i
FIVE WAYS TO
FUND A GREEN
NEW DEAL
1
Introduction 2
We can afford it. We can’t afford not to. 2
Public investment driving private finance 3
Five ways to fund a Green New Deal 4
1. Borrowing 4
2. Multipliers: Value future benefits 6
3. Tax those most responsible 8
4. Redirect dirty subsidies 10
5. Transform the Bank of England 12
No longer ‘if but ‘when’ 14
Endnotes 15
CONTENTS
2
INTRODUCTION
M
omentum is building around
a Green New Deal
1
– an idea
first developed by NEF and
others in 2008,
2
and now adopted by
a growing number of movements and
political parties around the world,
including in the UK.
3
The Green New Deal would be a major,
government-wide mission to respond
rapidly to the climate emergency
through a programme of state-led
investment in a new generation of good
jobs in clean industry, business and
infrastructure – in particular targeted at
the people and places that most need a
‘just transition’ to a new economy.
It’s a plan that meets the scale of
the climate crisis head on. We need
ambition to properly respond in a
socially just way to the imperative
of climate breakdown. It places the
state firmly at the heart of the climate
response, in a way we have almost
forgotten how to do after decades of
neoliberal economic policy.
Inevitably, as with all ideas that change
the rules of our economy, some people
will accuse it of costing too much. But
there’s no question that we can and
should fund this type of investment.
* NEF does not support the use of overseas offsets to balance out UK emissions within a ‘net’ calculation.
All investment costs money, but our
economy needs huge investment and
we can afford it. And unlike the kinds
of high carbon spending we have made
for decades, funding a Green New
Deal will be a win-win: good for both
people and the planet.
WE CAN AFFORD IT. WE
CANT AFFORD NOT TO.
The world has a handful of years to
act on the climate emergency. The
UK is keen to be seen as a leader on
the global stage, but is way off pace
at home.
4
The UK government is
committed to delivering ‘net zero’*
1
emissions by 2050, but Labour and the
Green Party have already pledged to
bring this date forward to 2030.
A programme like the Green New
Deal is essential to marry radical
climate action with social justice and
the rebalancing of the economy. When
wars need to be fought, or banks bailed
out, governments do not hesitate to
find the money.
The government’s total annual spending
is around 38% of GDP per year.
5
Spending on the climate emergency
each year only needs to increase to 2%
3
of GDP in the short term,
6
ramping up
to 5% to deliver change at pace.
7
Former
Chancellor Philip Hammond attempted
to criticise the new ‘net zero by 2050’
target by saying that it would cost “more
than £1 trillion”.
8
This was a one-sided
estimate that ignored the multitude of
jobs, innovation and resilience it would
unlock (see proposal 2) – and which in
any event represents only 1.5% of GDP
9
over that period.
Governments can borrow very cheaply;
the money they have available to spend
can be increased by the things they
spend money on, through higher tax
receipts; and they can if needed rely
on central banks for help. Provided
their spending supports productive
investment – the cornerstone of the
Green New Deal – any arguments
against borrowing are based on political
ideology rather than economic fact.
This pamphlet sets out five of the ways
we should fund the Green New Deal:
1. Public borrowing
2. Multipliers: valuing future benefits
3. Taxing those most responsible
4. Re-directing dirty subsidies
5. Transforming the Bank of England
PUBLIC INVESTMENT
DRIVING PRIVATE
FINANCE
The Green New Deal must be led by
democratic choices. This requires greater
state involvement and a much bigger
role for direct government investment.
That certainly does not mean that
there is no role for the private sector
in delivering the Green New Deal
– far from it. The Green New Deal’s
headline ambitions and determination
to guide innovation and investment
towards a clean and fair economy will
help provide the certainty to private
investors that they have been lacking
after many years of half-hearted
government climate policy.
10
But private markets will not deliver
the social justice that is integral to
the Green New Deal and the delivery
of a just transition. Markets alone
have little incentive to support the
workers, communities and places
whose livelihoods would be most
directly affected by a poorly managed
transition away from high carbon
work. The more that the private sector
is left to finance the transition to ‘net
zero’ without stewardship, the greater
the risk that the costs of the transition
will fall on the less well-off in society
– for example through higher everyday
energy bills. In other words, without
the approach of a Green New Deal,
the low-carbon transition risks
increasing inequality.
