Although climate change and global warming may be stated to be a global crisis, many cities around the world are developing their climate action plans, even if their own countries (federal government) withdraw from climate change agreements, such as the US officially withdrawing from the Paris Agreement at the beginning of November 2020, which is a greenhouse gas mitigation, adaptation and financing agreement signed in 2015, which local agencies and departments can use to develop their own municipal climate plans (U.S. Department of State, 2019). Public Administrators have an important role during this development of municipal plans goals, which may include ensuring reduction in carbon emissions, access to clean air and water, in part to improve the health and safety of their residents. In 2017, the Salt Lake City Council and former Mayor Jackie Biskupski jointly published a plan to tackle climate change and carbon pollution, called Climate Positive 2040 (SLC CP2040). The SLC CP2040 is a 13-page report highlighting plans and programs that work towards a cleaner energy future for Salt Lake City. Specifically, this research identified that SLC CP2040 presents 32 goals and strategies to encourage, spur, support, and incentivize science-based policy changes. SLC CP2040 also provides guides to reduce the use, waste, and consumption of energy and food, which may reduce carbon pollution.
This microstudy presents an analysis of the SLC CP2040. The study uses a synthetic policy-comparison approach, by contrasting the SLC CP2040 goals with recommendations drafted by the Intergovernmental Panel on Climate Change (IPCC). The IPCC is a robust scientific group of world-renowned scientists, approved in 1988 by the United Nations General Assembly, which provides governments and policymakers at all levels scientific information to develop climate policies and as significant inputs into international climate change negotiations.
Specifically, this microstudy compares the SLC CP2040 with the 2014 IPCC Assessment Report Mitigation of Climate Change (AR5; the IPCC Summary for Policymakers report published shortly before the SLC CP2040). Through a comparative analysis of the two documents, we assess the extent to which the 45 goals and suggestions that we identify in the IPCC SPM AR5 are reflected in the 32 SLC CP2040 goals. Our findings indicate that the SLC CP2040 proposes significant policy proposals and changes but does not adopt more than half of the IPCC SPM AR5 suggested goals.
Evaluating the SLC CP2040 falls in line with much research being conducted globally. Because much climate change policy development is happening at city and municipal levels, scholars have undertaken studies in municipalities from Canada to Denmark to evaluate their impacts. While this study focuses on Salt Lake City, it is helpful to note what evaluations have been done elsewhere.
According to the IPCC SPM AR5, it is vital to consider the wide range of possible adverse side effects and co-benefits and spillovers from climate policy that cannot be well-quantified. For such side-effects to materialize (or not) will depend on local circumstances and the scale, scope, and pace of climate policy implementation. This includes biodiversity conservation, water availability, food security, income distribution, the taxation system’s efficiency, labor supply, employment, urban sprawl, and the sustainability of the growth in developing and developed countries (IPCC SPM AR5, 2014, p. 17).
Climate change mitigation is highly dependent on a city’s financial and governance capability. The distribution of costs across countries can differ from the distribution of their actions. Various regional initiatives between the national and global scales are being developed and implemented, but their impact on global climate change mitigation has been limited to date. Evidence suggests this may not be the case for all energy supply and AFOLU (Agriculture, Forestry, and Other Land Use) measures. Mitigation efforts and associated costs vary between countries in mitigation scenarios (IPCC SPM AR5, 2014, pp. 17-26).
Plan quality evaluation is a framework and well-established field of research, from Kaiser et al. (1995) to more recent studies conducted by Lyles and Stevens (2014) and Berke et al. (2013). Such frameworks attempt to assess policy strengths and deficiencies. While researchers create different criteria to establish the assessments by which they study municipal climate change plans, most agree on ensuring plans are factual, have clear intentions and goals, are attainable and measurable, and have an impact on the city or municipality (Guyadeen et al, 2018). For example, Guyadeen et al. (2018), in a more recent study of Canada’s municipal climate plans, focuses explicitly on eight characteristics. Their evaluation of climate plans includes (1) fact base, (2) goals, (3) policies, (4) implementation, (5) monitoring and evaluation, (6) inter-organizational coordination, (7) participation, and (8) plan organization and presentation.
