Union Pacific and Norfolk Southern’s renewed attempt to push through their merger is facing strong resistance from rival rail operators, who argue that the revised application still falls short of regulatory requirements and fails to demonstrate clear benefits for shippers.
The Surface Transportation Board had previously rejected the original December 2025 filing, citing it as incomplete. The two rail giants resubmitted their application on April 30, including additional data intended to show cost savings and supply chain improvements linked to the merger.
However, competitors including BNSF Railway, Canadian Pacific Kansas City (CPKC) and CSX have all raised objections during the STB comment period, which ended on May 8. While Union Pacific and Norfolk Southern maintain that their revised submission is “comprehensive and complete,” rival operators strongly disagree.
BNSF Railway argues that the application relies too heavily on what it describes as inflated expectations around truck-to-rail conversions. According to filings submitted by its legal team, BNSF says most of the projected public benefits depend on shifting freight from trucks to rail, rather than genuine efficiency gains from the merger itself.
The railroad also notes that recent improvements in rail and intermodal volumes across the industry have already been driven by external factors such as higher trucking costs and fuel prices, rather than structural changes linked to consolidation. BNSF further argues that the merger proposal does not guarantee lower rates for customers, despite claimed efficiency gains.
Canadian Pacific Kansas City has also pushed back strongly. CEO Keith Creel said the amended application fails to serve shipper interests and “puts our supply chains and economy at needless risk.” CPKC argues that Union Pacific and Norfolk Southern have not provided a sufficiently detailed market impact analysis, particularly around traffic volumes and revenue projections across key commodity corridors.
In its filing with the STB, CPKC said the proposal must include a clearer breakdown of rail traffic flows and commodity-level data in order to meet regulatory standards for a transaction of this scale.
CSX, meanwhile, focused its criticism on competition concerns. The company argues that the two railroads have not demonstrated how the merger would improve rail-to-rail competition, as required under STB rules introduced in 2001.
According to CSX, the applicants instead rely on the assumption that creating a transcontinental railroad would naturally improve competition with trucking, without providing sufficient supporting analysis.
CSX also claims that Union Pacific and Norfolk Southern have not fully complied with requirements to submit detailed competition and efficiency assessments before re-filing their application.
As the regulatory review continues, the merger proposal remains under heavy scrutiny, with rival railroads questioning whether the deal meets the threshold for approval under existing competition and market impact standards.
