The correct answer is $\boxed{\theta – \delta}$.
The zenith distance of a star is the angle between the star and the zenith, which is the point directly overhead. The declination of a star is its angular distance from the celestial equator. The celestial equator is an imaginary line in the sky that is directly above the Earth’s equator.
If a star is located at a declination of $\delta$, then it will be visible at its upper culmination when the zenith distance is $\theta – \delta$. This is because the zenith distance is equal to the latitude of the observer minus the declination of the star.
For example, if the observer is located at a latitude of $\theta = 45^\circ$ and the star has a declination of $\delta = 30^\circ$, then the zenith distance of the star at its upper culmination will be $\theta – \delta = 15^\circ$.
The other options are incorrect because they do not take into account the latitude of the observer.