Appendix

2023 Climate Lobbying

The following provides an overview of the domestic and international climate lobbying activities we have engaged in directly on behalf of Delta Air Lines and indirectly via membership-based trade associations from 1er janvier 2023, through 31 décembre 2023. It also includes climate-related lobbying activities conducted by or on behalf of our wholly owned subsidiary Monroe Energy, LLC (Monroe) over that same time period. Consistent with our commitment to transparent climate policy leadership, this section of the report also assesses these climate lobbying activities for alignment with our net-zero climate goals and policy principles.

For more information on oversight and coordination of climate lobbying priorities and activities within Delta, see the Climate Lobbying summary.

CLIMATE LOBBYING PRINCIPLES

Our climate change policy principles provide a foundation for our advocacy and ensure consistency in our position development process. As a basis for navigating policies across the global markets, we embrace internationally and nationally harmonized policies to prevent the inconsistent application of policies that may result in competitive market distortions or send conflicting market signals. U.S. law, for example, recognizes the need for national consistency in aircraft regulation and preempts state and local regulation.

Delta believes climate policy for the aviation industry should also be:

Sector-specific but augmented by complementary policies to support our broader sustainability strategy (e.g., electrification of ground support equipment and operations);
Preventative of revenue diversion for non-aviation climate mitigation purposes, ensuring policymakers reinvest any revenue generated into this hard-to-abate sector and the diverse workforce it supports;
Grounded in science to ensure greenhouse gas (GHG) emissions reductions are maximized and realized in a manner designed to minimize increased costs for travelers;
Performance-based, feedstock- and technology- neutral, recognizing the innovations needed to decarbonize our sector are not yet commercially available at scale;
Supportive of the long-term capital investment necessary to sustain multi-decade aviation infrastructure and equipment commitments;
Rooted in the need for operational safety, technological feasibility and economic reasonableness;
Designed to drive efficiency in fleet procurement, fuel burn and air traffic operations; and
Designed to incentivize rather than mandate a net-zero trajectory at the lowest cost (e.g., tax incentives, grants, research and development investment, voluntary opt-in), as there is no scalable market where sustainable aviation fuel can compete on a level playing field with the on-road fuels market.

Direct Lobbying

FEDERAL

In 2023, Delta’s federal climate advocacy largely centered on initiatives and coalition building efforts central to scaling sustainable aviation fuel (SAF) and accelerating other clean energy solutions in the U.S. We positively influenced policy through several key efforts, highlighted below:

We continued our advocacy in support of increased funding and resources for the multiple agencies implementing the SAF Grand Challenge.
We advocated directly and indirectly for the timely implementation of the SAF credits contained in the Inflation Reduction Act (IRA) and sought clarity regarding adoption of the U.S. Department of Energy’s Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation (GREET) methodology for lifecycle carbon accounting purposes – key to utilizing domestic agricultural feedstocks for SAF production.
We coordinated with our State and Local Government Affairs team and supply chain partners to author letters of support to various federal grant applicants for the Federal Aviation Administration’s (FAA) newly implemented Fueling’s Aviation’s Sustainable Transition’s (FAST) SAF and Tech programs.
We fostered partnerships across the SAF value chain – from farm to plane – to launch Americans for Clean Aviation Fuelsopens in a new window, the first national coalition established to educate the public on the economic and jobs benefits associated with a strong domestic SAF market.
We supported key projects and discussions related to the Bipartisan Infrastructure Law’s Regional Clean Hydrogen Hub Program to deploy clean hydrogen as both an aviation fuel and an essential building block for scaling Power-to-Liquids or e-fuels, which are central to decarbonizing our sector.
We engaged in policy advocacy related to electrification of our ground support equipment (GSE) and airport operations.
We worked in a bicameral and bipartisan fashion to constructively engage on policies designed to incorporate SAF into the Farm Bill, such as the Farm to Fly Act.

ÉTAT

Delta believes that a dedicated state advocacy strategy is needed to scale the SAF market by augmenting the critical federal incentives established under the IRA and enabling geographic diversification. Our 2023 advocacy directly contributed to enactment of new SAF tax incentives in two of our hub states, Minnesota and Washington. Members of our team delivered testimony in support of these initiatives and participated in numerous stakeholder meetings with a broad cross section of interests – including but not limited to environmental NGOs, agri-business, producers and refiners, and other value chain players – to successfully advance these bills.

