1 unchanged sentence
Certain of these covenants impose restrictions on our business, and failure to comply with any of the covenants in these agreements could result in events of default.
−Removed: Our debt agreements contain various affirmative, negative and financial covenants, including our credit facilities and our SkyMiles financing agreements, each of which contains a minimum liquidity covenant.
+Added: Our debt agreements, including our credit facilities and our SkyMiles financing agreements, contain various affirmative, negative and financial covenants.
Certain of our debt agreements and our SkyMiles financing agreements contain minimum coverage ratios.
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As a result, Monroe is exposed to the market price of RINs.
−Removed: Market prices for RINs have been volatile, marked by periods of sharp increases and decreases primarily in response to speculation about what the EPA and/or the U.S.
+Added: Historically, market prices for RINs have been volatile, marked by periods of sharp increases and decreases, including in response to speculation about what the EPA and/or the U.S.
Congress will do with respect to compliance obligations.
We cannot predict these actions or the future prices of RINs.
−Removed: Monroe’s purchase of RINs at elevated prices in the future could have a material impact on our consolidated results of operations and cash flows.
Existing laws or regulations could change, and the minimum volumes of renewable fuels that must be blended with refined petroleum products may increase.
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| 2024 Form 10-K
−Removed: Our reputation and brand could also be adversely impacted by, among other things, failure to make progress toward and achieve our environmental sustainability and diversity, equity and inclusion goals, as well as public pressure from investors or policy groups to change our policies or negative public perception of the environmental impact of air travel.
+Added: Our reputation and brand could also be adversely impacted by, among other things, failure to make progress toward and achieve our environmental sustainability goals, as well as public pressure from investors or policy groups to change our policies or negative public perception of the environmental impact of air travel.
For example, we have established ambitious goals to reduce our greenhouse gas emissions.
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Risk Factors Relating to the Airline Industry
−Removed: Disease outbreaks, such as the COVID-19 pandemic or similar public health threats that may arise in the future, and measures implemented to combat them have had, and may in the future have, a material adverse effect on our business.
−Removed: The COVID-19 pandemic, the measures governments and private parties implemented in order to stem its spread, and the general concern about the virus among travelers had a material adverse effect on the demand for worldwide air travel compared to historical levels, and consequently upon our business for an extended period.
+Added: Disease outbreaks or other public health threats, and measures implemented to combat them have had, and may in the future have, a material adverse effect on our business.
+Added: The measures governments and private parties implemented in order to stem the spread of the COVID-19 pandemic, and the general concern about the virus among travelers, had a material adverse effect on the demand for worldwide air travel compared to historical levels, and consequently upon our business for an extended period.
Similar disease outbreaks or public health threats that may arise in the future could have similarly adverse effects on our business.
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Any of the foregoing could have a material adverse effect on our financial condition and results of operations.
−Removed: The airline industry is subject to extensive government regulation, which is costly and could materially adversely affect our business.
+Added: The airline industry is subject to extensive regulatory and legal compliance requirements, which is costly and could materially adversely affect our business.
Airlines are subject to extensive regulatory and legal compliance requirements that result in significant costs and may have material adverse effects on our business.
−Removed: For instance, the FAA from time to time issues directives and other regulations relating to the maintenance and operation of aircraft that necessitate significant expenditures and could carry operational implications.
+Added: There have also been recent legal developments in the United States that may change the way historical obligations have been interpreted or applied.
+Added: The FAA from time to time issues directives and other regulations relating to the maintenance and operation of aircraft that necessitate significant expenditures and could carry operational implications.
We expect to continue incurring significant expenses to comply with the FAA’s regulations.
In addition, a directive or other regulation that has a significant operational impact on us could have a material adverse impact on our financial results.
−Removed: Other laws, regulations, taxes and airport rates and charges have also been imposed from time to time that significantly increase the cost of airline operations, reduce revenues or otherwise impact our business.
−Removed: The industry is heavily taxed.
−Removed: Additional taxes and fees, if implemented, could negatively impact our results of operations.
Delta Air Lines, Inc.
| 2024 Form 10-K
−Removed: Airport slot access is subject to government regulation and changes in slot regulations or allocations could impose a significant cost on the airlines operating in airports subject to such regulations or allocations or otherwise adversely affect an airline’s business.
−Removed: Certain of our hubs are among the most congested airports in the United States and have been, and could in the future be, the subject of regulatory action that might limit the number of flights and/or increase costs of operations at certain times or throughout the day.
−Removed: Air traffic control inefficiencies can also enhance these pressures.
−Removed: In addition, inefficiencies in the U.S.
+Added: Inefficiencies in the U.S.
air traffic control system, which is regulated by the FAA, can result in delays and disruptions of air traffic, especially during peak travel periods in certain congested markets.
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Failure to update the air traffic control system in a timely manner, and the substantial funding requirements of an updated system that may be imposed on air carriers, may have an adverse impact on our financial condition and results of operations.
+Added: Airport slot access is subject to government regulation and changes in slot regulations or allocations could impose a significant cost on the airlines operating in airports subject to such regulations or allocations or otherwise adversely affect an airline’s business.
+Added: Certain of our hubs are among the most congested airports in the United States and have been, and could in the future be, the subject of regulatory action that might limit the number of flights and/or increase costs of operations at certain times or throughout the day.
+Added: Air traffic control inefficiencies can also enhance these pressures.
+Added: Other laws, regulations, taxes and airport rates and charges have also been imposed from time to time that significantly increase the cost of airline operations, reduce revenues or otherwise impact our business.
+Added: The industry is heavily taxed.
