(C2.2a) Which risk types are considered in your organization's climate-related risk assessments?
Relevance
&
inclusion
Please explain
Current
regulation
Relevant,
always
included
Local, state, federal, and international regulations regarding the environment create compliance and financial risks to United. Examples of international agreements include ICAO’s Carbon
Offsetting and Reduction Scheme for International Aviation (CORSIA), for which 2019 was the first reporting year. The unprecedented nature of the COVID-19 pandemic prompted ICAO to
include only 2019 emissions as the baseline upon which offsetting obligations would be calculated for the first phase (2021-23) of the scheme. The applicable baseline for the subsequent
phases of the scheme, however, is still uncertain, as CORSIA only applies to the flights between countries that have volunteered for the first phase. Approximately 33% of United’s pre-
COVID-19 capacity (including regional partners) was flown between country-pairs that have volunteered for the first phase of CORSIA. If additional countries join in subsequent years, this
number is expected to increase. Related state regulations include California’s AB 32 (The 2006 Global Warming Solutions Act), which created a Low Carbon Fuel Standard (LCFS) in
California that aims to reduce the carbon intensity of the state’s transportation fuel pool by approximately 20% by 2030 via both mandates and incentives. The LCFS program has helped
facilitate a market for lower-carbon fuels, for which there is currently insufficient supply in aviation, while contributing to upward price pressure for road-based conventional fuels. As the
California LCFS has matured, other states/regions within the United States are proposing similar low carbon-fuel policies. These risks are identified and assessed by Environmental Affairs
and Regulatory Affairs as existing regulations continue to evolve. These departments then proactively evaluate the financial impact of these regulations to determine the most appropriate
risk response, and report these results to the Enterprise Risk Management (ERM) Committee, United officers, and the Board.
Emerging
regulation
Relevant,
always
included
United continuously monitors the regulatory environment as it evolves to identify and evaluate new exposures and its risk response. United participates in various industry groups including
Airlines for America, the International Air Transport Association, and the Air Transport Action Group, which have environmental, fuel, and other groups that monitor and share information
on emerging environmental risks that impact the airline industry. A prior example of this risk was the introduction of the European Union Emissions Trading Scheme (EU ETS), which could
have applied to nearly all of United’s routes to Europe, were the company and these industry groups not successful in advocating the scheme apply to only intra-EU routes, thereby helping
to avoid a patchwork of different and potentially conflicting emission schemes levied against international air transport. Instead, the industry championed CORSIA, a sole international and
cooperative global market-based policy solution for aviation GHG emissions. A further example of regulatory risk is the emergence of sustainable aviation fuel (SAF) mandates, which could
require a volume of SAF that is not yet existing in supply and potentially lead to market distortion. Instead, United is currently advocating with the U.S. EU, and other governments for
positive incentives to encourage supply in the long-term. Most recently, on July 14, 2021, the European Commission proposed comprehensive climate change legislation (styled as “Fit for
55” – the Commission’s plan to set the EU on course to reduce EU GHG emissions by 55% by 2030) that would introduce a blending mandate for SAF. This proposal must navigate the
legislative process, and United will continue to make the case that incentives are more effective than mandates in promoting the production and use of SAF. These risks are identified and
assessed by Environmental Affairs and Regulatory Affairs as existing and new regulations continue to evolve. These departments then proactively evaluate the financial impact of these
regulations to determine the most appropriate risk response and report these results to the ERM Committee, United officers, and the Board.
Technology Relevant,
sometimes
included
Technology-related risks relevant to United include product efficiency regulations and standards such as ICAO’s CO2 efficiency standard (which the U.S. EPA adopted in late 2020) that
applies to aircraft designs, and the ability of aircraft manufacturers to meet the standard. These risks apply to all of United’s current and future aircraft types. These risks are identified and
assessed by Environmental Affairs and Regulatory Affairs as existing regulations continue to evolve. These departments then proactively evaluate the financial impact of these regulations
to help determine the most appropriate response, and report these results to the ERM Committee, United officers, and the Board.