Additional examples of Delta’s state advocacy include:

We led advocacy efforts in the Delta hub states of New York, Michigan, and Massachusetts where policymakers drafted legislation to establish new SAF tax incentives and/or low carbon/clean fuel standards with SAF included as an opt-in fuel that generates credits. We fostered coalitions to advance these clean energy policies as well as participated in state and regional workshops in partnership with Federal and State agencies.
We were engaged in our hub state of Washington in the successful passage of the State’s SAF Tax Credit, making it the first state in the country to have enacted both a SAF tax credit and a low-carbon fuel standard (LCFS) into law.
In our home state of Georgia, we fostered constructive engagement with value chain partners and state officials to better understand the potential for in-state SAF production, inclusive of an international site visit to a second-generation bio-ethanol plant that will use woody waste as feedstock for fuel. Georgia has the potential to utilize woody waste both for in-state production as well as serve as an export market.

In order to capitalize on the incentive in Minnesota, Delta was one of the anchor partners in the creation of the Minnesota SAF Hubopens in a new window, a first-of-its-kind value chain coalition to scale SAF investment to meet fuel demand at our MSP hub. We believe this hub driven investment model is key to enabling commercial aviation’s net-zero goals and is a key component of our state-driven SAF hub strategy. For more information, see Collaborating to Form the Minnesota SAF Hub.

INTERNATIONAUX

2023 marked the third International Civil Aviation Organization (ICAO) Conference on Aviation and Alternative Fuels (CAAF/3), which brought together member country delegates, civil society and business interests. CAAF/3 resulted in the adoption of a global framework and aspirational goal to reduce carbon dioxide (CO ₂) emissions in international aviation by 5% by 2030 through the use of SAF, low-carbon aviation fuel and other clean energy solutions. This intermediate goal provides a flexible path forward for attainment of ICAO’s global aspirational net-zero emissions by 2050 goal while enabling a strong basis for supportive policy adoption. It also reaffirmed ICAO as the global leader for addressing international aviation emissions ahead of the UN Climate Change Conference (COP28). Delta’s Government Affairs and Sustainability teams participated in pre-conference convenings at ICAO with Observer status as Delegates of the International Air Transport Association (IATA) ahead of CAAF/3.

Globally, we are constructively engaged directly and in partnership with our trade associations to scale a robust global SAF market that will enable our net-zero goals. In 2023, Delta lobbied for policies to scale SAF at the international level, including through the adoption of incentives, with engagement in the European Union (EU), United Kingdom (UK), Latin America, and East Asia. As SAF becomes a rising priority for global markets, our advocacy encourages a government-wide strategy for scaling SAF production. In Latin America and Japan, for example, we have encouraged policymakers to use the U.S. government’s SAF Grand Challenge Roadmap as a foundation for their own policy engagement and have expressed the importance of including incentives over or alongside any proposed SAF mandates in order to mitigate higher costs of SAF. In Europe and the UK, we advocated for the adoption of incentives for SAF development and deployment as they respectively worked to finalize ReFuelEU and initiate a consultation on the proposed UK SAF mandate. We also recognize that not all countries are able to offer incentives and have been supportive of U.S.- and ICAO-led efforts to engage with international financial institutions as well as ongoing efforts to encourage blended finance models for investment.

Beyond our SAF strategy, we engaged in several climate-related and climate-adjacent advocacy efforts worth highlighting. We continued to advocate for the exclusion of extra-European flights under the EU Emissions Trading Scheme to avoid duplicative regulatory structures for international aviation emissions given the industry’s commitment to and current voluntary participation in ICAO’s Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA). In 2023, we advocated in partnership with our Federal team to give the U.S. government authority to implement CORSIA via the pending FAA Reauthorization process in Congress.

Monroe

Delta owns Monroe as part of our strategy to mitigate the cost and supply risks associated with jet fuel. However, Monroe has experienced substantial economic setbacks under the federal Renewable Fuels Standard (RFS) due to a lack of transparency in the Renewable Identification Numbers (RINs) market that has resulted in prohibitive compliance costs. Therefore, we support Monroe’s efforts to seek RFS policy reform measures to reduce the financial impact on the operation, including via regulatory and legislative means. Delta and Monroe filed comments with the U.S. Environmental Protection Agency (EPA) on the RFS in 2023, raising these concerns and advocated for the bicameral and bipartisan introduction of the Safeguarding Domestic Energy Production and Independence Act of 2023opens in a new window in Congress. Through the comment process we clarified how RINs volatility is deterring sustained investment in SAF and, ironically, directing financial resources away from production and consumption of SAF and toward unobligated parties with no interest in advancing the biofuels market. The legislation we supported would therefore provide certainty and predictability by making renewable fuel credits available for refiners at a lower, fixed price while also investing in innovations in biofuels and environmental conservation. This bill is also essential to providing long-term investment certainty in key biofuels markets, such as SAF, by helping to eliminate the volatility in the RINs market.

