Delta Air Lines Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Delta Air Lines Inc. has demonstrated a comprehensive level of transparency in disclosing its climate lobbying activities. The company has explicitly named numerous specific climate policies and legislation it has engaged with, such as the SAF-specific provisions under the Inflation Reduction Act, the Sustainable Skies Act, the Aviation Emissions Reduction Opportunity (AERO) Act, and state-level SAF tax incentives in Minnesota, Washington, and Illinois. Additionally, Delta has disclosed its advocacy for international policies, including ICAO's Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) and the EU's ReFuelEU initiative. These disclosures provide clear and identifiable details about the policies and jurisdictions targeted. Delta has also provided detailed information about its lobbying mechanisms and targets. The company describes both direct and indirect lobbying efforts, such as authoring letters of support, delivering testimony, and filing comments with federal agencies like the FAA and EPA. It has also engaged with state-level policymakers and international bodies, including ICAO and the EU. Specific mechanisms include coalition-building efforts, such as its founding membership in Americans for Clean Aviation Fuels, and partnerships with organizations like the Minnesota SAF Hub and Greater MSP. These disclosures identify both the mechanisms (advocacy, coalition-building, and consultations) and the targets (federal, state, and international policymakers), showcasing transparency in its engagement methods. Furthermore, Delta has been explicit about the specific outcomes it seeks through its lobbying efforts. The company aims to scale sustainable aviation fuel (SAF) production and adoption, with measurable goals such as replacing 10% of its jet fuel with SAF by 2030 and achieving net-zero carbon emissions by 2050. Delta has advocated for SAF tax credits, reforms to the Renewable Fuels Standard (RFS), and incentives for next-generation technologies like power-to-liquids. It has also supported state-level SAF incentive legislation and international SAF mandates, such as the EU's ReFuelEU initiative. These disclosures clearly articulate the desired policy changes and measurable targets, demonstrating a high level of transparency in its lobbying objectives.	4

Lobbying Governance

Overall Assessment	Comment	Score
Comprehensive	Delta Air Lines demonstrates a comprehensive governance process for climate lobbying alignment, as evidenced by its detailed disclosures, oversight mechanisms, and proactive strategies. The company has published annual lobbying reports, such as the "2022 Climate Lobbying Report," which provide transparency into its direct and indirect lobbying activities and assess alignment with its net-zero climate goals and policy principles. Delta explicitly mentions aligning its lobbying efforts, including those conducted through trade associations, with its climate goals, stating, "We strive for our coordinated lobbying activities and those of our membership-based trade associations to jointly support our climate goals." The company evaluates areas of actual or perceived misalignment and takes independent actions when necessary, showcasing a proactive approach to managing indirect lobbying risks. Delta has established a robust governance structure, with oversight provided by the Corporate Governance Committee of the Board, which receives formal reports on political activities, including climate lobbying. Additionally, the Delta Leadership Committee, which includes key executives such as the Chief Sustainability Officer, is regularly briefed on ESG matters, including climate lobbying strategies. Delta has identified responsible parties for overseeing climate lobbying alignment, such as the Vice President, Government Affairs – Sustainability, who collaborates with the Chief Sustainability Officer and coordinates advocacy strategies across various levels of governance. The company also leverages a cross-functional team of experts and consults with outside specialists to develop and advance climate change policy positions. Furthermore, Delta actively monitors and engages with trade associations, periodically assessing their alignment with its climate goals, and has disclosed its advocacy for SAF-specific tax credits and foundational policy support for low-carbon fuel standards. This level of transparency, combined with detailed disclosures and robust oversight mechanisms, indicates a strong governance process that ensures alignment with its climate goals and principles.	4