 2. hazard mitigation including regulation of

a . building practices [hazard mitigation] b. floodplains [hazard mitigation] c. beach and dune alteration [beach and dune system] d. stormwater management [hazard mitigation] e. sanitary sewer and septic tanks [hazard mitigation] f. land uses [hazard mitigation]

3. reduce or maintain hurricane evacuation times [evacuatlon]

4. postdisaster redevelopment policies a. distinguish between immediate repaidcleanup and long

term redevelopment [post-storm redevelopmenl] b. removailrelocationlmodi~cation of damaged

infrastructure & unsafe structures [coastal infrastructure]

c. limiting redevelopment in areas of repeated damage [post-stom redevelopment]

d. policies for incorporating recommendations of interagency hazard mitigation report into local comprehensive plan [hazard mitigation]

5 . identifying areas needing redevelopment as opportunities

6. coastal high hazard area (CHHA) arise [post-storm redevelopment]

a. designating CHHA [hazard mitigation] b. limiting development within CHHA mazard

c. reiocatinglrcplacing infrastructure away from CHHA mitigation]

[coastal infrastructure] 7. shoreline land uses

a. establishing priorities [hazard mitigation] b. establishing performance standards [hazard mitigation]

infrastructure] 8. ensure availability of required infrastructure [coastal

FIGURE 1. date issue categories in which an individual mandate is included. (See table 1 .)

variables to select the cases: ( 1 ) history of hurricane strikes prior t o the plan year, ( 2 ) extent to which coastal areas were developed, a n d ( 3 ) population size.

We expected coastal hazard issues t o have greater salience in t h e communities t h a t had more recent hur- ricane experience before they prepared their plans.

Florida comprehensive plan mandates governing coastal storm hazards. Notations in brackets indicate man-

T h e range in o u r sample is substantial: the year of the most recent hurricane to strike Sarasota County was 1946, versus 1985 in Franklin and Bay counties and 1987 in Monroe County (Jarrell, Hebert, and Mayfield 1992). We expected that concerns with evacuation and safety issues might be higher in communities with

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LOCAL GOVERNMENT COMPLIANCE WITH STATE PLANNING MANDATES

more developed coastal areas, whereas they might give less attention to mitigation through development management, given the limited opportunities to alter their existing development patterns. For this variable we relied on an analysis of the percentage of developed beachfront land in coastal communities that had been prepared for the State Division of Beaches and Shores (1990). Values ranged from a low of 78 percent in Bre- vard County to 100 percent in Duval and Palm Beach counties. We used population size as a proxy for the resources and expertise likely to be available to the community in preparing its comprehensive plan. Among the cities, 1990 populations ranged from 2,602 in Apalachicola and 4,051 in Panama City Beach to 67,643 in West Palm Beach and 74,991 in Cape Coral. 1990 county populations ranged from 5,165 in Frank- lin County to 405,120 in Palm Beach County and 653,230 in Duval County.

We coded each of the 60 mandates as “not in com- pliance” or “in compliance” (O/l). To be considered compliant, inventories, analyses, goals, objectives, and policies had to address the mandates with sufficient specificity. We did not, however, evaluate plan quality, i.e. how it addressed the issues or whether the policies proposed were strong and likely to be effective.

We grouped the planning mandates in two ways. The first approach, based on plan component struc- ture, is mirrored in the structure of the 9J-5 reg- ulations and figure 1: (1) inventory and analysis mandates, ( 2 ) goal mandates, (3) objectives mandates, and (4) policy mandates. The second aggregation ap- proach groups the plan mandates by different catego- ries of policy issues: (1) evacuation, (2) beach and dune systems, (3) hazard mitigation, (4) coastal infrastruc- ture, and (5) post-storm redevelopment. These catego- ries allow us to explore hypotheses about the salience of different aspects of coastal storm hazards, both for local governments and for the state. The relevant pol- icy issue categories for each mandate listed in figure l are indicated in brackets.