In 2023, we also coordinated with Monroe to host policymakers from the U.S. Department of Transportation and the FAA at the Trainer refinery. This offered an opportunity for Monroe to serve as a resource to policymakers as they navigate the clean energy transition, better understanding what it takes for traditional refineries to produce biofuels.

Our advocacy is designed to provide Monroe with greater financial certainty and economic flexibility, and to invest in the business, including investment in clean energy and other sustainability measures, aligned with our climate policy principles and goals.

Trade Associations

In addition to the direct lobbying activities described above, we are members of sector-specific and multi-sector industry trade associations that engage in lobbying on a variety of matters, including climate change. Included in this final section is a table and climate policy alignment analysis of those trade associations. We have included all the trade association memberships disclosed in our separately-issued annual political contributions and activity report that, to our knowledge, engage in lobbying activities on climate matters. Additionally, we have included Monroe’s primary trade association membership in the table.

We analyzed alignment based on (1) whether the trade association has a climate position that supports the achievement of net-zero emissions by 2050 and/or temperature goals identified by the Intergovernmental Panel on Climate Change (IPCC) as the scientific underpinning of the Paris Agreement and (2) whether specific trade association climate lobbying activities were consistent with our climate goals. The aviation-specific associations in which we are members have expressed strong support for achieving GHG emissions reductions in line with science, with both A4A and IATA having ambitious net-zero goals.

Our participation in diverse and multi-sector industry associations, given our ambitious climate goals, helps positively influence the development and execution of climate policy positions and advocacy efforts. Our participation in industry-specific associations facilitates the identification, assessment and mitigation of risks while providing us with a platform for constructive engagement on a variety of policy issues related to climate and non-climate matters. With our climate policy principles, we are sharing our expectations for climate advocacy. While we may not always agree with the views or tactics of these trade associations, we believe they provide a valuable opportunity for us to better understand the views and perspectives of others as we work to inform our advocacy strategies. We are committed to collaborative engagement and problem solving; where we disagree with one or more of these trade associations on a matter tied to our strategy, we have in the past taken – and may in the future take – independent actions to mitigate risks an association’s actions may present to our strategy.

Airlines for America (A4A)

ABOUT

A4A is the primary trade association advocating for the leading U.S. airlines, both passenger and cargo carriers, on federal, state, local and international policies. A4A works collaboratively with industry stakeholders, federal agencies, the Administration, Congress, labor and other groups to improve aviation for the traveling and shipping public.

Delta Involvement:
Our Chief Executive Officer (CEO) sits on the Board of Directors. Delta representatives are active on a variety of working groups and committees, including the Sustainability Council, the SAF Committee and the Environmental Regulatory Committee.

CLIMATE CHANGE POSITION

A4A is committed to advancing policy solutions to address climate change. A4A has committed to work with government leaders and other stakeholders on the following goals, which it continues to affirm:

Achieving net-zero carbon emissions by 2050.
Partnering with key stakeholders to advance production and deployment of 3 billion gallons of cost-competitive SAF by 2030, including:

Implementation and extension of the IRA SAF tax credits with recognition of GREET as an appropriate and equivalent lifecycle carbon accounting methodology of qualifying SAF for the credits;
Advocating for State SAF tax credits and SAF opt-in provisions in state Clean Fuel Standard programs to promote regional diversification of SAF; and
Advocating for aviation technology R&D and SAF production infrastructure support in legislation for FAA Reauthorization and U.S. Department of Agriculture Farm Bill.

Reaffirming the global aviation industry goals under ICAO, including:
- CORSIA, including full implementation by the FAA;
- Aircraft CO ₂ certification standards applied to new aircraft and support for greater stringency;
- Adoption of a long-term aspirational goal, subject to critical aviation infrastructure and technology advances achieved by the industry and government; and
- Adoption of an aspirational goal for carbon emissions reductions from SAF, LCAF and cleaner energies for aviation.
Advancing transparent and effective reporting requirements for aircraft operators and their customers of their GHG emissions.