However the ‘five ways’ that we
set out in this pamphlet are about
simultaneously ramping up the
leadership and economic role of the
state whilst also setting a clear and
supportive framework for private
investment as well.
4
1. BORROWING
“Humanity will not come to an end if we double debt-to-GDP ratios,
but it could come to an end if we fail to tackle climate change” –
Professor Simon Wren-Lewis, University of Oxford
11
FIVE WAYS TO FUND A
GREEN NEW DEAL
Image: Tinmouse Animation Studio
A climate emergency means an end to
business as usual. Business as usual for
the last decade has been characterised
by austerity – which has harmed
people and held the economy back.
12
A Green New Deal however, needs
government investment. The most
obvious and best way it can do this
is by borrowing. One of the most
important things any government
should do is use its power to borrow at
ultra-low interest rates.
There has never been a smarter time in
history for the government to borrow
to invest. Interest rates are at or near
record lows
13
and likely to remain so
for the foreseeable future.
14
Modern
state-led investment programmes will
5
be hugely attractive to international
markets that want reliable, long-
term returns on their money. There
is a global ‘savings glut’: hundreds of
trillions of pounds of savings
15
looking
for something safe to invest in with a
modest return.
Did you know: The Austrian government just issued a 100 year bond (a
loan) at an interest rate of 1.2%, well below inflation. If inflation remains at its
current level, in 100 years’ time Austria would only effectively have to pay back
50% of what it owes.
16
Sometimes people argue against
borrowing by saying that it will
increase debt for future generations.
But borrowing is a fair way to pay for
useful and productive things across
time. Future generations will directly
benefit from investments we make
today, and borrowing helps to spread
the payments across generations.
The main problem is we are stuck
with arbitrary limits (‘fiscal rules’)
on the amount of borrowing that
can be carried out and debt that can
be incurred.
17
These rules, which
have evolved over time, currently
capping borrowing at 2% of GDP by
2020/21 – a level far too low, even for
an economy not facing the threat of
climate breakdown.
The rules also insist that the national
debt must be falling. With a handful of
years to launch and finance a Green
New Deal, the first step must be to
rewrite the rules to reflect the logic
of climate emergency.
18
New rules
must reflect what the government
can genuinely afford to spend, and
take into account both the benefits of
extra spending and the costs of not
investing enough.
ACTION 1:
Change the rules on
borrowing. Bin the arbitrary rules
on how much debt and borrowing
the government is allowed to
undertake, and make new rules t
for the climate emergency.
6
2. MULTIPLIERS: VALUE FUTURE BENEFITS
With hindsight, I now realise that I underestimated the risks. I should
have been much stronger in what I said in the report about the costs
of inaction. I underplayed the dangers.” –
Lord Stern, author of the Stern Review on the Economics of
Climate Change, speaking in 2016
19
Image: Tinmouse Animation Studio
The flip side of borrowing is that
many things on which money is spent
can more than pay for themselves in
the long run. Government spending
represents income to businesses and
families, and their spending in turn
creates more income for others. And
all of this income generates taxes for
government. There is also a world
of difference between borrowing to
support day-to-day consumption, and
the kind of transformative re-kitting of
the economy that would be unleashed
by a Green New Deal.
We are, after all, talking about
investment that will create jobs
and economic benefits in homes,
skills, infrastructure, and cities. A
programme like the Green New Deal
would, for example:
Create a new generation of decent,
well-paid jobs in the places that need
them the most. This would underpin
not just the future tax receipts to the
government but also the rejuvenation
of local places, many of which have
seen their economies suffer as jobs
7
and investment have focused on the
richest parts of the country
20
or been
offshored.
Spur world-leading innovation
and new business models, which
could make the UK the go-to place
for tomorrow’s zero carbon know-
how. Smart business leaders have for
many years demanded more ambitious
action on climate.
21
It could help
encourage UK companies to properly
invest
22
after years of the uncertainty
from Brexit and a lack of green policy
commitment from the government.
Save the nation millions of pounds
every year in energy bills by properly
insulating our inefficient homes,
23
which would also reduce the amount
of new heating infrastructure we need
to build.
Make our towns and cities green,
liveable and attractive places to
thrive and work, bringing economic
activity, footfall and community back to
the heart of the high street.