The community scores for each mandate category were calculated as the percentage of the mandates with which each community complied. Table 1 pre- sents these compliance rates for the 18 coastal com- munities we analyzed, aggregated by plan components and by issue categories. Both groupings clearly show that the final, state-approved plans of the local com- munities did not comply uniformly with the state’s mand-ates. In fact, on average, only 50 percent of the mandated goals and fewer than half of the policies that concern storm hazard planning were explicitly ad- dressed in the local plans. Inventory and analysis re- quirements are among those items for which there were relatively high percentages of compliance-an

TABLE 1. Compliance rates for Florida comprehensive plan mandates governing coastal storm hazards

Mandates

Mean Compliance Standard

Rate Deviation % %

Plan Components Inventory and analysis 64.03% 21 .OO% Goals 50.00 29.92 Objectives 64.14 30.65 Po I ici es 47.95 21.74

Issue Categories Evacuation 76.92% 22.65% Beach and dune systems 62.39 18.25 Hazard mitigation 48.61 20.89 Coastal infrastructure 50.00 29.60 Post-storm redevelopment 48.77 23.46

N = 18 except for the Beach and Dune Systems issue category, for which N = 14.

outcome we ascribe to the fact that many of the data needed to satisfy these requirements were available at the time (Nave 1997). In contrast, compliance with the policy mandates was the lowest. This is likely to reflect the specific nature of the policies and the obligations that their adoption places on the local community. Given the rather general and vague meaning of goals, we expected compliance with the goal mandates to be high. We attribute the relatively low rate of compli- ance to the small number of goals-three-and the proportionately large effects when a community failed to address any one of them.

Substantial variation in compliance rates is also evident when the mandates are aggregated by issue categories: typically over three-quarters of the evacua- tion mandates were met, but half or fewer of the man- dates concerned with land use and development controls (hazard mitigation, coastal infrastructure, and post-storm redevelopment) were adequately cov- ered in these final approved plans. Compliance with mandates concerned with preservation of beach and dune systems was intermediate between these ex- tremes. The findings are consistent with our under- standing of local government perspectives on coastal hazards. Protection of public safety through evacua- tion is given the greatest importance; it is followed by protection of existing development through such means as preserving beach and dune systems. Initia- tives to reduce risks through development controls are the least favored, because of their perceived political and economic costs. Throughout, the standard devia- tions for compliance within individual mandate cate-

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ROBERT E. DEYLE AND RICHARD A. SMITH

gories range from 18 to 31 percent. Thus, substantial variation existed among individual plans as well as among mandate categories.

These findings are consistent in one respect with the previous studies discussed above: we have pro- vided additional evidence of the low salience of hazard mitigation strategies in general and development limi- tations in particular. Our results are inconsistent, however, with what might be expected from a state with a strong planning mandate. Despite the very ex- plicit state mandates requiring that such strategies be addressed, we have shown that the extent to which lo- cal communities have complied with these require- ments has a high degree of variation. Thus, the results in table 1 suggest that the implementing agency may not have insisted o n the same level of compliance with every mandate and may have been inconsistent in what it required within mandate categories. We turn now to the questions of why and how such variation occurs in the context of what has been characterized as a strong, coercive state planning mandate.

Operating Under a Coercive Mandate

May and Burby (1996) argue that some level of co- ercion is necessary if higher-level governments seek to advance policies through local governments, but the local governments are less committed to those poli- cies. The authors maintain that compliance with such coercive mandates rests in part on the continued will- ingness and ability of the higher-level government to exercise its review and sanctioning authority over local governments. The extensive literature o n policy imple- mentation suggests, however, that administrative practicality and political feasibility are likely to sub- stantially influence how the designated administrative agency implements a mandate in that situation. (See, for example, Pressman and Wildavsky 1973; Bardach 1977; Bardach 1979; Sabatier and Mazmanian 1983; Browne and Wildavsky 1984; Majone and Wildavsky 1984; Hasenfeld and Brock 1991.) It is likely, therefore, that the manner in which the Florida Department of Community Affairs implemented the 1985 local plan- ning mandate may, explain a substantial amount of the observed variation in local plan content.

