Sub-national governments are now seen as having an important role to play in climate protection. Initial research in this area sought to identify their initiatives in climate change mitigation and theorize their role in relation to national and international climate protection policies. Because of the wide variations of constitutional arrangements that restrict and enable these bodies, it has been difficult to compare their efforts, particularly across national boundaries. However Bulkeley and Kern offer a conceptual framework of four 'modes of governing' that are common to local authorities, enabling their efforts to be compared more meaningfully. This schema is used in an empirical study of Freiburg´s climate protection program. The schema facilitates identification of the full range of Freiburg´s climate initiatives, but is not designed to account for the inappropriateness and counter-productiveness of some of the city´s key climate policies. It is therefore extended in two ways. First, using Hajer´s 'argumentative discourse' approach, the dominant discourses that drive Freiburg´s climate policies are examined, together with how these are held in place cognitively and institutionally. Secondly, a rationale is offered for examining the 'descriptive elements' of environmental discourse in terms of their correspondence to the way the world is. This approach enables a close critique of these discourses, which provides an explanation as to why Freiburg´s climate protection strategy has led to disappointing results. This model is offered for research on other sub-national bodies' climate programmes, and as a means of helping policymakers adopt a more self-critical approach.