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Fact Sheets, Examples, and Benefits of State Clean Energy Programs

 

States across the country have been implementing policies to cut carbon pollution from the power sector for years – utilizing many of the same state policies that will be available for use under the Clean Power Plan.

In many cases, these policies have already resulted in improvements to the economy, cost savings to customers, and significant carbon pollution cuts. Below are a few examples of state efforts.


Leading states have recently advanced ambitious climate and energy goals.

  • Hawaii set a 100 percent Renewable Portfolio Standard (RPS) target for 2045, becoming the first state to require all of its electricity to come from renewable power sources. The new law, signed June 10th, sets additional incremental and long-term renewable energy targets: 30 percent by the end of 2020, 70 percent by 2040, and 100 percent by 2045.
  • Vermont set a 75 percent Renewable Energy Standard (RES) for 2032. The law also establishes distributed generation requirements and energy transformation requirement for utilities.
  • New York set a 50 percent RPS by 2030 in its 2015 State Energy Plan released in June. The plan also requires a 40 percent reduction in carbon pollution by 2030 from the state’s 1990 levels.
  • California has long had commitments in place to cut carbon pollution to 1990 levels by 2020 and by 80 percent below those levels by 2050. In April, Gov. Jerry Brown established a new interim state-wide target to cut carbon pollution by 40 percent below 1990 levels by 2030.
  • Michigan Gov. Rick Snyder delivered his 2015 Energy Special Message in March, setting efficiency and clean energy benchmarks, including goals to meet at least 15 percent more of the state’s energy needs in the next decade by eliminating energy waste and to meet 30-40 percent of energy needs with clean energy by 2025.


States are creating significant benefits while reducing carbon pollution.

  • The Regional Greenhouse Gas Initiative
    • The nine RGGI states in the northeast and mid-Atlantic have reduced power sector carbon pollution 40 percent since 2005, while the regional economy has grown eight percent.
    • A recent report by the Analysis Group found that RGGI generated $1.3 billion in economic benefits from 2012-2014. In the last three years, RGGI has created more than 14,000 new job years, and the program cut electricity and heating bills, saving consumers $460 million. A previous report demonstrated that RGGI had also generated $1.6 billion in economic benefits over the first three years of the program (2009 to 2011).
    • 2015 RGGI report found that investments of RGGI auction proceeds to date are projected to return more than $2.9 billion in lifetime energy bill savings to households and businesses in the region, and avoid the release of about 10 million short tons of carbon dioxide pollution.
       
  • California
    • California’s emissions from electricity have fallen by nearly 14 million metric tons CO2 equivalent between 2000 and 2013.
    • California has an ambitious renewable portfolio standard of 33 percent by 2020, which is projected to generate $60 billion and create up to 235,000 jobs.
    • Renewables now provide about 25 percent of California’s electricity. The state has shifted in-state fossil generation almost entirely to natural gas and is rapidly phasing out imported power from coal-fired power plants.
    • As noted above, in April Gov. Jerry Brown signed an executive order (EO  B-30-15) establishing a state-wide carbon pollution reduction target of 40 percent below 1990 levels by 2030. The order instructs all state agencies and departments to use existing authorities to reduce greenhouse gas emissions. California was already committed to cut carbon pollution to 1990 levels by 2020 and by 80 percent below those levels by 2050. By 2025, California expects to cut carbon pollution from the power sector by 25 percent from 2005 levels.

View Full California Fact Sheet (Released July 2015)

  • New York
    • From 2005-2011, New York reduced its overall carbon pollution by 18 percent while growing its gross state product by 7 percent. From 2005-2012, carbon pollution from the power sector decreased by more than 40 percent.
    • In June, Gov. Cuomo announced carbon pollution reduction targets under the state's “reforming the energy vision" (REV) to reduce greenhouse gas emissions by 80 percent by 2050. The targets by 2030 include: a 40 percent cut in greenhouse gases from 1990 levels, a 50 percent statewide goal for renewable energy, and a 23 percent cut from 2012 levels for energy consumption in buildings.
    • Already, New York’s renewable portfolio standard requires 30 percent of electricity from renewables by 2015.
    • Cumulative environmental benefits associated with New York’s clean energy investments made during the past 15 years have helped deliver cleaner air by eliminating nearly 5,000 annual tons of NOx, and SO2 and 4.2 million annual tons of CO2, equivalent to removing 881,000 cars from New York’s highways.

