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their own parochial concerns based on commonalities like race, class, and economic status. i�s Indeed, it has been observed that community consultations in the context of civic planning are rarely able to capture the views of the most disempowered groups.126 This last point is one of particular concern in New Orleans. New Orleans was a hotbed of race and class divisions before the hurricane and certainly remains so afterward. Moreover, New Orleans city planning processes, like those in many United States Southern cities, had long been dominated by elites; this was due in part to those cities' antebellum social structures. i�' It has been asserted that one of the principal reasons that post-Hurricane New Orleans opted for the community guided plan was that efforts to develop a comprehensive city-wide plan were challenged for failing to take into account racial and economic diversity. i�g By delegating the responsibility for planning to the resident-led design teams, the city was able to abdicate the broader responsibility that it would have had under a traditional Euclidean scheme. Though a number of areas sustained significant damage in Hurricane Katrina and in Hurricane Rita, the storm that came less than a month later, some of the greatest damage occurred in low—lying predominantly black areas such as the Lower Ninth Ward and the Seventh Ward.129 These areas also had the highest rates of poverty and the fewest resources in '25 Ourousoff supra. 126 John Friedmann, The Prospect of Cities, supra note 68, at 101. i�' David R. Goldfield, Planning For Urban Growth in the Old South, in The Rise of Modern Urban Planning, 1800-1914 11, 12-15 (Anthony Sutcliffe ed., 1980). 128 Ourasoff supra. 129 New Orleans is divided into seventeen wards. The Ninth Ward, located in the easternmost downriver portion of the city, is the largest of these wards and is arguably the most famous ward. 35