Delta Responds to Rep. Pallone on Misinformation on Consumer Surveillance Pricing

Delta's President Peter Carter sent the following letter to U.S. Representative Frank Pallone in response to questions from Senators about the use of AI in Delta's dynamic pricing model. 

Sent on Sept. 9, 2026

Dear Ranking Member Pallone:

Thank you for your letter dated August 11, 2026, regarding concerns of a perceived rise of artificial intelligence (AI) assisted “surveillance pricing” across the consumer goods industry, including the airline industry. We appreciate the opportunity to further clarify how Delta Air Lines (Delta) prices air travel and how we are using AI to support, and not to replace, the analysts who do that work.

Delta recognizes that many Americans are closely managing household budgets and making careful choices about discretionary spending, including travel. We take seriously our responsibility to price air travel fairly and transparently. Technology, including AI-enabled decision-support tools, can help our analysts better match fares to market conditions and customer demand. In periods of lower demand, these tools, for example, may support decisions to lower fares, helping make air travel more accessible to more customers. Consistent with that objective, there is no fare product Delta has ever used, is testing, or plans to use that targets customers with individualized prices based on personal data. Furthermore, we have zero tolerance for discriminatory or predatory pricing and fully comply with applicable privacy, pricing, and advertising laws.

Your letter raises very specific questions that pre-suppose the use of surveillance or individualized pricing by our company. In July of 2025, we publicly condemned such assertions, in response to misinformation on this topic and reinforced our commitment as the airline of choice for our customers. Though we share your goal of ensuring customers can trust prices offered for air travel, we remain deeply concerned that the perpetuation of this narrative around airline prices could have unintended consequences that negatively impact consumer sentiment and trust. However, we appreciate the opportunity to set the record straight once again and further clarify our efforts. While we take these questions seriously, because we do not engage in this form of pricing, our letter responds to your questions with a thematic, principles-based approach rather than on a question-by-question basis.

Airline Pricing

Please associate our comment letter with the Airlines for America (A4A) industry submission, dated August 25, 2026, which provides insight into how U.S. airlines competitively price air travel. As reinforced by A4A, airline ticket prices are driven by changing market dynamics, consumer demand, and vigorous competition, not individualized customer surveillance. Prices are also influenced by a wide variety of factors, NOT a customer’s personal information, including:

• Customer demand for a particular flight or route;
• Seat and fare class availability;
• Competitive schedules and marketplace offerings;
• Historical and forecasted travel demand; and
• Operating costs, including fuel, labor, airport charges, and other inputs.

Use of AI in Pricing and Innovation

At Delta, our AI strategy aims to improve efficiency and enhance – not exploit – the customer experience. Delta’s previously reported piloted use of a generative AI pricing recommendation tool (“AI Pricing Tool”) – in domestic and international test markets – supports analyst decision-making by reducing manual work, accelerating analysis, and shortening the time needed to bring a pricing adjustment to market. Given the tens of millions of fares and hundreds of thousands of routes for sale at any given time, technology of this kind helps us analyze existing data and respond to changing market conditions at greater speed and scale. Under Delta’s agreement for the AI Pricing Tool, only route-level demand and market data are provided to support Delta’s dedicated private deployment of the AI Pricing Tool. Delta does not provide the AI Pricing Tool with personal information about our customers, and the fares we file do not take any customer’s personal data into account.

Delta has also clarified that the AI Pricing Tool used by our analysts is a decision-support tool. We continue to rely on the expertise and experience of our analysts to set competitive fares. Technology of this kind, when deployed responsibly, has the potential to augment decision making and streamline operations without compromising fairness or transparency. Delta’s approach reflects this broader innovative trend while maintaining strict safeguards and human oversight.

Guiding Principles Informing Our Approach to Innovation

Responsible AI Governance: Delta has committed to a responsible approach to AI. All AI tools are assessed against and must comply with a proprietary governance framework, which includes a rigorous assessment and mitigation of the privacy and security risks of AI use cases. The framework also prohibits the use of personal data in ticket pricing.

• Delta analysts maintain meaningful oversight over the operation of the AI Pricing Tool through governance processes, monitoring, and intervention capabilities.
• Delta transparently discloses in its Privacy Policy how we use, store, and disclose personal information when customers interact with Delta, including when customers use the Delta.com website or Fly Delta app.
• Delta provides AI Terms of Use and discloses to customers instances when they are interacting with an AI-powered chatbot or agent (e.g. Delta’s search functionality on delta.com and its recent beta launch of Delta Concierge, a virtual in-app assistant).

Compliance with Law: Delta adheres to applicable federal, state, and international antitrust, privacy, and consumer protection laws and regulations (e.g. the Department of Transportation’s (DOT) Unfair and Deceptive Practices regulations, the California Consumer Privacy Act (CCPA), the European Union’s Global Data Protection Regulation (GDPR), etc.) while continuously reviewing evolving standards. We also evaluate AI use cases for compliance with applicable legal and regulatory requirements.

Aggregate Data Use: The AI Pricing Tool leverages aggregated demand (historic and predicted) and route-level information—not individual customer data—to assist analysts in setting fares. Types of data utilized and use cases are highlighted below:

• Aggregating purchasing behavior for specific routes and flights;
• Forecasting demand for specific routes and flights;
• Adapting to new market conditions;
• Factoring in thousands of variables simultaneously; and
• Learning from each pricing decision to improve future outcomes.

Commitment to Loyalty: Delta’s loyalty program is designed to reward customers for choosing Delta – not to determine or personalize the price they pay for airfare. SkyMiles® Members benefit from transparent, customer-friendly value through opportunities to earn and redeem miles, access elevated travel experiences, and receive benefits (e.g. waived bag fees, SkyMiles discounts, free wifi, lounge access, etc.) that recognize their relationship with Delta while preserving customer trust and choice. Delta may use anonymized, aggregated insights to better understand broad customer preferences and improve program offerings, but those insights do not utilize protected class demographics nor individual consumer data for the purposes of setting individualized ticket pricing. Delta also offers SkyMiles Members access to medical emergency fares and bereavement fares.

• Outside of Delta’s loyalty program, we offer discounted fares and benefits for active members of the U.S. military and dependents. We also participate in the City Pair Program, providing special rates and benefits for federal employees. These benefits turn on transparent eligibility criteria, not on inferences drawn from a customer’s personal data. We also occasionally offer promotional pricing that is publicly available to all travelers regardless of loyalty status.

In closing, we reiterate our shared goal of ensuring consumers can trust how airfares are set. Delta’s goal is simple: to enhance efficiency and responsiveness in fare management while upholding the trust of our customers and the integrity of our brand – never to exploit or take advantage of our customers. We appreciate your engagement and hope this letter further clarifies our use of AI in pricing and innovation.

Very truly yours,
Peter Carter
President

See Peter Carter's letter to Senators in 2025: Delta responds to misinformation around AI pricing.