Shield communities from
climate impacts we will be unable
to avoid, such as more floods
or heatwaves. Flood defences,
for example, quickly pay for
themselves in avoided damages.
24
A major problem is that the Treasury’s
economic world view is too narrow to
cope with the far-reaching economic
potential from ambitious climate
action – its models don’t even properly
account for the huge harm that climate
breakdown would itself cause.
25
They
are designed to produce estimates of
‘costs’ which go-slow ministers can
use to hold back climate action, rather
than properly understand the long-
term benefits.
ACTION 2:
Use better economic models that
properly balance the up-front ‘costs’
of the Green New Deal against
the wealth of long-term economic
benets it would bring.
8
3. TAX THOSE MOST RESPONSIBLE
The great tragedy of the climate crisis is that seven and a half billion
people must pay the price – in the form of a degraded planet – so that
a couple of dozen polluting interests can continue to make record
profits.” –
Professor Michael Mann, October 2019
26
Image: Tinmouse Animation Studio
Taxation is a vital tool for making
sure the right people are paying
for climate action, that pollution is
discouraged, and that clean economic
activity is given the leg up that it
needs. The productive investment
under a Green New Deal would
result in new business models, more
and better paid jobs, and stronger
local economies. All of this will help
bring in healthy tax receipts in the
long-run. But right now, we need to
make sure we are taxing the right
things in the right way.
27
The mission of a Green New Deal is
to simultaneously decarbonise while
making the economy fairer. Yet the
UK has a fundamentally unfair tax
system, where income from wealth
is taxed far less than income from
work,
28
and wealthy families are
taxed too little overall. One estimate
suggests that between £90 billion and
£120 billion could be raised if income
from wealth was taxed the same as
income from work.
29
Nor do we tax pollution properly or
fairly. The wealthiest are far more
9
responsible for climate breakdown
than the poorest – for example in 2013,
70% of the total number of flights were
taken by only 15% of the population,
while 57% of the population took
no flights abroad at all.
30
NEF has
proposed a Frequent Flyer Levy
31
which
would see tax rates on plane tickets rise
sharply the more flights you take.
Did you know: 58% of the UK public support higher taxes on
environmentally-unfriendly products, and only 15% think they should
be lower.
32
We also give a huge effective subsidy to
the owners and shareholders of fossil
fuel companies like Shell and BP by not
properly taxing the carbon emissions
that their business model depends
on. Instead, we pay to mitigate the
negative effects of the industry – like
cleaning up after floods, or the treating
the effects of air pollution.
Tax reform under a Green New Deal
must ensure that:
Taxes must be fair. There should be
no ‘poll tax for the planet’ – any new
taxes must be weighted towards those
who pollute the most and have the
largest ability to pay.
People should see visible
improvements to their lives as
a result of the taxes they pay – for
example, much better public transport
in those places introducing congestion
charging,
33
or free home insulation for
the fuel poor.
Pollution taxes should be part
of phasing out fossil fuels in the
medium-term, not legitimising
them – this is essential given the pace
of carbon cuts needed. Money raised
should be used for urgent transitional
funding, not come to be relied upon by
the Treasury. If successful, revenue will
fall away anyway.
ACTION 3:
Implement fair carbon
taxation as part of a Green
New Deal.
10
4. REDIRECT DIRTY SUBSIDIES
“Removing fossil fuel subsidies, which typically benefit the rich more
than the poor, could gain up to 4% of global GDP.” –
International Monetary Fund, 201934
Image: Tinmouse Animation Studio
Paying for a Green New Deal is
not just about giving money to
the things that we do want to
see, but about removing support
from things that we don’t. Behind
the scenes the government still
gives many billions of pounds in
economic support to high carbon
activity. Estimates for the overall
level of subsidy vary depending
on definitions – the European
Commission, for example, reported
that the UK has the biggest fossil
fuel subsidies in Europe, at about
£10.5 billion per year.
35
There are many different types of
direct and indirect fossil fuel subsidy.
For example:
Tax rates for North Sea oil and gas
production have been cut so much over
recent years to encourage production
that some firms now receive more in
tax rebates from the Treasury than they
pay in corporation tax – over £1 billion
in rebates between 2015 and 2017.
37
Every year the government provides
far more loans or guarantees to UK
companies to support them winning
11
Did you know: In 2019 an investigation revealed that loan support from the
government which had supposedly been earmarked for clean energy instead
supported UK companies to invest in Argentina’s fracking industry.