View Full New York Fact Sheet (Released July 2015)

  • Minnesota
    • Minnesota’s Next Generation Energy Act, adopted in 2007, established state-level greenhouse gas emission reduction targets of 15 percent from 2005 levels by 2015, 30 percent by 2025, and 80 percent by 2050.
    • Minnesota’s renewable standard requires 25 percent of power from renewables by 2025.
    • The state’s Energy Efficiency Resource Standard set a 1.5 percent energy savings goal for utilities that operate in Minnesota.
    • Minnesota’s clean energy and emissions reduction programs have helped the state reduce carbon pollution in the power sector by 18 percent from 2005 to 2012.

View Full Minnesota Fact Sheet (Released July 2015)

  • Connecticut
    • Between 1990 and 2012, carbon pollution from the power sector in Connecticut has declined by 34 percent while the state's economy grew by 41 percent.
    • A 2015 independent study estimated that between 2012 –2014 Connecticut’s investments of Regional Greenhouse Gas Initiative proceeds added more than $56 million in net economic value to the state and resulted in a net increase of 863 job-years.
    • Connecticut’s renewable portfolio standard requires all retail electricity suppliers to obtain at least 27% of their supply from renewable sources by 2020. The state has increased its deployment of in-state renewables more than ten fold since 2010.
    • The 2008 Global Warming Solutions Act requires a 10 percent reduction from 1990 emission levels by 2020 (which the state has already met) and an 80 percent reduction from 2001 emissions by 2050.

View Full Connecticut Fact Sheet (Released July 2015)
 

  • Massachusetts
    • Since 1990, greenhouse gas emissions in the power sector have fallen by 41 percent and while the state's Gross State Product increased 68 percent.
    • The Commonwealth's clean energy industry is growing rapidly. There was an increase in clean energy jobs of 11.8% in 2013 and now almost 80,000 employees are working in clean energy throughout the Commonwealth. Since 2011, growth in the clean energy sector has outpaced the growth in the overall Massachusetts economy by more than eight times.
    • The Global Warming Solutions Act requires cuts in carbon pollution from all sectors of the economy to reach a 25% reduction of greenhouse gas emissions below 1990 levels by 2020 and an 80% reduction by 2050.

View Full Massachusetts Fact Sheet (Released June 2014)

 

  • Oregon
    • Since 2002, the Energy Trust of Oregon has invested nearly $1 billion in energy efficiency and renewable energy generation. These investments have saved customers $1.3 billion on utility bills and reduced energy demand by over 400 average megawatts.
    • Oregon’s RPS requires the state’s largest utilities to provide at least 25 percent of their electricity from renewable sources of energy by 2025.
    • Oregon’s investment in energy efficiency and renewable energy generation has added $2.7 billion to the local economy, including $793 million in wages and $155 million in small business income.

 View Full Oregon Fact Sheet (Released June 2014)
 

  • Maryland
    • Maryland has set an economy-wide goal to reduce carbon pollution 25 percent from 2006 levels by 2020. Accelerating the reduction of carbon pollution from the electricity sector through participation in the Regional Greenhouse Gas Initiative (RGGI), and the expansion of energy savings and renewable energy programs are key components of the state’s Greenhouse Gas Reduction Plan.
    • An independent study found that Maryland’s Greenhouse Gas Reduction Plan is likely to generate $1.6 billion dollars in expanded economic output and support nearly 30,000 jobs.

View Full Maryland Fact Sheet (Released June 2014)

  • Delaware
    • Delaware’s carbon emissions per Gross Domestic Product (GDP) dropped by 63 percent from 1990-2009 while economic output continued to increase.
    • Between January 1996 and January 2010, the state's clean economy jobs increased by 28 percent, significantly outpacing overall job growth.
    • In 2010, Delaware increased its renewable energy portfolio standard to 25 percent renewables by 2025 with a 3.5 percent photovoltaic requirement. Over the past seven years, Delaware has increased solar throughout the state from 2 megawatts to 62 megawatts today. Delaware is one of the top states for solar energy – ranked 7th in the nation in 2012 and 2013 per capita for solar installations.