To have an empirical base for a plan – in this case, a municipal climate plan – requires credible facts and information. Strong fact bases help frame climate change as a local issue, to assess both current and future local conditions, including causes and effects (Aguiar et al, 2018; Baker et al, 2012; Fu et al, 2017; Geneletti and Zardo 2016; Li and Song 2016). For SLC CP2040, fact bases include an inventory of Greenhouse Gases (GHG) emissions, information on climate change impacts, and vulnerability assessments (SLC Community Carbon Footprint, 2010). This information is presented in parts of the climate change plan.
Our microstudy borrows from prior frameworks established by the many that have preceded this study by using a comparison-based approach to evaluating the SLC CP2040. Specifically, we use guidelines from the IPCC SPM AR5 as the comparison for the SLC CP2040.
We use three documents to carry our microstudy: (1) the Intergovernmental Panel on Climate Change 2014 Summary for Policymakers Assessment Report Mitigation of Climate Change (IPCC SPM AR5), (2) the Climate Positive 2040 report from the Salt Lake City Sustainability Department (SLC CP2040), and (3) the Salt Lake City Community Carbon Footprint (2010). The IPCC is among the most robust information sources of scientific evidence about climate change, providing perhaps the most authoritative comparison for the goals of the SLC CP2040 at the time of its publication. In 2014, the IPCC published an Assessment Report Mitigation of Climate Change (AR5). The AR5 comprises 1,435 pages, which analyzes 1200 new computer scenarios generated by 31 modeling teams worldwide. This report was compounded with 170 contributing authors providing draft texts and information to 235 coordinating lead authors and co-lead authors, which included 38 review editors. However, for this microstudy, we rely on a 30-page Summary for Policymakers as the comparison for the SLC CP2040, with a collection of 900 mitigations from those 1200 computer scenarios.
To conduct the analysis, we first analyzed the IPCC SPM AR5 to identify and compile the discrete goals it outlines. Our analysis resulted in 45 goals from the IPCC SPM AR5 (as identified in Tables 2 and 3). We then did the same for the SLC CP2040, resulting in 32 identified goals (see Table 1). We conducted a qualitative comparison of the SLC CP2040 goals against the IPCC SPM AR5 international guidelines. For each IPCC SPM AR5 goal, we determined whether the SLC CP2040 goals fully, partially, or did not align (assigning a 1, 0.5, and 0, respectively).
Although the SLC CP2040 did not cite reliance IPCC recommendations, the Plan primarily focuses on the transition to clean, renewable energy. Therefore, many of the goals attempt to encourage and incentivize the adoption and formulation of code updates or provide guidelines for reducing the use, waste, and consumption of energy and food, both of which reflect attempted reduction of carbon pollution. As seen in Table 2, the SLC CP2040 adopted less than half of the IPCC SPM AR5 goals (the unadopted IPCC goals are listed in Table 3, in the Appendix).
|No.||SLC CP2040 Goal Description|
|1||Access to clean air and water|
|3||Transition to clean, renewable energy|
|4||Remove carbon pollution from electricity|
|5||At least 16 separate government properties with renewable energy generation|
|6||50% renewable electricity for Salt Lake City government operations by 2020|
|7||Subscribe to approximately three megawatts (3 MW) of solar energy for use at various City facilities under the Company’s Subscriber Solar Program|
|8||100% renewable electricity for Salt Lake City government operations by 2042|
|9||Recycling 70% of the waste stream by 2025|
|10||100% community electricity by 2032|
|11||80% net reduction in carbon pollution by 2040|
|12||Zero waste by 2040|
|13||Encourages customer-side investments in renewable options like rooftop solar|
|14||Envisions measures to mitigate any incremental costs associated with pursuing clean energy users, preventing adverse impacts on low-income residents|
|15||Reductions in renewable energy costs “in parts”|
|16||SLC and Rocky Mountain Power will strive to develop a variety of energy efficiency and renewable resource options for all energy users (residential, commercial, industrial, gov, non-profit)|
|17||SLC and Rock Mountain will keep working together on Project Skyline and other programs.|
|18||Expanding public transportation options|
|19||Electrified transportation powered by renewable energy sources|
|20||Develop and investigate options to deploy EV charging infrastructure and innovative technologies|
|21||Reducing long-distance air travels|
|22||Reducing energy waste|
|23||Improve residential and non-residential properties’ performance in gas and electricity|
|24||Energy codes for new constructions|
|25||Support strong pollution reduction programs from industry|
|26||Reduce carbon emission from production and food waste|
|27||Improve local, low carbon, and diversified food production with more methods|
|28||Reduce consumable food waste|
|29||Recycling 70% of the waste stream by 2025|
|30||Working across sectors in non-partisan ways|
|31||Prioritize collaborations to enhance understanding of climate risks|
|32||Foster joint opportunities to reduce carbon pollution|
As stated above, the SLC CP2040 only mentions 21 of the IPCC SPM AR5 guidelines (or part of those goals), which is less than half of the 45 goals presented in the Summary for Policymakers. We found the SLC CP2040 to have four goals that are not mentioned or suggested in IPCC SPM AR5, as follows: to improve local, low carbon, and diversified food production with more methods (goal 27), working across sectors in non-partisan ways (goal 30), prioritize collaborations to enhance understanding of climate risks (goal 31), and foster collaborative opportunities to reduce carbon pollution (goal 32).
