Direct Climate Lobbying


In 2022, the Administration and Congress advanced the largest investments in climate change policy in history, putting the United States on a path to achieve a roughly 40% reduction in GHG emissions by 2030 and setting the stage for strong, incentive-based global leadership. Notably, the Administration accelerated its 2021 SAF Grand Challenge commitment by finalizing a comprehensive SAF Grand Challenge Roadmap, outlining a government-wide strategy for scaling up SAF production in the U.S. and serving as a replicable model for international partners.
As part of Delta’s advocacy efforts in 2022, we positively influenced the federal policy environment through several key efforts targeting government funding, stakeholder engagement, legislative advocacy and regulatory implementation. Specifically:
  1. We directly advocated for increased funding and resources for the multiple federal agencies supporting the SAF Grand Challenge. For example, we advocated in support of the Federal Aviation Administration’s (FAA) Continuous Lower Energy Emissions and Noise (CLEEN) program and its Center of Excellence for Alternative Jet Fuels and Environment (ASCENT) as well as the Department of Energy’s (DOE) Bioenergy Technologies Office (BETO) to support the development of SAF at commercial scale.
  1. We also participated in stakeholder engagement with federal agencies and policymakers to inform the development of the final roadmap.
  1. We actively advocated alongside our supply chain and industry partners to support federal legislation to promote the development of the SAF market via targeted tax incentives and grants. Specifically, we supported the enactment of the SAF provisions in the Inflation Reduction Act (IRA) and in its earlier iterations (e.g., Build Back Better 2.0) as well as standalone policy measures such as the Sustainable Skies Act and the Aviation Emissions Reduction Opportunity (AERO) Act.
  1. Within the IRA, we also supported provisions that will enable the development of next-generation power to liquids (PtL) technology, among other breakthroughs – key to achieving net-zero emissions – including incentives for renewable electricity, clean hydrogen and carbon capture technologies. Additional policy measures of significance included the first-ever commercial EV credit and new as well as expanded loan guarantee authorities at DOE.
  1. Following the enactment of the IRA, we centered our advocacy around implementation and coordinated with supply chain and industry partners to file select comments with the U.S. Department of Treasury and the Internal Revenue Service (IRS), encouraging flexibility in the interpretation of the law to maximize emissions reductions. We also set our sights on developing a coordinated advocacy strategy to support future bipartisan investment in SAF policy, given the short-term nature of the newly enacted SAF incentives.


We laid the foundation for long-term engagement on SAF policy deployment and advocated for supportive policies to accelerate investment in SAF production in existing as well as new markets, with a prioritization on states where our hub operations are located.
In Georgia (GA) and Minnesota (MN), we fostered foundational discussions with multiple public and private stakeholders (e.g., GA Forestry Commission, Bioeconomy Coalition of MN) to create SAF ecosystems and directly influenced the development of the MN Clean Fuels Standard (CFS) Report. We also actively supported SAF incentive legislation in California, New York, Kentucky, Illinois and Hawaii.
Examples of our advocacy include:
  • In California, we directly advocated with industry and supply chain partners – inclusive of a robust media campaign – for significant budget support for increased SAF production as well as for legislation (AB1322) directing the California Air Resources Board to study and develop a plan for increased SAF incentives in its 2025 scoping plan.
  • In Illinois, we worked with a coalition of airlines and producers to successfully advance legislation (HB5749) providing a 10-year purchasers’ incentive for SAF to help offset the state’s jet fuel tax, which will be implemented in the summer of 2023.
  • In Hawaii, we successfully advocated to ensure SAF was eligible for the reinstated Renewable Fuels Production Tax Credit (SB2478) and worked with our trade association to advance the enactment of a new Low Carbon Fuel Advisory Board, inclusive of a commercial airline board member.


United Nations International Civil Aviation Organization (ICAO) On the international level, 2022 marked the convening of the triannual 41st Assembly of the UN’s International Civil Aviation Organization (ICAO). The Assembly resulted in the adoption of a long-term aspirational goal to achieve net-zero carbon emissions for international aviation by 2050, representing one of the only global sector-specific goals of its kind, as well as the adoption of a new baseline – 85% of 2019 levels – for stabilizing GHG emissions from international aviation under ICAO’s Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA).
In partnership with A4A and the International Air Transport Association (IATA), we directly supported the long-term goal and the important role of CORSIA as the only market-based measure governing international aviation emissions over a patchwork of individual or duplicative regulations (e.g., EU ETS), which can be problematic for an international industry. We also expressed concerns with the final baseline compromise, advocating to maintain the CORSIA baseline at 100% of 2019 levels for the duration of the program. Notably, the new baseline roughly doubles the costs of the program, potentially diverting billions in limited resources from preferred in-sector emissions reduction measures, such as SAF, to out-of-sector offsets. Moving forward, we believe it will be important for the United States to encourage the prioritization of SAF over offsets, to ensure structural decarbonization through additional policy supports and incentives, as well as take appropriate steps to implement CORSIA domestically with appropriate safeguards to protect the competitiveness of the U.S. industry.
European Union (EU) In the EU, we again coordinated with our trade associations. We advocated for the EU to adopt incentives for SAF development and deployment, noting that the Refuel EU SAF mandate contained in the EU’s Fit for 55 package seeks to drive SAF supply without appropriate incentives to enable cost-effective investment. Also, consistent with our support for harmonized global policies, we advocated for the exclusion of extra-European flights under the EU ETS to avoid undermining CORSIA and potentially adding duplicative charges and obligations for international aviation emissions.