36
overseas fossil fuel contracts than it
does for clean energy.
38
Aviation pays no fuel duty or VAT on
the kerosene it uses
39
- as compared
to the 58p per litre that drivers of
petroleum cars pay.
40
The Treasury argues that none of these
are subsidies – but trying to define your
way out of a problem only underlines
how deeply entrenched that problem
is. The intention is to prop up the
economics of fossil fuel businesses
despite the urgent need to act on
climate. The more reliant we are on
fossil fuels, the harder it is to transition
away from them rapidly and fairly.
These are dangerous subsidies at
a time when a huge stimulus is
needed in clean infrastructure as part
of a Green New Deal. Renewable
energy companies, local people and
councils wanting to install their
own community power, have spent
much of the last decade reeling as
the government has hacked away at
subsidies for clean energy, costing
jobs and hugely undermining the
attractiveness of the UK for zero
carbon investment.
41
Where possible,
subsidies currently given to fossil fuels
should be redirected towards the move
to net zero.
ACTION 4:
Commit to review and
reverse by 2025 all direct and
indirect subsidies for fossil fuels,
making sure each is phased out
in a way that enables a just
transition for those whose jobs
they currently support.
12
5. TRANSFORM THE BANK OF ENGLAND
“I don’t normally quote bankers, but James Gorman, who is the CEO of
Morgan Stanley, said the other day: ‘If we don’t have a planet, we’re not
going to have a very good financial system.’ Ultimately, that is true.” –
Mark Carney, Governor of the Bank of England, October 2019
Image: Tinmouse Animation Studio
An essential final part of funding
the Green New Deal is making sure
the Bank of England is pulling in the
same direction. The Bank’s governor,
Mark Carney, has been increasingly
firm on the risks of climate change
to economic stability (see above).
Climate breakdown has the potential
to wipe out many trillions of pounds
worth of assets – making the 2008
financial crash seem like a walk in
the park.
42
But the Bank is not yet fully walking
the walk on climate change. It has
promised to assess and publish the
risks that the climate transition poses
to its own operations and lending.
43
But it has an even more powerful role,
which is to make sure financial markets
take climate change very seriously and
act accordingly.
The net effect of the ‘quantitative
easing’ money-printing schemes the
Bank led after the crash was skewed
towards high carbon sectors, because
it followed the market and didn’t set
any green criteria.
44
And the Bank
is not attaching green conditions to
its existing programmes, such as the
near-0% interest loans it gives to
13
commercial banks.
45
These programmes
could be used much more strategically,
redesigned to channel funds towards
low-carbon investments and exclude
environmentally harmful ones. The
Bank should penalise dirty lending
across the economy by making it
harder for banks that give loans to
fossil fuels to get credit.
46
Other banks are needed too to direct
low-interest funding to the sectors
and places that most need it. A public
national investment bank should be
established which provides Green
New Deal projects with cheap finance,
which the Bank of England could help
to fund. It should be supported by a
network of local banks that intimately
understand the investment needs
and transition pathways of different
regions.
47
Most important is that the
Green New Deal becomes a central
mission for the Treasury, which should
then make sure that the Bank does
everything it can – including helping to
keep treasury borrowing costs low – to
open the taps of finance for the green
transition.
ACTION 5:
Give the Bank of England a
clear mandate to support the
Treasury in its central mission of
building a Green New Deal.
14
NO LONGER ‘IF’ BUT ‘WHEN’
A
ll important government
programmes cost money,
from educating our children
to funding the NHS. Responding
rapidly to climate breakdown is as
important as they come. The costs of
inaction in climate terms alone will
be staggering.
48
A Green New Deal is now essential
to respond to the climate breakdown
in a way that makes sure the people
and places that most need a better
economy actively benefit from cleaner
jobs and industry. Whether we can
build a Green New Deal is a question
of political choice, not economic
practicality. The question of feasibility
is no longer about if; but about how far,
how fast and when.
We bailed out the banks. Now it is time
to bail out the planet, which is – of
course – far too big to fail.
15
ENDNOTES
1 Fahnbulleh, M., Powell, D., Pendleton, A.,
Stirling, A., Van Lerven, F., & Balata, F. (2019).