ALIGNMENT

Delta strongly supports A4A’s climate change position and goals. Our federal, state, and international climate policy advocacy is aligned. Additional illustrative examples of interest can be found below.

RFS Comment Process: A4A filed comments with the EPA on the RFS and Delta offered support as well as guidance. Notably, the comments highlighted the important role of the RFS in driving SAF investment as an opt-in credit generator under the program while recommending certain enhancements.
Amsterdam Schiphol Airport Capacity Reduction Proposal: While not originally associated with climate mitigation, policymakers began to consider this as a potential benefit. Delta, A4A and IATA objected to the Dutch Government's decision to advance flight restrictions without following the Balanced Approach.
California Air Resources Board’s LCFS Reform: In our hub state of California, we ended the year navigating the state’s efforts to regulate jet fuel as an obligated fuel under the existing LCFS with A4A. In coordination with A4A, we have cautioned that the proposal would not lead to increased SAF production but rather would result in increased jet fuel costs. Furthermore, the state does not have authority to regulate jet fuel, which under federal law is preempted from regulation by any authority other than the FAA.
Climate Disclosure: This year, we closely monitored climate disclosure bills enacted in California related to reporting GHG emissions and climate-related financial risk. While we did not lobby on these bills, A4A and other business groups expressed concerns regarding the emergence of a patchwork of duplicative state disclosure requirements when the industry is already reporting our emissions and awaiting the pending federal disclosure requirements from the Securities and Exchange Commission (SEC).

Business Roundtable (BRT)

ABOUT

BRT is an association of CEOs from America’s leading companies working to promote a thriving U.S. economy and expanded opportunity for all Americans through public policy. For more than 45 years, the membership of BRT has applied CEO expertise to the major issues facing the nation.

Delta Involvement:
Delta representatives are active on the Corporate Governance and Energy & Environment Committees.

CLIMATE CHANGE POSITION

The BRT believes that to avoid the worst impacts of climate change, the world must work together to limit global temperature rise this century to well below 2°C above preindustrial levels, consistent with the Paris Agreement. The BRT also acknowledges that the IPCC’s 2018 report limiting warming to no more than 1.5°C compared to preindustrial levels will be necessary to avoid some of the most severe risks associated with climate change. The BRT supports a goal of reducing net U.S. GHG emissions by at least 80% from 2005 levels by 2050.

The BRT has developed a suite of principles by which U.S. climate policy should be guided, including but not limited to the following:

Align policy goals and GHG emissions reduction targets with science;
Increase global engagement, cooperation and accountability;
Provide adequate transition time and long-term regulatory certainty; and
Ensure that U.S. policies account for international emissions reduction programs.

The BRT also actively engages in the COP process, facilitating business delegations at COP28 this year.

ALIGNMENT

We are appreciative of the BRT’s recognition that while a market-based climate strategy should apply broadly across the economy, no one policy or approach can fully address climate change across such a diverse economy and such diverse sources of GHG emissions. The BRT’s formal policy also notes that, in unique circumstances, non-duplicative, tailored policies may be more effective or administratively feasible.

While the BRT’s climate change position indicates alignment with the stated temperature goals identified by the IPCC, its current 2050 ambition is not a net-zero goal. The BRT’s climate advocacy is not misaligned with our goals.

In 2023, the BRT engaged on advocacy related to clean energy deployment of importance to Delta:

Federal Permitting Reform: BRT performed advocacy related to federal permitting reforms to accelerate America’s clean energy infrastructure and capacity. Building out clean energy in the United States is central to scaling clean hydrogen – an integral building block for PtLs, which is key to our net-zero goal by 2050.

International Air Transport Association (IATA)

ABOUT

IATA is the trade association for the world’s airlines with a mission to represent, lead and serve the airline industry. Its 290 members comprise 83% of total air traffic and it works with over 400 strategic partners to deliver solutions that shape aviation.

Delta Involvement:
Delta currently participates in the Fuels Task Group committee within IATA. Moving forward, we hope to increase our active and direct participation in the Sustainability & Environment Advisory Council.

CLIMATE CHANGE POSITION

IATA recognizes the need to address the global challenge of climate change and has adopted an ambitious goal of net-zero carbon emissions by 2050, in alignment with the Paris Agreement goal for global warming not to exceed 1.5°C.

