We have evaluated the lobbying activities of the trade associations above for alignment with our climate goals and policy principles.
We analyzed alignment based on (i) 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 (ii) 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.
The advocacy efforts of A4A and IATA are geared toward advancing government policies and regulations that will support achieving their climate goals and opposing potential measures that would be harmful or counterproductive to reaching these ambitions. Thus, they align with our climate goals and principles. In some cases, approaches may differ yet continue to be aligned on goals and outcomes. The following are some illustrative examples which we believe are consistent with our climate goals.
  1. As discussed under our direct international advocacy, CORSIA is designed to stabilize international aviation emissions and is a multilateral, global approach, which is preferred to a patchwork of regional and jurisdictional approaches that may result in duplicative measures covering the same emissions. A4A and IATA advocated for the continued use of 2019 as a baseline for calculating offsetting obligations beyond the pilot phase of CORSIA to reduce dependence on out-of-sector offsets and further incentivize and facilitate the use of SAF to help decarbonize aviation operations.
  1. A4A and IATA have generally opposed SAF mandates that do not also include incentives that are well-designed to ensure a sufficient supply of SAF at competitive market prices and avoid competitive distortions. This opposition reflects the aviation industry’s concern that mandates alone, without incentives designed to encourage supply and reasonable pricing, will not support the industry’s ambitious decarbonization goals. Delta, A4A and IATA have therefore advocated for the EU to adopt incentives in addition to mandates to develop the SAF market and close the gap between traditional jet fuel and SAF. Collectively, we have also encouraged the adoption of a book-and-claim SAF accounting system as a means of improving the functionality of a mandated policy for a nascent market by providing greater supply flexibility.
  1. Additionally, IATA has opposed the EU’s power to liquids (PtL) sub-mandate, which is at an even more nascent stage than SAF. Data demonstrate that prematurely requiring PtL could unintentionally increase emissions in the EU where there is an insufficient existing renewable energy supply to support green hydrogen in the early years of the program, undermining the objectives of the mandate. This position aligns with our principle that climate policy be grounded in science.
  1. A4A and IATA have opposed environmental taxes and fees where the revenue collected goes to national treasuries rather than aviation climate mitigation efforts, resulting in increased costs for travelers and the industry without corresponding benefits for the climate. Increased costs to the industry also reduce the ability of airlines to invest in new and more fuel-efficient aircraft and technologies.
  1. A4A and IATA advocate for globally aligned and coordinated measures to ensure that applicable measures are most effective and efficient and that airlines do not pay multiple times for the same ton of emissions. Without global harmonization, a patchwork of regional or national measures would only serve to increase the administrative burden and cost for airlines that often operate across multiple jurisdictions and distract from the sustained investments required to achieve long-term decarbonization.
  • Relatedly, at the state level through A4A, we opposed efforts by California and Hawaii to advance state-specific regulatory and legislative actions on federal preemption grounds. Notably, we opposed the regulation of aviation GHG emissions by the California Air Resources Board as well as the imposition of a state carbon tax on jet fuel (HB1639 and SB2007). Both positions are consistent with our principle of supporting harmonized national and international approaches to reducing aircraft emissions.
  1. IATA has opposed per-flight emissions disclosures at the national level due to variance in emissions methodologies by state that could lead to inconsistent and non-comparable disclosures and instead urged that any such requirements use a standard international methodology, which IATA is currently developing.
With respect to Delta’s non-aviation-specific trade associations, the U.S. Chamber has not specifically taken a public position on the stated temperature goals identified by the IPCC, which does not align with Delta’s climate goals; however, the Chamber has developed a clear climate change policy position and actively supported U.S. participation in the Paris Agreement while facilitating direct business engagement during COP27. The BRT also facilitated business engagement during COP27, and its climate change position indicates alignment with the stated temperature goals identified by the IPCC. However, its current 2050 ambition is not a net-zero goal.
  • There may be areas of perceived misalignment from the lobbying activities of these two organizations. For example, the Chamber and BRT actively opposed, on tax policy grounds, the overall Inflation Reduction Act (IRA) legislative package, which contained a variety of climate change-related provisions, including incentives to support SAF development, which Delta actively supported - although we did not take a position on the non-climate change related provisions of the broader package. Following direct engagement from member companies, the BRT expressed support for the provisions that incentivized clean energy technology deployment and the U.S. Chamber pointed to its growing support for bipartisan clean energy policies and expressed disappointment that the climate and clean energy provisions were tied to partisan legislation that they could not support.
Both organizations were ultimately criticized by NGOs and other groups for their positions; however, we do not find their lobbying activities to be inconsistent, given their analysis extended beyond the climate policy provisions of the legislation.
With respect to climate lobbying activity undertaken by our aviation and non-aviation trade associations, A4A, BRT and the U.S. Chamber filed comments on the Securities and Exchange Commission’s (SEC) climate risk disclosure proposal noting their support for more transparent and comparable climate-related disclosures while raising significant concerns around key provisions of the specific proposal. Each association expressed an intention to work constructively with the SEC to advance a reporting regime that is grounded in the SEC’s long-standing concepts of materiality and that advances meaningful, decision-useful climate-related disclosures without being overly burdensome, complex or prescriptive. A4A, also provided airline-specific contextualization to demonstrate the range of interests and dynamics impacting our industry. We do not view any of these comments as inconsistent with our climate policies. As part of the iterative process, it is essential that trade associations provide sufficient input to inform this and future rulemakings governing disclosures.
  • Relatedly, at the state level, California sought to advance its own climate risk-disclosure proposal (SB260), which would have required reporting Scope 1, 2 and 3 emissions by corporations with over $1 billion in annual revenue. A4A opposed this legislation as duplicative of pending federal and international disclosure regimes, which is consistent with our climate policy principle of advancing harmonized policy approaches that mitigate redundancy.
With respect to Monroe’s trade association engagement, AFPM has not specifically taken a public position on the stated temperature goals identified by the IPCC nor actively engaged in the COP process; however, AFPM has developed a climate change policy position, reflected in the previous table. This lack of clarity and engagement regarding the science-based temperature goals has resulted in criticism from NGOs and certain other organizations and is inconsistent with Delta’s climate goals. There are also specific areas with respect to recent lobbying activities, including AFPM’s lack of support for the SAF provisions in the IRA, where we disagree. In our assessment, AFPM partially took issue with the bill’s treatment of liquid fuels, expressing concern with a perceived lack of recognition for their role in advancing a cleaner and more energy secure future. In contrast, Delta actively supported the SAF provisions within the bill as an important first step for scaling the market while acknowledging areas of improvement needed to provide investment certainty. While there are areas of misalignment, Monroe’s engagement with AFPM has helped facilitate increased thought leadership and engagement within the association around the role of SAF and other clean fuel solutions for hard-to-abate sectors like aviation, which is supportive of Delta’s SAF goal. Additionally, as the operator of an independent refinery, Monroe has utilized its membership in AFPM as part of its RFS compliance and risk mitigation strategy to seek permanent reform to the RFS program for the reasons explained previously.
However, it is important to note that advocacy is only one element of Monroe’s engagement with AFPM. It utilizes its membership to stay informed on, and to contribute to, best practices in the industry, covering a variety of issues beyond climate change including but not limited to safety, environmental stewardship and operational performance. Therefore, we believe the overall benefits of engagement outweigh the identified concerns.