|IPCC SPM AR5 Goals||SLC CP2040 Goals||Alignment|
|Reduced costs for achieving air quality and energy security objectives (p. 16)||14||1|
|Sufficiency of resources to meet national energy demand (p. 16)||3||1|
|Resilience of energy supply (p.16)||4||1|
|Energy systems that are less vulnerable to price volatility and supply disruptions (p. 16)||3||1|
|Major cuts in air pollutant emissions (p. 17)||1||1|
|Legislate and plan air pollution controls (p. 17)||1||1|
|Energy supply sector emissions are expected to continue to be the major source of GHG emissions, ultimately accounting for the significant increases in indirect emissions from electricity use in the buildings and industry sectors (p. 17) | Decarbonization happens more rapidly in electricity generation than in the industry, buildings, and transport sectors (p. 20)||4||1|
|Reinforce the importance of early action for ambitious mitigation changing infrastructure developments and long-lived products into GHG-intensive emissions pathways “magnitude of the investment cost” (p. 18)||5, 6, 7, 8, 16, 17, 18, 19, 20, 23, 24, 25||1|
|Pace between introducing mitigation measures in energy supply and energy end-use and developments in the AFOLU sector (p. 18)||7, 8, 10, 16, 25||1|
|Changes in the energy supply sector (p. 18)||3, 4, 5, 6, 7, 8, 10, 13, 14, 15, 16, 17, 19, 24||1|
|Efficiency enhancements and behavioral changes, in order to reduce energy demand “near-term reductions in energy demand” in the transport, buildings and industry sectors for 2030 and 2050 (p. 20)||2, 22, 9||1|
|Dietary change and reduction in food wastes (p. 20)||26, 28||1|
|Reduce energy and material consumption (p. 24)||28||1|
|Reductions in total transport CO2 emissions of 15 – 40 % by 2050 (p. 21)||19, 20, 21||1|
|Adoption of very low energy building codes (p. 23)||22, 24||1|
|Efficiency of material use, recycling and re-use of materials and products (p. 24)||29||1|
|Reduce energy and material consumption (p. 24)||28||1|
|Waste reduction, followed by re-use, recycling, and energy recovery (p. 24)||12, 29||1|
|Develop appropriate enabling environments to play an important role in financing mitigation between the private and public sector (p. 29)||16||1|
|Redevelopment investments in new infrastructure, all transport modes, and urban development (p. 21)||20, 18, 19||0.5|
|Building codes and appliance standards (p. 23)||24||0.5|
A more detailed account of the findings suggests that the SLC CP2040 fully adhered to 19 IPCC SPM AR5 goals (42%), including: (1) reduced costs for achieving air quality and energy security objectives (goal 1, p. 16), (2) sufficiency of resources to meet national energy demand (goal 2, p. 16), (3) resilience of energy supply (goal 3, p. 16), (4) energy systems that are less vulnerable to price volatility and supply disruptions (goal 4, p. 16), (5) major cuts in air pollutant emissions (goal 5, p. 17), (6) legislate and plan air pollution controls (goal 6, p. 17), (7) energy supply sector emissions are expected to continue to be the major source of GHG emissions, ultimately accounting for the significant increases in indirect emissions from electricity use in the buildings and industry sectors (p. 17). Decarbonization happens more rapidly in electricity generation than in the industry, buildings, and transport sectors (goal 7, p. 20), (8) reinforce the importance of early action for ambitious mitigation changing infrastructure developments and long-lived products into GHG-intensive emissions pathways “magnitude of the investment cost” (goal 8, p. 18), (9) pace between introducing mitigation measures in energy supply and energy end-use and developments in the AFOLU sector (goal 9, p. 18), (10) changes in the energy supply sector (goal 10, p. 18), (11) efficiency enhancements and behavioral changes, in order to reduce energy demand “near-term reductions in energy demand” in the transport, buildings and industry sectors for 2030 and 2050 (goal 11, p. 20), (12) dietary change and reduction in food wastes (goal 12, p. 20), (13) energy intensity improvements (goal 13, p. 20), (14) reductions in total transport CO2 emissions of 15 – 40 % by 2050 (goal 18, p. 21), (15) adoption of very low energy building codes (goal 21, p. 23), (16) efficiency of material use, recycling and re-use of materials and products (goal 25, p. 24), (17) reduce energy and material consumption (goal 27, p. 24), (18) waste reduction, followed by re-use, recycling and energy recovery (goal 28, p. 24), and (19) develop appropriate enabling environments to play an important role in financing mitigation between the private and public sector (goal 44, p. 29).