View Full Delaware Fact Sheet (Released July 2015)

State Net Capitol Journal: California, Hawaii lead way on climate change targets

 

In a story discussing state efforts to reduce carbon pollution and grow clean energy by Lou Cannon, Vicki Arroyo comments about how actions by individual states help drive similar efforts by other states. 

Prodded by the Environmental Protection Agency and led by California and Hawaii, states are tackling climate change and promoting renewable energy, says to the article. In addition to various state actions, the article discusses the EPA's Clean Power Plan and international efforts to reduce carbon pollution. 

Even small states can set an example, and Hawaii’s establishment of a 100-percent renewable energy goal could have “aspirational” value for other states, said Vicki Arroyo, executive director of the Georgetown Climate Center. ...

Arroyo believes a tipping point (for climate action) could be near. She points out that polls show younger people are more concerned about global warming than their elders — and more convinced that something can be done.

Read the full story here

Greenwire: EPA releases new state 'carbon budgets' under power proposal

 

U.S. EPA moved yesterday to show states what their responsibilities would be if they choose to use cap-and-trade programs to comply with a landmark federal draft rule aimed at curbing greenhouse gas emissions from power plants.

In a long-promised clarification memo, EPA said states would be allowed to turn carbon intensity targets into "carbon budgets," letting them comply with the rule via policies that limits emissions on an annual basis.

...

Gabriel Pacyniak of the Georgetown Climate Center said states might opt for a "carbon budget" approach in part because it's easier to administer than the rate-based target. All a state would need to do is measure emissions from power plants, rather than using a complex equation considering demand-side energy efficiency efforts and other factors.

Read the full article at Greenwire.

USA Today: Blue and red states going green on energy policy

 

Politically "red" and "blue" states are increasingly turning green as they push energy efficiency and renewable power to save money and protect the planet, says a report today with prominent bi-partisan support.

In the last two years alone, GOP-dominant red states have adopted policies that could serve as models for others seeking to meet proposed federal targets for reducing heat-trapping carbon dioxide emissions, according to the "State Clean Energy Cookbook" by Stanford University and the Hoover Institution.

...

In the last decade, as its costs have fallen, solar and wind energy have grown markedly nationwide. So, too, has the number of energy-efficiency programs. Vicki Arroyo, executive director of the Georgetown Climate Center, a research group, says 40 states now require or encourage a certain amount of their energy be obtained from efficiency measures, renewable power or both.

Read the full article at USA Today.

Inside EPA: EPA Plans Guides To Ease Hurdles On ESPS Rate Conversions, Efficiency

 

A top air office official is pledging to take steps to ease states' compliance with EPA's greenhouse gas (GHG) standards for existing power plants, with the agency slated to release guidance on how to translate its rate-based GHG targets to mass-based measures, as well as a policy for verifying reductions from energy efficiency programs.

In addition, Joe Goffman, EPA's associate assistant administrator for climate and senior counsel for EPA's air office, said in Sept. 18 remarks that the agency could rework interim 2020 emissions goals that states must meet under the existing source performance standards (ESPS) but which many states have urged the agency to drop because they require such steep reductions.

"It seems to us that will be something we will have to analyze very, very carefully," Goffman said of the interim targets. The agency will have to revisit the issue "to the point of providing additional analysis that concludes we got it more or less right, or if we can't come to that conclusion, look at ways of changing that feature."

Goffman's remarks during an event at the Georgetown Climate Center in Washington, D.C., did not include specific announcements of new guidance or a different approach to the GHG rule's targets, but they underscore that EPA is actively considering several major requests from states and utilities.

Read the full article at Inside EPA.

Bloomberg BNA: EPA Power Plant Rule ‘Workable’ But Needs Improvement, Utilities Say

 

An Environmental Protection Agency proposal to regulate carbon dioxide from existing power plants is “workable” but needs improvement, energy executives said at a Sept. 18 forum.

While utilities said they could support the EPA's approach to regulating carbon dioxide emissions, they also cautioned that the rule may not provide the incentives needed to stimulate investment in demand reduction programs or new lower-carbon generation sources during a forum sponsored by the Georgetown Climate Center and Lazard, a financial advisory firm.

“Overall, the industry views the rule as generally workable, but it needs some important tweaks to make it truly workable,” Ted Craver, chairman, president and chief executive officer of Edison International, said. “The framework is there, but the comments will be oriented toward being constructive and suggesting improvements that need to be made.”

