Union Pacific and Norfolk Southern on April 30, 2026, resubmitted a revised merger application to the Surface Transportation Board, months after regulators unanimously rejected their first attempt as incomplete. The revised filing sets the stage for a fresh round of public scrutiny over what would be the largest railroad consolidation in decades, even as opposition from shippers, unions, farm groups and rival railroads continues to mount.

On Jan. 16, 2026, the Surface Transportation Board (STB) reported on their website that, in a unanimous decision, the major merger application filed by Union Pacific (UP) and Norfolk Southern (NS) on Dec. 19, 2025, was incomplete because it did not contain certain information required by the board's merger regulations as written here: https://www.ecfr.gov/….

On April 30, 2026, the STB announced on their website it received a revised major merger application from UP and NS (together, Applicants). The Board further announced comments on the completeness of that revised application were due by Friday, May 8, 2026, at noon EDT.

"As discussed in the Board's Aug. 28, 2025, notice of receipt of the Applicants' prefiling notification, the proposed transaction is classified as a major transaction under the Board's regulations at 49 C.F.R. 1180.2(a). An application for a major transaction must include substantial supporting information, detailed in the Board's regulations at 49 C.F.R. part 1180," said the STB in a news release.

"Following this comment and reply period, the Board will make a determination on the completeness of the revised application, either accepting it as complete or rejecting it as incomplete. This determination should not be mistaken for a determination on the merits of the proposed transaction. Should the Board accept the revised application for consideration, it will issue a procedural schedule for comments on the merits of the proposed transaction," added the STB.

In an April 30, 2026, news release, UP and NS said after submitting the application the additional analysis reinforces that the combination will drive growth, enable substantial cost savings for shippers and strengthen the U.S. supply chain.

"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," said Union Pacific CEO Jim Vena. "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."

"This merger is fundamentally about growth," said Norfolk Southern President and CEO Mark George. "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."

The press release went on to say, "The Union Pacific-Norfolk Southern combination is an end-to-end merger connecting the eastern and western United States with virtually no overlap. The goal: Growth through new routes and improved service that removes interchange handoffs that can add 24 to 48 hours and cost to the supply chain." Here is a link to the full press release: https://www.up.com/….

COMMENTS FROM SHIPPERS, AG GROUPS AND UNIONS

Comments to the STB were mixed as far as approval or disapproval of the proposed UP-NS merger. Here are a few, and more can be found in the 'view filings' section on the STB website: https://www.stb.gov/….

In a March 3, 2026 letter to Congress, Jeremy R. Ferguson, president of the transportation division wrote on behalf of the International Association of Sheet Metal, Air, Rail and Transportation Workers -- Transportation Division (SMART-TD): "Following extensive negotiations, SMART-TD reached a historic agreement with Union Pacific that provides extraordinary job protections for employees in train and yardmaster service. Under this agreement, Union Pacific has committed that employees of both Union Pacific and Norfolk Southern will not face involuntary furloughs, guaranteeing job protection for the duration of their careers. This level of protection is unprecedented in modern rail consolidations and represents a meaningful departure from the uncertainty that has accompanied prior transactions. Because of the strong workforce protections secured, the stability they provide to thousands of railroad families, and the broader public benefits anticipated by the transaction, SMART-TD will be conveying its support for the merger before the Surface Transportation Board." Here is a link to the letter: https://www.smart-union.org/….

"A proposed merger between Union Pacific and Norfolk Southern is being sold as progress. We're not buying it," said Mark Wallace, president of the Teamsters Rail Conference and the Brotherhood of Locomotive Engineers and Trainmen (BLET), and Tony Cardwell, president of the Brotherhood of Maintenance of Way Employes Division (BMWED), in a joint statement. "We lead the two unions that make up the Teamsters Rail Conference -- the Brotherhood of Locomotive Engineers and Trainmen and the Brotherhood of Maintenance of Way Employes Division. Together, we represent more than half of the national union workforce at both railroads. We've talked to our members. We've looked at the numbers. And we know what this kind of deal usually means." Read more of their statement here: https://blet.org/….

Keith Creel, president and CEO of CPKC said, "Opposition to the UP-NS merger proposal continues to grow across a broad range of stakeholders, including rail shippers and customers, business associations, unions and labor groups, railroads, elected officials, community leaders and more. All of them have deep and widespread unease about the implications of this unnecessary mega-merger on rail competition, affordability, supply chain reliability, and market balance."

"Farmers and ranchers rely heavily on rail service to get products to families across the country," said President of the American Farm Bureau Federation Zippy Duvall. "This merger would lead to greater consolidation and higher costs when farmers are already hard-pressed with economic headwinds beyond their control. Ultimately, those costs ripple far beyond the farm gate, impacting not only the price of food for Americans, but also likely pushing farm margins even lower."

"This (merger proposal) did not begin with a customer asking for a UP-NS merger to happen," said President and Chief Executive Officer of BNSF Railway Katie Farmer. "It's driven by Wall Street on the promise of a big shareholder payout. It will eliminate competition, raise costs for consumers, and destabilize the supply chain that powers the American economy." Read more comments here from the Stop the Rail Merger Coalition: https://www.bnsf.com/….

The NGFA said in their filing to the STB, "While the Amended Application contains the term 'precise steps' in several places, there is no explanation of precisely how the Applicants will utilize other railroads to help them overcome serious service disruptions post-merger. Such additional details are necessary because the 2001 Rules require them, but also because the process of how the cooperation of other railroads would be sought and executed is not one-size-fits-all. It will vary according to where such disruptions occur on the combined system." NGFA added the "Amended Application is incomplete in at least several areas" as discussed in their filing on May 8, 2026: Here is a link to their filing: https://www.ngfa.org/….

Link to UP/NS merger application: https://www.stb.gov/….

BNSF Flyer: The UP-NS Merger: A Monopoly in the Making: https://www.bnsf.com/….

Follow any developments from the STB on the merger here: https://www.stb.gov/….

Mary Kennedy can be reached at mary.kennedy@dtn.com

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