The SLC CP2040 only partially followed another 2 IPCC SPM AR5 goals (5%): (1) redevelopment investments in new infrastructure in urban development (goal 19; p. 21), as at no time is this goal mentioned in the report on urban development, and (2) building codes and appliance standards (goal 23; p. 23), which at no time is mentioned in the report on appliance standard codes.
This microstudy undertook a synthetic policy-comparison of the SLC CP2040, by comparing the SLC Plan with the 2014 IPCC Assessment Report Mitigation of Climate Change. Collectively, as indicated in the findings reported above, our analysis suggests that the SLC CP2040 includes 21 of the 45 IPCC SPM AR5 goals. SLC CP2040 does not follow the other 24 IPCC SPM AR5 goals (53%; see the Appendix). This section expands on these findings by discussing overlapping or parallel political and policy considerations.
According to IPCC SPM AR5 “Thousands of cities are undertaking climate action plans, but their aggregate impact on urban emissions is uncertain. There has been little systematic assessment on their implementation, the extent to which emission reduction targets are being achieved, or emissions reduced” (IPCC SPM AR5, 2014, p. 26). Salt Lake City is one of those locations which has attempted to quantify such impacts – yest even here the aggregate impact on urban emissions is still uncertain. Part of this uncertainty can be found in the second part of SLC CP2040 introduction, which states that Salt Lake City published a community greenhouse gas inventory in 2009 to track changes in emissions annually (SLC CP2040, 2016, p. 2). In this inventory, Salt Lake City Mayor Ralph Becker together with more 49 people stated: “This baseline inventory tells us that Salt Lake City emitted 4.75 million metric tons of carbon dioxide equivalent “mT CO2e” – or 26 metric tons per person – in 2009, which is just above the national average per person” (SLC Community Carbon Footprint, 2010, p. 4). However, these figures diverge notably from research conducted between 2009 to 2015 – raising questions regarding the validity of the different measures and credibility of SLC CP2040 claims.
Our analysis raises other questions regarding the credibility and/or durability of claims made in the SLC CP2040. For instance, the Plan mentioned that Salt Lake City was part of national and international efforts committed to the tracking, reporting and reduction of carbon emissions, including the Carbon Disclosure Project (CDP), which was in 2016 compounded for 533 cities (SLC CP2040, 2016, p. 2). However, currently only 105 cities are part of this list – and Salt Lake City is no longer part of this list (CDP, Cities A List 2019). Also, the partnership mentioned between Salt Lake City and the Carbon Neutral Cities Alliance is no longer active (CNCA, n.d.).
Of course, we must note limitations of the study’s approach. For example, this study did not include local reports published between 2015 to 2020 because the study’s intention was only to measure the extent to which Salt Lake City followed international guidance at the time the plan was released to the public. Furthermore, it should be recognized that municipal environmental problems are not necessarily climate problems – these can be two distinct subjects (Felício, 2014, p. 257). Thus, the presentation and formulation of the Salt Lake City goals through the Climate Positive 2040 may have different approaches and tangent perspectives from international climate action goals.
