Extending “body-brain” evolution to the real-world presents a number of difficulties due to conflicting idealizations between evolutionary and constructional models. Toward addressing this gap, we develop a simple model system to analyze the effects of undoing these idealizations. Preliminary experiments with this system show that high variability developmental substrates can influence evolutionary dynamics by causing ambiguities in selection. Furthermore the substrate can enable the evolution of adaptive responses to nondeterministic developmental effects.