Structured interviews with DCA staff who were major actors in the review of local plans confirm that political pressure and administrative feasibility sub- stantially affected how the agency enforced the spe- cific 9J-5 planning mandates? According to Nave (1997) and Pelham (1997), the agency had to walk a fine line between a review process that was too rigor- ous and one that was too lenient. A key indication of

that is the way in which state officials imposed the statutorily authorized sanctions that significantly withhold state funds from local governments. The Ad- ministration Commission wielded the sanctions with restraint. Only 34 percent of the adopted plans were initially found to be in compliance, yet in 1988 and 1989 sanctions were levied in just three cases when communities refused to meet the plan submission deadline. According to Pelham, the sanctions were im- posed to send a strong message that the state would not permit communities to ignore the state’s planning mandate. Nonetheless, sanctions were never used to enforce compliance with specific substantive require- ments of the mandate.

Political pressures influenced the plan review pro- cess as well. The first plan reviews were extremely thor- ough and resulted in extensive lists of deficiencies. Early on, however, DCA encountered criticism from communities and state legislators that the 9J-S regula- tions were too cumbersome and too detailed. DCA of- ficials were pressured to shorten the deficiency reports and expedite the approval of plans. There was consid- erable pressure on DCA to be flexible and to move away from micro-management to assessing plans as a whole. Pelham reports that these pressures also changed over time. Following the election of Governor Lawton Chiles in 1990, his administration made it clear that the sanctions would not be imposed. As a result, compliance was achieved principally through negotiation.

Administrative realities pushed the agency in a similar direction. DCA had to review more than 400 comprehensive plans in four years, each of which ad- dressed at least eight sets of policy issues, plus coastal issues where applicable. The draft plans were subject to comment by a variety of state and sub-state agen- cies as well as the public, and each plan had to be re- viewed twice by the agency. Most were hundreds of pages long. Although the plan review teams were di- rected to perform a comprehensive evaluation of the initial plans, it was the senior staff, including the sec- retary, the division director, and others, that decided which deficiencies were of greatest concern (Nave 1997; Pelham 1997). The agency could not pursue ev- ery issue with equal vigor, so priorities had to be estab- lished. During the first years of Pelham’s tenure as DCA Secretary, c o n c ~ r r e n c y , ~ development moratoria, and urban sprawl received his greatest attention.

Senior staff developed an informal list of “fatal flaws” as one means of contending with the magni- tude and complexity of the review process. According to Nave (1997), only when one of these issue inadequa- cies occurred was a plan likely to be declared non- compliant. One such flaw did concern coastal storm

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LOCAL G O V E K N h l E N T COMPLIANCE WITH STATE PLANNING MANDATIJS

hazards- namely, policies that would allow increased densities within the designated coastal high hazard area of a community (Nave 1997; Pelham 1997). The senior s t a f f s priorities influenced the focus of the evaluations performed by the plan review teams. A list of “major issues” was used to structure these reviews (Banning 1997). The list includes 5 3 individual 9J-5 requirements, but encompasses only 12 of the 60 man- dates concerning coastal storm hazards that are listed in figure 1. All I 2 concern evacuation-see sections I. R., II.B.4., and II.C.3 in figure 1.

Evacuation and public safety were virtually the sole focus of DCA’s concern with coastal hazards. Pel- ham (1997) and Nave (1997) report that this narrowed view arose from three circumstances besides the broader factors of administrative feasibility and politi- cal pressure. First, DCA’s Division of Emergency Man- agement (DEM) was looked to as the agency’s authority on storm hazard issues. DEM viewed evacu- ation as a critical policy concern, in part because the agency had been criticized during the 1980s for inade- quate hurricane evacuation planning in the state. Sec- ond, counties already had to address hurricane hazard mitigation in their comprehensive emergency manage- ment plans (CEMPs), and D E M viewed many of the 9J-5 requirements as duplicating the CEMP require- ments. Finally, the DCA staff perceived little chance of accomplishing hazard mitigation through land use planning and development management in most coastal areas of the state, because they had already been developed (Nave 1997).