IATA also reaffirms its support of global aviation industry goals under ICAO by:

Reaffirming CORSIA as an effective measure to stabilize net emissions from international aviation in the short- to medium-term;
Calling for governments to support CORSIA, coordinate policy measures and avoid a patchwork of regional, national, or local measures;
Calling for governments to deliver more incentive policies to scale up SAF supply;
Urging parties of Conference of United Nations Framework Convention on Climate Change to authorize the CORSIA eligible emissions units for airlines’ compliance under CORSIA; and
Encouraging global SAF incentives and creating a global SAF accounting framework with a robust chain of custody.

ALIGNMENT

Delta strongly supports IATA’s climate change position and goals. We also support IATA’s active involvement in ICAO to promote harmonized global standards and international agreement on aviation emissions as well as complementary policies, such as SAF incentives. IATA’s climate advocacy on the international front is fully aligned with our climate goals and objectives. Some illustrative examples can be found below.

ICAO CAAF/3: IATA supported the global framework to promote SAF production in all geographies around the world. The outcome highlights the urgency and importance for states to support national-level policies to drive SAF market development. Delta attended pre-CAAF/3 meetings as a delegate under IATA.
SAF Accounting: Delta is supportive of IATA’s work to advance a global SAF accounting framework, such as book and claim, with a robust chain of custody. We believe this is key to advancing global SAF usage and development.
RefuelEU: Delta, IATA and A4A advocated for the EU to adopt incentives for SAF development and deployment, noting that the RefuelEU SAF mandate contained in the EU’s Fit for 55 package mandates SAF supply without appropriate incentives to enable cost-effective investment to drive market development.

American Fuel and Petrochemical Manufacturers (AFPM)

ABOUT

AFPM is the leading trade association representing the fuel and petrochemical manufacturing and refining industry. Its mission includes educating policymakers, the media and the public on the value its members and their products provide the nation and the world, as well as providing strategic business and technical information to its members, among other items.

Delta/Monroe Involvement:
Monroe is a dues-paying member of AFPM. It has a representative on AFPM’s Board of Directors (as do all other members) and on AFPM’s Executive Committee. Monroe also has representatives on issue-specific committees, including environmental, fuels and government relations.

Advocacy is only one element of Monroe’s engagement with AFPM. It utilizes its membership to stay informed on and contribute to best practices in the industry, covering a variety of issues beyond climate change, such as safety, environmental stewardship and operational performance. Therefore, we believe the overall benefits of engagement outweigh identified concerns.

CLIMATE CHANGE POSITION

AFPM is committed to engaging in the discussion and development of sound climate change policies. The association acknowledges climate change is real and is committed to the development of sound policies that enable its members to supply the fuel and petrochemicals that growing global populations and economies need to thrive and to do so in an environmentally sustainable way. Policies addressing climate change must be:

Balanced and measured to improve quality of life, ensuring the long-term economic, energy and environmental needs of humanity are met;
Protective of U.S. competitiveness, including preventing the shifting of production, jobs and emissions from the United States to other countries;
Harmonized, preemptive and economy-wide;
Simple and transparent; and
Achievable and flexible to adjust, as necessary.

ALIGNMENT

While AFPM’s climate policy is not aligned with our net-zero ambition, we believe in the value of influencing from the inside, and Monroe has been able to help champion constructive viewpoints and perspectives on renewable fuels such as SAF through its involvement and unique vantage point.

Monroe works alongside AFPM to advance policies that mitigate the economic hardship of RFS compliance as well as a diverse array of matters impacting the overall industry.

An area of particular visibility in 2023 where AFPM was active – which without additional context could be viewed as misaligned with Delta’s net-zero objectives – includes its advocacy around zero emission vehicle (ZEV) mandates at the state and federal levels.

ZEV Mandates: AFPM has filed comments and supported legislation in opposition to policy efforts to accelerate investment in ZEVs. Both AFPM and Monroe supported the Preserving Choice in Vehicle Purchasing Act, for example, which would prevent the state of California from limiting the sale or use of new motor vehicles with internal combustion engines. AFPM and Monroe view this initiative as ensuring a future for liquid fuels, inclusive of renewable biofuels, in the on-road vehicle market while maintaining consumer choice in vehicle purchasing decisions.

Conclusion

Delta appreciates that many factors surrounding our ambitious climate goals are outside our control and will require significant capital investment, government policies and incentives, dedicated R&D and the transformation of some of the world’s largest industries. As highlighted in this appendix, one critical component of the advancement and ultimate achievement of our climate goals is effective public policy engagement, including direct and indirect lobbying activities. Delta remains committed to being a voice of leadership on climate policy issues that impact our business and stakeholders.