A Green New Deal in the UK. London:
New Economics Foundation. Retrieved from
https://neweconomics.org/2019/04/a-green-
new-deal
2 Green New Deal Group (Simms, A., Pettifor,
A., Lucas, C., Secrett, C., Hines, H., Leggett, J.,
Elliott, L., Murphy, R., & Juniper. T.). (2008). A
Green New Deal: Joined-up policies to solve the
triple crunch of the credit crisis, climate change
and high oil prices. London: New Economics
Foundation, on behalf of the Green New Deal
Group. Retrieved from https://neweconomics.
org/2008/07/green-new-deal
3 Labour for a Green New Deal (n. d.).
Retrieved from https://www.labourgnd.uk
4 Committee on Climate Change [CCC].
(2019). Reducing UK emissions – progress
report to Parliament 2019. London: CCC
https://www.theccc.org.uk/publication/
reducing-uk-emissions-2019-progress-
report-to-parliament/
5 Office for Budget Responsibility [OBR].
(2019). March 2019 Economic and fiscal
outlook: Charts & Tables. Retrieved from
https://obr.uk/efo/economic-fiscal-outlook-
march-2019/
6 Stirling, A., Powell, D. & Van Lerven, F.
(2019). Changing the fiscal rules. London:
New Economics Foundation. Retrieved from
https://neweconomics.org/2019/07/changing-
the-fiscal-rules
7 Harvey, F. (2019, November 4). Charities say
next UK government must bring forward
climate targets. The Guardian. Retrieved
from https://www.theguardian.com/
environment/2019/nov/04/charities-next-uk-
government-bring-forward-climate-targets;
Murphy, R. (2019), Funding the UK Green
New Deal. Retrieved from https://www.
taxresearch.org.uk/Blog/2019/09/16/funding-
the-uk-green-new-deal/
8 Merrick, R. (6 June 2019). Philip Hammond
accused of trying to kill off landmark action
on global warming by claiming bill will top
£1 trillion. The Independent. Retrieved from
https://www.independent.co.uk/news/uk/
politics/climate-change-global-warming-
crisis-philip-hammond-uk-2050-a8947011.
html
9 Pettifor, A. (2019). On Philip Hammond
and £1 trillion. Retrieved from https://
progressiveeconomyforum.com/blog/on-
philip-hammond-and-1-trillion/
10 UK Parliament, Environmental Audit
Committee. (2018). MPs sound alarm as
green investment plummets to lowest for ten
years. Retrieved from https://www.parliament.
uk/business/committees/committees-a-z/
commons-select/environmental-audit-
committee/news-parliament-2017/green-
finance-report-published-17-19/
11 Wren-Lewis, S. (2019, February 18). The
case for funding a Green New Deal through
government debt. New Statesman. Retrieved
from https://www.newstatesman.com/
politics/economy/2019/02/case-funding-
green-new-deal-through-government-debt
12 New Economics Foundation. (2019).
Austerity hitting UK economy by almost
£100bn this year- more than £3,600
per household. Retrieved from https://
neweconomics.org/2019/02/austerity-hitting-
uk-economy-by-almost-100bn-this-year-
more-than-3-600-per-household
13 A long-run history of the official Bank
of England rate can be found in: Bank
of England. (2018). A millennium of
macroeconomic data. Retrieved from
https://www.bankofengland.co.uk/-/media/
boe/files/statistics/research-datasets/a-
millennium-of-macroeconomic-data-for-the-
uk.xlsx
14 For a forecast of the Bank Rate up to Q1
2024, see Office for Budget Responsibility.
(2019). March 2019 Economic and fiscal
outlook: Charts & Tables. Retrieved from
https://obr.uk/efo/economic-fiscal-outlook-
march-2019/
16
15 Bernanke, B.S. (2015). Why are interest
rates so low, part 3: The Global Savings
Glut. Brookings. Retrieved from
https://www.brookings.edu/blog/ben-
bernanke/2015/04/01/why-are-interest-rates-
so-low-part-3-the-global-savings-glut/
16 Financial Times. (2019). Austria sells ‘century
bond’ with yield of just 1.2%. Retrieved from
https://www.ft.com/content/abe7c3fa-9807-
11e9-8cfb-30c211dcd229
17 Stirling, A., Powell, D. & Van Lerven, F.
(2019). Changing the fiscal rules. London:
New Economics Foundation. Retrieved from
https://neweconomics.org/2019/07/changing-
the-fiscal-rules
18 For a more detailed discussion, see: Stirling,
A., Powell, D. & Van Lerven, F. (2019).