The effect of this implementation behavior by se- nior DCA staff appears in a number of outcomes be- sides those reported in table 1. For example, given the distinction made between major and minor issues in the review process, we would expect the rates of com- pliance to be higher for major issues. Indeed, this is the case; the 18 communities’ mean compliance rate with the storm hazard planning mandates viewed by DCA as major issues is 76 percent, versus 5 3 percent for the remaining storm hazard mandates.

To further test this distinction, we compared our evaluations of the final plans that were approved by DCA with the evaluations by DCA staff of the initial plans submitted for state review. We compared the to- tal numbers of deficiencies for major and for non- major issues flagged by DCA in their initial reports to the local communities with the total numbers of deficiencies we found in the final plans. (See table 2.) This analysis shows a clear dichotomy in the revisions made to plans after DCA’s review. Though the number of deficiencies in the major issue mandates, which fo- cused exclusively on evacuation, was cut by more than half (from 109 to 52), the number of deficiencies in

TABLE 2. Deficiencies o f initial and final plans for the coastal hazard planning mandates viewed by the Florida Department o f Community A f i i r s as “major” and “non-major”

Total Total Deficiencies in Deficiencies in

“ Major” ‘IN o n- M aj o r” Coastal Hazard Coastal Hazard

Planning Planning Mandates Mandates

DCA review o f initial 109 plans

plans Our review o f final 52

388

406

Chi-square - - 19.023, p = 0.001; 1 degree offreedom, N = 18

other coastal storm hazard planning mandates was es- sentially unchanged. The number of deficiencies in our review of the final plans was slightly higher than that in DCA’s initial review, which probably reflects a higher standard of acceptance o n our part (Pelham 1997). A chi-square test of independence confirms that these evaluations are independent at the 0.001 level of significance.

We also have evidence that plans with more initial total deficiencies across all major issue mandates were less likely to comply, in the final approved plan, with the non-major issue mandates for storm hazard miti- gation. The Pearson’s correlation coefficient between compliance with non-major issue mandates and the total number of initial major issue deficiencies is -0.50 (significant at 0.06 level of significance). We take this to indicate that non-major issue mandates were overlooked or negotiated away in the face of large numbers of plan deficiencies in major issue mandates.

The latter finding may also help to explain the high standard deviations we observed in the compli- ance rates of different communities’ plans for the same mandate categories. (See table 1 .) In an effort to further explain this apparent inconsistency across plans, we examined the compliance rates of plans eval- uated by DCA’s three different review teams. The ini- tial comprehensive plans submitted by communities were assigned to one of three teams of planners (Teams A, B, C), with each team administered by a dif- ferent plan manager. Usually these initial reviews de- fined the scope of the issues on the table when senior staff reviewed the plans, although senior staff some- times raised questions about major issues if they found they had not been adequately scrutinized by the review teams (Nave 1997; Pelham 1997).

The composition of the teams changed over time

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ROBERT E. DEYLE AND RICHARD A. SMITH

TABLE 3. Effect of the Florida Department of Community Affairs review team on compliance with planning mandates

Mandates

Mean Compliance, Mean Compliance, Mean Compliance, Difference in Means: Reviews by Team A

( N = 3) (N = 7) ( N = 8) t-values Reviews by Team B Reviews by Team C Teams B and C

Plan Components Inventory and analysis 61 .I 8% 55.67% 74.81% 2.01"" Goals 22.22 54.17 57.14 0.20 0 bjectives 38.33 67.50 71.43 0.26 Policies 51.81 41.56 53.60 1.10