A good example of this distinction may be a natural winter phenomenon observed in Salt Lake and Provo Counties, as a result of the area’s somewhat unique topography – the “inversion” (Utah Department of Environmental Quality, Air Quality, Inversion). Thermal inversions are a natural phenomenon that occurs in Utah and other mountain areas, involving a reversal of the normal tendency of air to cool down with increased altitude, and resulting in cold air at the earth’s surface getting trapped under a layer of warmer air. If a high-pressure system moves in, the gradual sinking of the warmer air acts as a cap over the cooler air, much like a lid over the valley bowl. The longer a high-pressure system lasts, the longer and stronger the inversion (UDEQ, n.d.). This impacts air quality, and not only cold air but CO2 and other trace gases may get trapped under this layer. Although inversions therefore create environmental hazards that seem to overlap with matters of climate change, the relationship between local inversions and global warming is as-yet uncertain.
Finally, it is worth noting that even as municipalities such as Salt Lake City continue to encourage climate actions, such as transitioning to clean energy sources, it is unclear the extent to which these isolated actions will have any impact on global climate trends. Aside from the fact that their impacts likely pale in comparison with other elements of the global climate system – such as the oceans that occupy about 72% of the Earth’s surface – there remains debate regarding the precise amount that human development activities are responsible for a warming climate (i.e. anthropogenic global warming). Thus, the extent to which municipal climate action policies can “move the needle” on climate change – at least in isolation – is likely small.
The goal of this study was to analyze the SLC CP2040 and compare it to the guidelines of the IPCC SPM AR5 report. While there is much research being done in the realm of analyzing the effectiveness of city climate plans, this research project has directly used the international guidelines for climate change policy as the guidepost to review Salt Lake City’s current climate plan. We developed a simple yet arguably effective scoring method through which SLC CP2040 and its support documents were compared against IPCC SPM AR5 recommendations. The results suggest that Salt Lake City’s Plan followed less than half of the IPCC SPM AR5 recommendations, neglecting 58% of the IPCC AR5 recommendations.
In summary, while SLC CP2040 proposes helpful and – to a degree – IPCC-informed policy goals that could have a local impact on Salt Lake City’s air quality and carbon emissions, the plan neglects other essential components from the IPCC SPM AR5. The plan has room for improvement, which could make the SLC CP2040 more impactful and meaningful to combat climate change in Salt Lake City and the Utah community-at-large. Of course, we recognize that this policy review is limited, for it only analyzed SLC CP2040 and the supporting documents through the lens of its relation to IPCC SPM AR5 policy proposals. Nonetheless, by analyzing the Salt Lake City Plan through the lens, we hope to help empower future policymakers to prepare better and support IPCC-approved policy proposals.
Berke, P., Spurlock, D., Hess, G., Band, L. (2013). Local comprehensive plan quality and regional ecosystem protection: the case of the Jordan Lake watershed, North Carolina, U.S.A. Land Use Policy 31, 450–459
Carbon Disclosure Project (CDP). (2019). Cities A List 2019. Retrieved Nov 2, 2020 from https://www.cdp.net/en/cities/cities-scores
Carbon Neutral Cities Alliance (CNCA). (n.d.). Retrieved Nov 2, 2020 from https://carbonneutralcities.org/cities/
Felicio, R.A., Onça, DS. (2010). “Mudanças Climáticas” e “Aquecimento Global” – Nova Formatação e Paradigma para o Pensamento Contemporâneo? [“Climate Change” and “Global Warming” – Formatting and New Paradigm for Contemporary Thought?]. São Paulo, Brazil: Ciência e Natura [Online], 36.3 (2014): 257-266.
Geneletti, D., & Zardo, L. (2016). Ecosystem-based adaptation in cities: An analysis of European urban climate adaptation plans. Land Use Policy, 50, 38-47. doi:10.1016/j.landusepol.2015.09.003
Guyadeen, D., Thistlethwaite, J., & Henstra, D. (2018). Evaluating the quality of municipal climate change plans in Canada. Climatic Change, 152(1), 121-143. doi:10.1007/s10584-018-2312-1
IPCC, 2014: Summary for Policymakers. In: Climate Change 2014: Mitigation of Climate Change. Contribution of Working Group III to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change [Edenhofer, O., R. Pichs-Madruga, Y. Sokona, E. Farahani, S. Kadner, K. Seyboth, A. Adler, I. Baum, S. Brunner, P. Eickemeier, B. Kriemann, J. Savolainen, S. Schlömer, C. von Stechow, T. Zwickel and J.C. Minx (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA.
