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This suit and its resolution reflect the complexities of law structured around fixed levels of governance attempting to address a problem like climate change. Localities are often at the front-end of forwarding more progressive climate policy, such as in their joining international coalitions of cities, developing greenhouse gas emissions plans, and pledging to meet Kyoto standards. But this dispute serves as an important reminder that localities also are important sites in the dialogue about whether economic development and emissions reductions can be reconciled. For example, Warming Law Blog has reported on the massive political tensions surrounding this suit. As our carbon economy faces up to the crisis of climate change, these kinds of conversations will only become more critical.