Issue Categories Evacuation 66.67% 70.19% 89.01% 1.77"*

Hazard mitigation 52.08 39.84 57.14 1.64* Coastal infrastructure 40.00 48.75 55.71 0.54

Beach and dune systems 38.89 62.96 64.81 0.21

Post-storm redevelopment 48.15 40.28 58.73 1.54*

All Mandates 54.1 9% 51.94% 66.85% 1.91""

Major Issue Mandates 66.67% 68.75% 88.10% 1.67* Non-Major Issue Mandates 50.83 47.34 61.43 1.65"

* * p = 0.05 @ t > 1.75 * p = 0.10 @ t > 1.34

as new assignments were made and new personnel en- tered the process (Banning 1997). The training and ex- perience of the planners on the teams varied widely. Furthermore, the teams operated largely indepen- dently of each other, resulting in slightly different per- ceptions of the issues and the standards by which plans were reviewed. Under these conditions, it is pos- sible that plan compliance scores are affected by the particular group to which the plan was assigned.

To test this possibility, we computed the mean compliance scores for the set of plans reviewed by each of the three teams. As shown in table 3, for some man- date categories there were indeed large differences in mean compliance scores between the teams. We con- ducted an F test for statistical significance of these dif- ferences among the three groups, and none of the differences were found significant at the 0.1 level of significance or higher. However, a paired significance test, using the t statistic to compare Teams B and C, does show that the plans reviewed by these two teams have significantly different compliance scores for a number of the mandate categories. Thus, plan content also appears to be at least partially a function of which personnel at DCA reviewed a plan.

One of the tenets of implementation theory is that individuals who occupy positions of authority in implementing agencies can influence how legislated policies are executed (Bardach 1977; Sabatier and Mazmanian 1983; May and Williams 1986; Dunsire 1990). Thus the observed variance in compliance rates across mandate categories among the different local

APA JOURNALmAUTUMN 1998

plans we analyzed may also be attributed to differ- ent implementation strategies at the upper levels of DCA's administration. The former DCA Secretary Thomas Pelham (1997) reported that his successor, William Sadowski, was under even greater pressure from the administration of Governor Lawton Chiles to be flexible and permit greater local variation in plan content. We anticipated, therefore, that the plans ap- proved during Sadowski's tenure might have lower compliance rates than those approved under Pelham.

Table 4 compares the mean compliance scores for the different storm hazard mandates for plans ap- proved under Pelham and Sadowski. During Pelham's tenure, compliance determinations were issued for 15 of the 18 plans we analyzed. The other three were is- sued under Sadowski. Because of the distribution of these numbers, the results may not be entirely reliable. Nevertheless, the mean compliance scores reported in table 4 show that, overwhelmingly, there are lower mean scores for communities whose plans were ap- proved under Sadowski. It is noteworthy that compli- ance rates were substantially lower for the evacuation mandates and other major-issue storm-hazard man- dates that had been the principal concerns under Pelham's administration. Although alternative inter- pretations of these outcomes are possible (e.g., that the later plans were those that were most problem- atic), it is nonetheless the case that substantial plan deficiencies were not corrected under Sadowski's ad- ministration.

In summary, there is significant qualitative and

LOCAL GOVERNMENT COMPLIANCE WITH STATE PLANNING MANDATES

TABLE 4. Effect o f administrative agency chief executive on compliance with planning mandates

Mandate

Plans Approved Plans Approved Under Pelham Under Sadowski

(N = 15) (N = 3)

Difference in Means t-values

Plan Components Inventory and analysis Goals 0 bjectives Policies

Issue Categories Evacuation Beach and dune systems Hazard m i tigation Coastal infrastructure Post-storm redevelopment