Kaiser, E.J., Godschalk, D.R., and Chapin, S.F. (1995). Urban land use. Urbana: University of Illinois Press.
Lyles, W., Stevens, M. (2014). Plan quality evaluation 1994-2012: growth and contributions, limitations, and new directions. J Plan Educ Res 34, 433–450
Rocky Mountain Blue Sky Product Content Label. (2020). Prospective Product Content Label. Retrieved Nov 2, 2020 from https://www.rockymountainpower.net/savings-energy-choices/blue-sky-renewable-energy/product-content-label.html
Salt Lake City (SLC). Climate Positive 2040. Retrieved Nov 2, 2020 from http://www.slcdocs.com/slcgreen/CP0320.pdf
Salt Lake City (SLC). (2010). SLC Community Carbon Footprint. Retrieved Nov 2, 2020 from http://www.slcdocs.com/slcgreen/SLC%20Community%20Carbon%20Footprint%20Report%20(2).pdf
Salt Lake City (SLC). (2016). SLC Corp and Rocky Mountain Power Clean Energy Cooperation Statement. Retrieved Nov 2, 2020 from http://www.slcdocs.com/slcgreen/Climate%20&%20Energy/CooperationStatement.pdf
U.S. Department of State. (2019). On the U.S. Withdrawal from the Paris Agreement [Press Statement]. Retrieved from https://www.state.gov/on-the-u-s-withdrawal-from-the-paris-agreement/
Utah Department of Environmental Quality (UDEQ). (n.d.). Inversion. Retrieved Nov 2, 2020 from https://deq.utah.gov/air-quality/inversions#:~:text=Utah%20inversions%20often%20occur%20after,lid%20over%20the%20valley%20bowl
|1||Nuclear energy could make an increasing contribution to low-carbon energy supply (p. 20)|
|2||Replacing current coal-fired power plants with modern, highly efficient natural gas combined-cycle power plants or combined heat and power plants (p. 21)|
|3||Carbon dioxide capture and storage technologies (CCS) (p. 21)|
|4||Combining bioenergy with CCS (BECCS) (p. 21)|
|5||Strategies to reduce the carbon intensities of fuel and the rate of reducing carbon intensity (p. 22)|
|6||Overcome strong barriers with split incentives (e. g., tenants and builders) by policy interventions addressing all stages of the building and appliance lifecycles (p. 23)|
|7||Reduction the energy intensity of the industry sector by about 25 % compared to the current level (p. 23)|
|8||Reduction of hydrofluorocarbon (HFCs) emissions by process optimization and refrigerant recovery, recycling and substitution (p. 24)|
|9||Decreasing deforestation rates and increased afforestation (p. 24)|
|10||Reduce emissions from deforestation and forest degradation implemented sustainably (p. 25)|
|11||Packages of mutually reinforcing policies, including co-locating high residential with high employment densities (p. 25)|
|12||Achieving high diversity and integration of land uses (p. 26)|
|13||Increasing accessibility and investing in public transport and other demand management measures (p. 26)|
|14||Large changes in investment patterns in low-carbon electricity supply to reduce CO2 emissions (p. 26)|
|15||Make it easier to assess aggregate impact on future emissions (p. 27)|
|16||Decrease administrative and political barriers that make economy-wide policies harder to design and implement than sector-specific policies (p. 28)|
|17||Regulatory approaches that include energy efficiency standards “labelling programs that can help consumers make better-informed decisions” (p. 28)|
|18||Achieve mitigation in a cost-effective way by a cap and trade system (p. 28)|
|19||Tax-based policies specifically aimed at reducing GHG emissions (p. 28)|
|20||Reduction of subsidies for GHG-related activities in various sectors (p. 28)|
|21||Interactions between or among mitigation policies (p. 29)|
|22||Adoption of complementary policies for some mitigation policies does not raise the prices for some energy services that could hamper the ability of societies to expand access to modern energy services to underserved populations (p. 29)|
|23||Technology policy to complement other mitigation policies “such policies address market failures related to innovation and technology diffusion” (p. 29)|
|24||To implement climate policies across geographical regions (p. 30)|