Read the full article on Bloomberg BNA.

The Energy Daily: EPA carbon rule ‘generally workable,’ but needs tweaks—EEI chairman

 

Investor-owned utilities see proposed federal regulations to trim power plant carbon emissions as “generally workable,” but have identified 20 areas of concern that need to be addressed by the Environmental Protection Agency, the chairman of the Edison Electric Institute said Thursday.

Ted Craver, chairman, president and chief executive officer of Edison International and chairman of EEI, which represents investor-owned utilities, told a Washington, D.C., conference that one of the group’s biggest concerns with the EPA’s Clean Power Plan (CPP) regulation is the timetable for reducing power plant emissions of carbon dioxide (CO2).

...

“Timing is probably the single most critical area for utilities,” said Craver, who spoke on a panel at a conference sponsored by the Georgetown Climate Center and the investment firm Lazard. “The 2020 to 2030 period will be a big focus for utilities….”

Read the full article at Energy Daily.

New Online Tool Illustrates Key State Energy and Carbon Pollution Data Ahead of New EPA Rules

 

Leading up to the Obama Administration's release of new carbon pollution standards for the power sector, the Georgetown Climate Center today launched a dynamic online tool that generates maps and graphics that can help the public better understand how the new rules may affect different states.

The data visualization tool is intended to assist state policymakers, stakeholders, and reporters grappling with energy and carbon pollution data.

It gives users the ability to compare energy and carbon pollution data across multiple states, create regions for analyzing potential multi-state collaborations under the new rules, view in-depth state energy profiles, and generate an array of U.S. data maps, including maps that show the degree to which carbon pollution has changed in each state since 2005.   It will also provide context about how such data can inform states' compliance options under the power plant standards.

"We believe this tool provides essential data for states as they move forward to implement the power plant standards to achieve cost-effective carbon pollution reductions," said Vicki Arroyo, executive director of the Georgetown Climate Center. "The tool makes it easy to see how many states have already reduced their carbon pollution emissions and emission rates, and to explore the potential for further reductions."

The State Energy Analysis Tool provides state-by-state breakdowns of key energy data, including carbon pollution reductions, electricity generation sources, changes in electricity generation mix over time, emissions of carbon dioxide and other pollutants, renewable energy usage, and states' clean energy potential. Data provided by the tool is compiled from leading sources, including the U.S. Energy Information Administration and the National Renewable Energy Laboratory.

To view State Energy Analysis Tool data, go to one of the links below:

The Center launched an initial, spreadsheet-based version of the tool in 2013 that was developed by the Analysis Group.  Today's tool builds on the initial success of its predecessor, increases the amount of data available, and provides users with an interactive, graphics-rich experience.

Illinois Clean Energy and Economic Development Policies

 
View Other Midwest Clean Energy Policy Approaches

More than 300 Illinois companies work in the wind, solar or geothermal energy industries. They range “from old-line steel fabricators to high-tech start-ups” and employ over 18,000 people.   On the automotive front, the state will invest over $10 million in electric vehicle infrastructure from 2011-2014.

Illinois is home to about 16 wind farms - over 2700 megawatts of wind generation capacity.   In 2011, Illinois was second only to California in new installed wind power and currently ranks fourth in wind-generated electricity.  More than 150 Illinois companies engage in some piece of the wind-energy pipeline.

Chicago has thirteen wind energy headquarters including developers and wind turbine manufacturers.   Chicago draws wind companies because of proximity to wind projects; its air, rail and auto transportation infrastructure; and legal and financial expertise.  The state’s Renewable Portfolio Standard (RPS) increases demand by requiring investor-owned electric utilities to ramp up to 25 percent of electricity from renewable sources by 2025, with 75 percent of that to come from wind. Additionally, six percent of renewable energy must come from solar by the year 2015. In 2008, lawmakers amended the law to cover all competitive electric suppliers in Illinois, essentially doubling the size of the RPS.

The wind-power industry employs about 1,500 directly in Illinois, plus another 3,800 among local suppliers, according to a Navigant Consulting, Inc. study for the American Wind Energy Association. The study predicts a drop to about 800 direct jobs and 1,100 supplier jobs by next year if the federal wind production tax credit expires.