All Mandates

Major-Issue Mandates Non-Maior Issue Mandates

69.57% 46.67 71.67 50.53

83.59% 64.65 49.58 55.33 51.11

62.40%

83.33% 56.86

36.36% 66.67 26.67 35.09

43.59% 44.44 43.75 23.33 37.04

36.67%

38.89% 36.1 1

3.09*** 1.09 2.77""" 1.19

3.67""" 1.91"" 0.46 2.22** 0.97

2.93 *** 3.85""" 2.09**

* * * p = 0.01 @ t > 2 . 5 8 * * p = 0.05 @ t > 1.75

quantitative evidence that the problems of reviewing and approving the comprehensive plans submitted un- der Florida's Growth Management Act resulted in a variety of adjustments and compromises in the crite- ria for plan approval. Furthermore, it is evident that the compromises worked to the &sadvantage of most of the substantive storm hazard mandates, except for those concerned with hurricane evacuation. Storm hazard issues other than evacuation were not highly salient to either local governments or the state. Thus, when localities did not meet the letter of the 9J-S regu- lations for those mandates, their deficiencies were readily overlooked by DCA in its efforts to approve plans that met what it considered the intent of the legislative mandate and that complied with the man- dates DCA considered to be most crucial.

Our analysis also indicates that DCA tolerated substantial variations in compliance within specific mandate categories. Some of the variation has been attributed to the differing training, expertise, and fo- cus among the DCA review teams and the changing policies of the upper DCA administration under dif- ferent governors. We hypothesize that beyond this, the variation also may reflect differences in local con- ditions. It is to this second hypothesis that we now turn.

The Influence of Local Conditions Several of the researchers who analyzed data from

the cross-state survey of local planning directed by Burby examined the effects of local conditions o n the

content of local plans. Berke et al. (1996) tested five dimensions of local conditions: local commitment to hazard mitigation goals, local capacity to plan, local perception of threat from natural hazards, feasibility of land use adjustments to mitigate hazards, and de- gree of threat posed by hazards. They found that local conditions were related to plan quality only in com- munities in non-mandate states. They suggest this may indicate that the state planning mandate "subs ti- tutes" for the influence of local factors o n plan con- tent; that is, the mandate overcomes variation in local planning capacity and compensates for lack of local concern or understanding of hazards. Dalton and Burby (1994), in a different analysis of the same survey data, found that variation in plan content was ex- plained by only one measure of local conditions-pop- ulation density.

We tested the narrower question of the associa- tion between plan compliance and local conditions for the mandates in different issue categories and for ma- jor and non-major issue mandates. We analyzed three groups of local condition variables: (1) storm exper- iences (magnitude of the last direct-hit hurricane, magnitude divided by number of years since this hurricane), (2) development patterns (population den- sity, shoreline development), and (3) planning capac- ity (local government own-source revenues). We found no significant relationships (at the 10 percent confi- dence level) for 1990 population density (U.S. Depart- ment of Commerce 1992), percent of developed shoreline (Florida Department of Environmental Pro-

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ROBERT E. DEYLE AND RICHARD A. SMITH

TABLE 5. Influence of local conditions on compliance with storm hazard planning mandates

Kendall's tau-b Correlations'

Mandates

Magnitude o f Last Direct-H i t Hurricane

(N = 18)

M agn i tu d e / T i m e Since Last Direct-

Hit Hurricane (N = 18)

Issue Categories Evacuation Beach and dune systems ( N = 14) Hazard mitigation Coastal infrastructure Post-storm redevelopment

0.17 0.27 0.35" 0.22 0.32

0.38" 0.1 8 0.04 0.49"* 0.09

Major Issue Mandates 0.25 -0.33 Non-Major Issue Mandates 0.37" 0.26

* * p = 0.05 @ t > 1.75 * p = 0.10 @ t > 1.34 t Sample sizes are as indicated for each column, except where indicated otherwise for the Beach and Dune Systems issue category. Hurricane hazard measures are defined relative t o the year when the plan was initially submitted t o DCA for review, using data from Jarrell, Hebert, and Mayfield (1992) and Hebert, Jarrell, and Mayfield (1993).

tection, Division of Beaches and Shores 1990), or 1986-87 local revenues from own sources (U.S. De- partment of Commerce 1988). We did obtain some sig- nificant correlations, however, between compliance and measures of hurricane experience. These are shown in table 5 as Kendall's tau-b correlation coeffi- cients. There is some relatively weak evidence that storm experience may influence compliance with man- dates on non-major issues and with two of the non- evacuation issue categories: hazard mitigation and coastal infrastructure.