Changing the fiscal rules. London: New
Economics Foundation. Retrieved from
https://neweconomics.org/2019/07/changing-
the-fiscal-rules
19 McKie, R. (2016, November 6). Nicholas Stern:
cost of global warming ‘is worse than I feared’’.
The Guardian. Retrieved from https://www.
theguardian.com/environment/2016/nov/06/
nicholas-stern-climate-change-review-10-
years-on-interview-decisive-years-humanity
20 Powell, D., Balata, F., & van Lerven, F.
(forthcoming). Trust in transition. London:
New Economics Foundation.
21 See for example, the Prince of Wales’s
Corporate Leaders Group on Climate Change:
Aiming for Zero: Business leadership for a net
zero economy. (n. d.). Retrieved from https://
www.corporateleadersgroup.com/reports-
evidence-and-insights/collections/net-zero
22 Stirling, A. & Arnold., S. (2019). Tackling the
Productivity Puzzle: A higher Minimum Wage
and a 4-day Week. Retrieved from. https://
neweconomics.org/2019/04/tackling-the-
productivity-puzzle
23 Committee on Climate Change [CCC].
(2019, February 21). UK homes unfit for the
challenges of climate change. Retrieved from
https://www.theccc.org.uk/2019/02/21/uk-
homes-unfit-for-the-challenges-of-climate-
change-ccc-says/
24 University of Bristol. (2017). Benefits of
dikes outweigh costs – effective measures
for reducing future flooding. Retrieved from
https://www.bristol.ac.uk/news/2017/july/
benefits-of-dikes.html
25 Ackerman, F. & Daniel, J. (2014).
Misunderstanding climate policy. The role
of economic modelling. Report for Friends
of the Earth (England, Wales & Northern
Ireland) and WWF-UK. Retrieved from
https://friendsoftheearth.uk/sites/default/
files/downloads/synapse-misunderstanding-
climate-policy-low-res-46332.pdf
26 Taylor, M. & Watts, J. (2019, October 9).
Revealed: the 20 firms behind a third of all
carbon emissions. The Guardian. Retrieved
from https://www.theguardian.com/
environment/2019/oct/09/revealed-20-firms-
third-carbon-emissions
27 Powell, D. (2019). Why ‘Net Zero Emissions
by 2050’ needs a Green New Deal. Retrieved
from https://neweconomics.org/2019/05/
why-net-zero-emissions-by-2050-needs-a-
green-new-deal
28 Nanda, S. & Parkes, H. (2019). Just tax.
Reforming the taxation of income from
wealth and work’. London: IPPR. Retrieved
from https://www.ippr.org/research/
publications/just-tax
29 Nanda, S. & Parkes, H. (2019). Just tax.
Reforming the taxation of income from
wealth and work’. London: IPPR. Retrieved
from https://www.ippr.org/research/
publications/just-tax
30 Devlin, S. & Bernick, S. (2015). Managing
aviation passenger demand with a
frequent flyer levy. London: New
Economics Foundation. Retrieved from
https://neweconomics.org/uploads/
files/58e9fad2705500ed8d_hzm6yx1zf.pdf
31 Ibid.
32 Ipsos MORI & Deloitte. (2019).
The State of the State infographic.
Retrieved from https://infogram.
com/1p907qvvr0ry7kh71z6lx323eqf31g3er6w
within https://www2.deloitte.com/uk/en/
pages/public-sector/articles/the-citizen-view.
html
33 Badstuber, N. (2018, March 12). London
congestion charge has been a huge success.
It’s time to change it. City Metric. Retrieved
fromhttps://www.citymetric.com/transport/
london-congestion-charge-has-been-huge-
success-it-s-time-change-it-3751
34 International Monetary Fund. (2019,
August 14). Fuel for thought: ditch the
subsidies. Retrieved from https://blogs.imf.
17
org/2019/08/14/fuel-for-thought-ditch-the-
subsidies/
35 Carrington, D. (2019, January 23). UK has
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WRITTEN BY:
David Powell, Lukasz Krebel,
Frank van Lerven
PUBLISHED:
November 2019
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