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Over the past several years, subnational actors have taken larger and more prominent roles in global conversations of climate governance. These discussions have been embedded as side events at the COP, forefronted at meetings like the United Nations Civil Society Conference in 2019, and even operated as standalone conferences led by city mayors. This paper uses one metric of climate governance documentation—Nationally Determined Contributions (NDCs)—to measure the integration of cities and other subnational actors into the fabric of national climate mitigation and adaptation strategies. I compare the first and second draft NDCs (n=380) using both topic modeling and thematic patterning (Fuiji, 2017) to understand how nations have (or have not) moved to incorporate subnational actors into their national-level strategies. I conclude with an analysis on how this inclusion (or lack of inclusion) of subnational actors poses implications for efficacy in NDC planning and action.