The analysis of major and non-major issue man- dates suggests that DCA's differential enforcement may have allowed local conditions (storm experience) to influence compliance with those mandates that were of lesser concern to the state. The correlation be- tween the second measure of storm experience, i.e., magnitude divided by time since the last direct-hit hurricane, and compliance with evacuation mandates, however, suggests that DCA enforcement may not have completely "substituted" for local conditions even on this high priority issue.

Conclusion Do state planning mandates work? The recent lit-

erature on planning mandates for natural hazards provides convincing evidence that mandates do work at one level-state mandates have been successful in compelling local governments to develop the required plans. A t issue, however, is not merely plan develop- ment, but plan content. Invariably, planning man-

dates go beyond the simple matter of requiring a plan, to require that local plans contain specific compo- nents and address specific issues. In Florida this takes the form of several hundred specific directives cov- ering both the types of data and the analysis that the local community is to complete, as well as directives to adopt goals, objectives, and policies that address specific issue areas ranging from housing, transporta- tion, and infrastructure to coastal management and others.

Our analysis demonstrates that compliance by lo- cal communities with the detailed requirements of the state planning mandate is highly variable. The mean compliance rates for different mandate categories vary substantially, as do those within mandate categories. We find substantial evidence that mandate compli- ance, and therefore plan content, was influenced by the manner in which the state administrative agency pursued its responsibilities, including how it defined the issues and how well it monitored and enforced compliance. We have weaker evidence that some local conditions, i.e., the community's recent experience with hurricanes, may have influenced the salience of storm hazards and the community's compliance with planning mandates.

Our evidence is most compelling for the influence of agency implementation. Administration of the comprehensive planning mandate by the Florida De- partment of Community Affairs (DCA), which was a task both new and complex, occurred within the con- text of limited time and enormous political contro-

466 APA JOURNALmAUTUMN 1998 i

LOCAL GOVERNMENT COMPLIANCE WITH STATE PLANNING MANDATES

versy. DCA was under pressure to make the review system work and to fend off threats to the authorizing statute that ranged from revision to recision. They met these challenges by treating some issues more rigorously than others and negotiating compliance with local governments according to those priorities. Throughout, our data show that compliance with the mandates treated as major issues by DCA was higher than compliance with all others. We also show that variations in compliance are associated with the or- ganization of the plan review process and with the leadership of the agency.

These results suggest that state mandates should not be viewed as monolithic entities that are uni- formly implemented. Although other researchers con- clude that the presence of a stronger mandate in Florida explains the higher quality of the natural haz- ards components of local plans, our results show that the Florida mandate was selectively implemented by the state administrative agency, and that storm hazard planning requirements were not rigorously enforced. This suggests that it is important to take account of the “adaptive translation” (Browne and Wildavsky 1984) of the statutory mandate that goes on during the implementation process, when analyzing the in- fluence of planning mandates on plan content or other planning outcomes.

Our demonstration of the selective exercise of co- ercive powers in implementing the Florida planning mandate raises the possibility of alternative explana- tions for the apparent relationship between the strength of the state’s mandate and the quality of the local plans produced. In a comparative study of local plans from a small number of states, it may be that mandate strength covaries with the substantive re- quirements of the mandate concerning hazard mitiga- tion. In such a case, researchers run the risk of making spurious inferences about the impact of the mandate on local plan quality unless controls are included for the degree to which the detailed state plan require- ments correspond with the components of the re- searchers’ indices of plan quality. One remedy for this potential limitation would be to include a variable that represents a quality score for each state’s plan re- quirements, rather than using a dummy variable for the state in which the community is located.