+Added: Additional taxes and fees, if implemented, could negatively impact our results of operations.
As an international carrier, we are subject to a wide variety of U.S.
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In particular, the imposition of significant tariffs with respect to aircraft that we are not able to mitigate could substantially increase our costs, which in turn could have a material adverse effect on our financial results.
−Removed: In addition, some of our operations are in high-risk legal compliance environments.
+Added: Some of our operations are in high-risk legal compliance environments.
Failure to comply with trade sanctions and restrictions, the Foreign Corrupt Practices Act (the "FCPA") and similar anti-bribery laws in non-U.S.
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carriers are subject to U.S.
−Removed: and foreign laws regarding privacy and security of passenger and employee data that are not consistent in all countries in which we operate and which are continuously evolving, requiring ongoing monitoring and updates to our privacy and information security programs.
+Added: and foreign data privacy and security laws that are not consistent in all countries in which we operate and which are continuously evolving, requiring ongoing monitoring and updates to our privacy and information security programs.
Although we dedicate significant resources to manage compliance with global privacy and information security obligations, this challenging regulatory environment may pose material risks to our business, including increased operational burdens and costs, regulatory enforcement, and legal claims or proceedings.
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Compliance with existing and future environmental laws and regulations could require capital investment and increase operational costs, and violations can lead to significant fines and penalties and reputational harm.
−Removed: For example, in 2022, the EPA proposed regulations to define certain PFAS as "hazardous substances" under CERCLA, and the EPA has proposed to regulate certain PFAS as "hazardous constituents" under RCRA.
−Removed: The EPA is also proposing to regulate PFAS under the Safe Drinking Water Act.
−Removed: PFAS are used in a wide variety of consumer and industrial products, including the firefighting foams used to extinguish fuel-based fires at airports and refineries.
−Removed: Numerous states have adopted regulations governing PFAS as well, and some have adopted legislation prohibiting the manufacture, sale, distribution and/or use of firefighting foam containing intentionally added PFAS.
−Removed: EPA’s proposed rule under CERCLA, once finalized, could subject airports, airlines, and refineries, among others, to potential liability for cleanup of historical PFAS contamination associated with use of PFAS-containing firefighting foam, and some state laws require transition to alternative fire suppression systems.
+Added: For example, in 2024, the EPA finalized regulations defining certain per- and polyfluoroalkyl substances ("PFAS") as "hazardous substances" under the Comprehensive Environmental Response Compensation and Liability Act ("CERCLA"), and the EPA also finalized regulations establishing drinking water standards for certain PFAS under the Safe Drinking Water Act.
+Added: PFAS are man-made chemicals that have been used in a wide variety of consumer and industrial products, including the firefighting foams used to extinguish fuel-based fires at airports and refineries.
+Added: Numerous states have adopted regulations governing PFAS as well.
+Added: The EPA’s final rule under CERCLA, and analogous state laws, could subject airports, airlines, and refineries, among others, to potential liability for cleanup of historical PFAS contamination associated with use of PFAS-containing firefighting foam.
+Added: In addition, some states have adopted legislation prohibiting the manufacture, sale, distribution and/or use of firefighting foam containing intentionally added PFAS, which may require the transition to alternative fire suppression systems.
The ultimate impact and associated cost to Delta of these legislative and regulatory developments related to PFAS, including firefighting foam, cannot be predicted at this time.
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Because certain CORSIA program details remain to be developed and could potentially be affected by political developments in participating countries or the results of the initial phases of the program, the impact of CORSIA cannot be predicted at this time.
−Removed: However, CORSIA is expected to increase operating costs for airlines that operate internationally.
+Added: However, compliance with CORSIA is expected to increase operating costs for airlines that operate internationally.
In addition to CORSIA, we may face a patchwork of regulation of aircraft emissions in the U.S.
1 unchanged sentence
For example, in 2023, the EU adopted updated legislation on the EU Emissions Trading System (“ETS”).
−Removed: The new legislation continues in effect the so-called “stop-the-clock” provision whereby EU ETS does not apply to flights to or from locations outside the EEA, Switzerland or the UK until 2027.
−Removed: However, the legislation provides for a review of the effectiveness of CORSIA in 2026 that could, if CORSIA is not deemed sufficiently effective, lead to the application of EU ETS to all flights departing the EU and EEA.
+Added: That legislation continues in effect the so-called “stop-the-clock” provision whereby EU ETS does not apply to flights to or from locations outside the EEA, Switzerland or the UK until 2027.
+Added: The legislation also provides for a review of the effectiveness of CORSIA in 2026 that could, if CORSIA is not deemed sufficiently effective, lead to the application of EU ETS to all flights departing the EU and EEA.
Also in 2023, the EU adopted legislation that will impose a SAF mandate on fuel supplied at EU airports.
1 unchanged sentence
This mandate is expected to increase the cost of SAF in the EU.
+Added: In 2024, the UK also adopted SAF mandate legislation, and other countries are considering mandates.
Additional regulation could result in taxation, regulatory or permitting requirements from multiple jurisdictions for the same operations and significant costs for the airline industry, including Delta.
12 unchanged sentences
In addition, significant or volatile changes in exchange rates between the U.S.
−Removed: dollar and other currencies, and the imposition of exchange controls or other currency restrictions, may have a material adverse effect on our liquidity, financial conditions and results of operations.
+Added: dollar and other currencies, and the imposition of exchange controls or other currency restrictions, may have a material adverse effect on our liquidity, financial condition and results of operations.
Our international operations are an important part of our route network.
2 unchanged sentences
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.