Southwest Airlines Co

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Southwest Airlines provides a high level of transparency around its climate-policy lobbying. It lists multiple, clearly identifiable measures it has tried to influence, including federal initiatives such as the SAF Grand Challenge, the Sustainable Aviation Fuel Blender’s Tax Credit and Clean Fuel Production Credit contained in the Inflation Reduction Act, funding for the FAA’s CLEEN and ASCENT programmes, and state bills such as Colorado’s HB23-1272, Illinois’ SB 2951/SB 1963 and California’s “AB 1322” to stimulate SAF production. The company also describes a variety of direct and indirect engagement channels and names the targets of those efforts: it “signed a letter to the Senate Committee on Energy and Natural Resources”, “worked alongside a coalition of aviation industry stakeholders” to promote AB 1322 before the “California Air Resources Board (CARB)”, and participates in the SAF Blender’s Tax Credit Coalition as well as trade bodies like Airlines for America and IATA, while its Government Affairs staff in Washington, D.C. conduct direct outreach to policymakers at federal, state, local and international level. Finally, Southwest is explicit about the outcomes it seeks: inclusion of long-term SAF tax incentives in the Inflation Reduction Act, state-level tax credits that “incentivize sustainable aviation fuel (SAF) production and utilization”, adoption of the GREET model for life-cycle accounting, and continued federal funding for technology programmes that will cut aviation emissions. By naming the policies, detailing the avenues of engagement and setting out the precise legislative changes it wants to see, the company demonstrates comprehensive disclosure of its climate lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Southwest Airlines discloses a public position to conduct its engagement activities in line with the goals of the Paris Agreement, responding “Yes” to having such a commitment. It explains that its “Governmental Affairs Team works to stay on top of proposed statutory and regulatory changes to educate a wide range of policymakers and Stakeholder groups directly” and that it “engage[s] directly and indirectly with policymakers and other Stakeholders at the federal, state, local, and international levels to advance decarbonization in alignment with the goals ... CORSIA and the Paris Agreement.” The company shows alignment across both direct efforts—presenting its views to federal and state officials—and indirect channels, notably through Airlines for America, where Southwest has served as “Vice Chair of A4A’s Environmental Sustainability Council” and collaborated on objectives such as “net zero carbon emissions by 2050.” However, Southwest does not disclose a structured review or monitoring procedure for its lobbying alignment nor identify a specific individual or body responsible for overseeing that alignment, noting only that “when such misalignment occurs, Southwest will ... use our influence to advocate for change as needed.” While these disclosures demonstrate active measures to align lobbying with climate goals, the absence of a named oversight function and formalized review process limits the transparency of its governance framework.	2