Legal Relevant,
sometimes
included
Legal risks relevant to United include, among others, litigation, regulatory, or administrative proceedings related to environmental issues. The Legal department works with other
departments within the company, including Environmental Affairs and Regulatory Affairs, to evaluate and assess these risks. Examples of legal risk include litigation, regulatory, or
administrative proceedings that municipalities have initiated against the industry on climate-related issues, or against government agencies seeking more aggressive regulations. For
example, in Brazil the State Public Prosecutor filed lawsuits against all airlines operating at Sao Paulo Guarulhos International Airport seeking damages due to GHG emissions, in the form
of land restoration projects, or a fixed fee per passenger to offset perceived environmental issues. The case was dismissed in March 2021. Failure to properly respond to such actions
could lead to financial penalties as well as negatively impact United’s reputation. By way of further example, airlines face exposure to significant penalties for breach of strict noise
standards in certain countries where United operates, such as Belgium.
Market Relevant,
sometimes
included
Market risks relevant to United include consumer preferences for lower carbon travel, which could lead to shifts in demand from international to domestic air travel, or shifts in demand away
from air travel to alternate modes of transportation or shifts away from business travel towards virtual meetings and events. These risks are identified and assessed by Network Planning as
markets continue to evolve. This department evaluates changes in market demand on an ongoing basis.
Reputation Relevant,
sometimes
included
Reputational risks relevant to United include shifts in consumer preferences that may impact demand for United’s travel services, or increased expectations regarding decarbonization and
emissions reductions activities, including reporting and disclosure of these initiatives, such as decarbonization investments or use of emissions-reducing sustainable aviation fuel. If United
is not viewed as market leader in terms of disclosure and emissions reduction, the reputational impact could lead to customers seeking to use alternative airlines. These risks are identified
and assessed by Environmental Affairs, Corporate Communications, and Investor Relations. These departments monitor public opinion and expectations and investor interest and
expectations around climate commitments, and the perceptions of its stakeholders regarding United’s and other airlines’ impact on climate change.
Acute
physical
Relevant,
sometimes
included
Acute physical risks relevant to United include changes in weather intensity that may result in impacts to United’s flight operations, such as the extreme polar vortex event that occurred in
the Midwest in 2019, which created extreme delays in aircraft fueling, impacting service and operations by necessitating normally nonstop flights international flights to make fueling stops in
other cities. In 2017 United temporarily suspended service to Delhi due to poor air quality concerns from pollution. In September 2020, wildfires in the Pacific Northwest restricted visibility,
requiring United to cancel flights at certain airports in the region. These risks are identified and assessed by Airport Affairs, Environmental Affairs, Network Operations, and Risk
Management. These departments constantly evaluate and respond to weather-related events, focus on improving aircraft performance, and work with local airport authorities to ensure that
adequate airport runway capacity and operating capabilities are in place.
Chronic
physical
Relevant,
always
included
Chronic physical risks relevant to United include changes in mean (average) temperature, changes in mean (average) precipitation, and sea level rise that may result in impacts to United’s
flight operations as well as changes in consumer preferences that may impact demand for United’s travel services. For example, there may be changes to traditional winter sports vacation
destinations if temperature increases impact the desirability of these destinations. By way of further example, in winter 2017-18 there was lower than normal snowfall in markets such as
Colorado and Montana that resulted in reduced travel demand. These risks are identified and assessed by Airport Affairs, Environmental Affairs, and Network Operations. These
departments constantly evaluate and respond to weather-related events, focus on improving aircraft performance, and work with local airport authorities to ensure adequate airport runway
capacity and operating capabilities are in place.
C2.3
(C2.3) Have you identified any inherent climate-related risks with the potential to have a substantive financial or strategic impact on your business?
Yes
C2.3a
(C2.3a) Provide details of risks identified with the potential to have a substantive financial or strategic impact on your business.
Identifier
Risk 1
Where in the value chain does the risk driver occur?
Direct operations
Risk type & Primary climate-related risk driver
Emerging regulation Mandates on and regulation of existing products and services
Primary potential financial impact
Increased direct costs
Climate risk type mapped to traditional financial services industry risk classification