Renewable Energy Resources Program

This state program promotes the development of renewable energy through the Renewable Energy Resources Trust Fund, a public benefits fund administered by the Department of Commerce and Economic Opportunity (DCEO).  The Fund receives about $5-6 million a year for eligible projects and is supported by surcharges including a $0.05 per month per residential electric and gas service, $0.50 per month for small nonresidential electric and gas service, and $37.50 per month for large nonresidential electric and gas service.   These funds support several renewable energy programs including the Solar and Wind Rebate Program, Community Solar and Wind Energy Program, Renewable Energy Business Development Program, and Biogas and Biomass to Energy Grant Program.

Solar and Wind Energy Programs

The DCEO offers rebates for solar and wind energy systems up to 30 percent for residential and commercial systems (equipment and installation) and up to 50 percent for non-profit and government installations, with a maximum individual award of $30,000.  DCEO also offers a grant program that provides similar incentives for larger distributed solar and wind energy projects.  The maximum incentive for this program is $250,000.

Renewable Energy Business Development Program

This program funds projects that support new or expanded renewable energy production through the development of renewable energy businesses and component manufacturers.  Proposed projects currently are eligible for grants up to 50 percent of total project cost, with a maximum grant of $500,000.  

This program has helped attract several solar and wind energy manufacturers to Illinois.  For example, in 2010, DCEO provided Wanxiang America a $700,000 grant for developing a solar panel production facility in Rockford.  The $12.5 million project is expected to create 60 jobs.  In late 2011, Rockford Solar Partners, LLC, a joint venture between Elgin-based Wanxiang America and Chicago-based New Generation Power, received federal environmental approval to proceed on the largest U.S. commercial airport solar farm, starting at 20 MW with plans to scale up to 62 MW. Ameren Illinois executed a 20-year power purchase agreement to acquire the energy and all renewable attributes from the project as part of the state’s long-term renewable energy procurement program. 

In 2008, Siemens Energy & Automation received a $1.25 million grant for a second plant in Elgin for its Mechanical Drives and Winergy businesses, adding an estimated 355 jobs.  The high precision, high torque mechanical gear drives are used by the wind, cement, coal and oil and gas industries.

In recent years, fewer state funds were spent on this program due to the federal ARRA stimulus grant programs.  DCEO received grant applications for the Renewable Energy Business Development Program last fall and expects to approve up to five grants in 2012.

Biogas and Biomass to Energy Grant Program

This state program helps fund projects designed to use biogas or biomass as fuel to produce electricity with combined heat and power (CHP) through gasification, co-firing or anaerobic digestion technologies.  Applicants are eligible for up to $2,500 for feasibility studies and up to 50 percent of total project cost, with a maximum grant for biogas to energy systems of $225,000 and for biomass to energy systems of $500,000.  So far, $800,000 has been awarded for several feasibility studies and six projects including two electric generating systems at wastewater treatment facilities in Fox Lake and Danville, a digester gas system at a dairy cow farm in Pearl City, and co-firing corn bran pellets and wood chips at a CHP system at John Deere Harvester in East Moline.  

Invest Illinois Venture Fund

The Invest Illinois Venture Fund (IIVF supports young, innovative companies and start-ups that show a high potential for future growth resulting in the creation of high-paying professional Illinois jobs.  The fund focuses on cutting-edge technology sectors including clean energy and energy efficiency and  is part of the state’s Advantage Illinois program to reduce the credit crunch for small businesses through a federal small business program.

Electric Vehicles and Infrastructure

 Illinois provides early leadership and support for the adoption and use of electric vehicles (EVs):

  • The Illinois Environmental Protection Agency offers rebates toward EV purchases.
  • DCEO received up to $10 million in capital funding to award EV manufacturing and infrastructure grants and loans.
  • The Illinois Commerce Commission (ICC) launched a Plug‐in Electric Vehicle Initiative to explore regulatory issues related to EV deployment including impact on the electric grid. 
  • In partnership with the City of Chicago and Clean Cities Coalition, Illinois is installing a comprehensive public charging station network.  With about $1 million from a DCEO capital grant and $1 million in federal Clean Cities American Recovery and Reinvestment Act (ARRA) funds, the partners leveraged almost $7 million in private investment to develop the Chicago Area EV Charging Station Project. The project will deploy 73 DC Fast Charge and 207 Level 2 EV charging stations throughout the Chicago area.
  • In addition, EVtown’s creation in Bloomington-Normal  and Kane County’s EV infrastructure ordinance are models for the nation.