It is intuitively reasonable that local community conditions also should affect plan content. We found weak evidence that some local conditions are associ- ated with compliance with those mandates that have lower priority for the state administrative agency. Sev- eral explanations are possible. First, the small effect of local conditions may reflect a generally low salience of

coastal storm hazard issues among the communities we studied, i.e., variations in local conditions were largely irrelevant because the issues were of little con- cern to nearly all the communities. Second, we may not have effectively tested the relevant local condi- tions. However, our finding that some local conditions are related to compliance with the mandates on non- major issues is consistent with DCA’s selective en- forcement of the state planning mandate. DCA was more willing to allow communities to exclude certain issues from their plans where those issues were consid- ered to be less crucial.

Thus, the question of how mandates influence plan content has not yet been fully answered. Planning mandates clearly influence the decision of whether or not to prepare a local plan. Our inference from the comparative state studies done by Burby and others is that the particulars of a state’s mandate requirements may also influence the issues addressed in local plans, particularly where the issues of state concern have low local salience. Our study shows, however, that the state administrative agency’s implementation of the mandate has a substantial effect on which issues com- munities are more likely to address in their plans.

Beyond the question of plan content is the issue of how local governments use their plans. Do the plans produced under the state’s planning mandate guide local decision-making, as originally intended, or are they produced only to satisfy state requirements? If the latter, then the issue of how the implementation process affects plan content is of only secondary inter- est. Other research we have conducted suggests that local officials in many Florida communities are un- aware of, or have paid little attention to, the policies in their comprehensive plans o n coastal storm hazards (Smith and Deyle forthcoming). These behaviors suggest that the strength or substance of the state mandate is of little consequence without local com- mitment to the policies contained in the plan. Hence, the issue turns not only on the question of whether communities comply with planning mandates, but also o n the conditions under which the plan influ- ences local decision-making.

AUTHORS’ NOTE

The authors would like to thank Philip Berke, Raymond Burby, Linda Dalton, Robert Nave, and Thomas Pelham for their comments and helpful suggestions on earlier drafts. This research was supported by grants from The Florida De- partment of Community Affairs, Florida Coastal Manage- ment Program, using funds made available through NOAA under the Coastal Zone Management Act of 1972, as amended, and from The Florida Sea Grant Program, The

APA JOURNAL.AUTUMN 1998 1467

ROBERT E. DEYLE AND RICHARD A. SMITH

University of Florida, using funds made available through the National Sea Grant Program, NOAA.

1. Burby and Dalton (1994) rated the mean quality of plans from different states by counting the number of development management measures included in each plan from a list of five they specified. Berke and French (1994) constructed separate plan quality indices for 11 plan dimensions encompassing 66 items ranked on an ordinal scale: 0 = not mentioned in the plan; 1 = men- tioned, but not detailed; and 2 = mentioned and de- tailed.

2. We conducted structured interviews with three DCA staff who were involved in reviewing the plans we ana- lyzed. Thomas Pelham served as secretary during the time when all the plans we analyzed were initially sub- mitted to DCA for review. Three were approved under his successor, William Sadowski, who is now deceased. Robert Nave served as director of the DCA Division of Resource Planning and Management during the time when nine of the plans we analyzed were reviewed by the agency. Nave reported directly to the department secretary. Walker Banning supervised one of the three plan review teams within the Division of Resource Plan- ning and Management.

3. Concurrency is a term peculiar to Florida’s 1985 Local Government Comprehensive Planning Act. It is defined as “coordinat[ing] the timing of development with capi- tal improvements planning by providing for the delivery of necessary facilities simultaneous with, or within a rea- sonable time of, the permitting or occupation of new development” (Pelham 1992).

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