Union Pacific and Norfolk Southern have filed an amended merger application with the Surface Transportation Board (STB), setting out updated analysis for a proposed coast-to-coast freight network in the United States.

The companies state that the revised submission incorporates additional data and modelling requested by the regulator. The merger would create a single rail system linking eastern and western routes, with limited network overlap. The companies argue that this structure would allow for more direct freight movements without the need for interchange between rail operators.

The updated analysis estimates that shippers could save around 3.5 billion USD annually if freight shifts from road haulage to rail. The companies also project that the combined network could remove approximately 2.1 million lorry journeys each year, based on expected changes in long-distance freight patterns.

Union Pacific Arizona AAR

Union Pacific in Arizona

Both firms note that the modelling uses complete traffic data from all six North American Class I railways, rather than sample data typically used in regulatory filings. They argue that this provides a more comprehensive view of potential market and operational effects.

Union Pacific CEO Jim Vena said:

After completing the additional work requested by the STB, the facts remain clear: This merger enhances competition and delivers real public benefits that make America’s supply chain stronger. Our analysis uses complete systemwide traffic data provided by all Class I railroads to identify even more opportunities for our combined railroad to grow and compete.

In their submission, the companies state that the merger would expand intermodal services, increasing the number of proposed premium routes operating daily. One additional route would link Northern California with the south-eastern United States. The application also indicates that existing infrastructure and equipment capacity would be sufficient to support projected growth.

On competition, the companies maintain that the transaction would not materially reduce access to alternative rail services. They argue that the combined system would offer a new single-line option across regions currently served by multiple carriers, while existing routes operated by other railways would remain available.

The revised filing also includes updated employment projections. The companies estimate that around 1,200 additional union roles could be created within three years of completion, reflecting anticipated increases in freight volumes. They reiterate a commitment that existing union employees would retain their positions at the time of the merger.

Norfolk Southern President and CEO Mark George said:

This merger is fundamentally about growth. Shippers have been clear about what they value, and the data backs it up. When single-line rail service is available, they choose it. Our combined network will deliver seamless freight moves within and across the Mississippi watershed markets with one Class I railroad accountable from origin to destination.

In response to regulatory concerns, the companies have addressed ownership arrangements involving the Terminal Railroad Association of St. Louis. They now state that any controlling interest in the association would be relinquished as a condition of the merger.

The STB will review the application as part of its statutory process, including an assessment of competition, service impacts and public interest considerations. The regulator may impose conditions or require further information before reaching a decision.

Union Pacific and Norfolk Southern have indicated that, subject to approval, the transaction could be completed in the first half of 2027.

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