A recent report provides a roadmap for EV deployment in Illinois and summarizes the benefits:
"…environmental benefits from reduced emissions, economic development and job creation from the growth of EV‐related technologies and services, decreased reliance on imported petroleum, and opportunities to integrate and leverage renewable energy resources and smart grid deployment."

In the spring of 2011, the General Assembly passed legislation to encourage car‐sharing organizations to purchase EVs in fiscal years 2012 and 2013. Two known car‐sharing organizations, I‐GO and Zipcar, will be eligible for up to 25 percent of project costs involving the purchase of new EVs and new charging infrastructure.  The funds can only be used to purchase new EVs from Illinois car dealerships.

Two Chicago-based entities support renewable and clean energy businesses. The Clean Energy Trust, a non-profit corporation, helps connect entrepreneurs, researchers and early stage companies to accelerate business development, and the Illinois Clean Energy Community Foundation provides clean energy grants.

Rio + 20: International Goals and Subnational Actions

 

In June 2012, the United Nations Conference on Sustainable Development met in Rio de Janeiro to take stock of the progress achieved since the 1992 Earth Summit and to chart a new path for the future.  In advance of the summit, the Georgetown Climate Center was joined by White House Council on Environmental Quality Chair Nancy Sutley and numerous states and provinces to discuss sustainable activity happening in states, provinces, and regions across the U.S., Canada, Germany, and Brazil.  The event was co-sponsored by the Province of Quebec's Washington Bureau.

As the keynote speaker, Sutley discussed the Obama Administration's commitment to supporting healthy and sustainable communities and clean energy job growth while acknowledging that we still have a lot of work to do. She also emphasized the important role that states play in advancing environmental goals in the United States.

"I know that we, as a nation, have made the progress we've made on the environment not just because of federal laws, but certainly because of the incredible work at the state and local level.  

"Sustainability –  I think as we've learned over the last 20 years – is about protecting the environment, but it's more than just that.  Certainly, from where I sit, and I think all of you sit, it is essential that we protect our natural resources, and that we understand the link between our natural resources and the health of our economy and our society."  

States and provinces also weighed in and discussed an array of initiatives that are underway – including everything from conservation to energy efficiency to clean technology development to higher fuel efficiency standards.

Dan Esty, the Commissioner of the Connecticut Department of Energy and Environmental Protection,  who was also with the Environmental Protection Agency at the Earth Summit 20 years ago, praised the outcomes of the original summit, but also underscored the large amount of work that still must be done.

"We are at a very, very awkward moment, and I do think it is critical that we recognize that it is important...to focus on getting the job done on the ground," he said.

 

More coverage:

Watch a video feed of this event.
E&E TV Discusses Sustainability with Vicki Arroyo and Maryland's Kathy Kinsey in the Lead Up to Rio+20

 

Event Agenda and Participants:

 

Welcome:
Edith Brown Weiss, Francis Cabell Brown Professor of International Law at Georgetown Law

Keynote Address:
Nancy Sutley, Chair of the White House Council on Environmental Quality (CEQ)

Subnational Panel:
Discussion of efforts to promote sustainability and address climate change through clean energy development and promoting innovation (e.g., renewables, electric vehicles), emissions trading programs, and multistate and cross-border collaborations.  These initiatives and collaborations provide important examples of successful approaches to sustainable development.

  • Doug Scott, Chairman, Illinois Commerce Commission
  • Dan Esty, Commissioner of the Connecticut Department of Energy and Environmental Protection 
  • Kathy Kinsey, Deputy Secretary, Operations and Regulatory Programs, Maryland Department of the Environment
  • Alain Olivier, Director, Québec Government Office in Washington, DC
  • Brian Turner, Deputy Director, Washington DC Office of California Governor Edmund G. Brown Jr.
  • Marianne Rude, Washington Representative, Province of Manitoba, Canada
  • Mark Rupp, Director, Washington DC Office of Washington Governor Chris Gregoire
  • Vivian Thomson, Associate Professor, University of Virginia and Former Vice Chair, Virginia Air Pollution Control Board  (discussing work of Brazil and German states)

Moderator: 
Vicki Arroyo, Executive Director, Georgetown Climate Center & Visiting Professor, Georgetown Law
 
  
 

 

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