BNSF Railway reiterated that the merger between Union Pacific (UP) and Norfolk Southern (NS) presents serious risks to competition, service and the supply chain .
According to Tom G. Williams, executive vice president and chief marketing officer of BNSF Railway, he noted the above after reviewing the merger application that the companies submitted to the United States Land Transportation Board (STB) on December 19, 2025.
In a letter sent to its customers, it mentioned that the growth promises presented by the companies are unrealistic , since the combined volumes of UP and NS alone have decreased by 13% in the last decade.
However, the first one promises 12% growth in just three years, almost entirely thanks to the conversion of truck carriers to rail carriers.
“STB statistics show that UP already earns more revenue from higher fares than any other Class I railroad. When this growth in truck conversion doesn’t materialize, you’ll pay for their merger premiums with higher fares. The protections proposed by UP are a Trojan horse designed to get their application approved,” he emphasized.
Regarding the Gateway Tariff Commitment proposed by UP, he considered that it excludes almost all shippers . Only 0.4% of all rail freight transport would be eligible. Furthermore, it expires in a few years, “leaving you vulnerable to monopoly pricing.”
Williams also indicated that integration risks exist due to UP and NS’s “trust us” approach, which does not offer fundamental safeguards against serious supply chain disruptions on a much larger scale.
“The last time UP led a merger integration in 2008, the STB had to extend its oversight period twice due to the congestion problems it caused in Chicago,” he recalled.
He noted that the UP-NS merger request cites more than two thousand letters of support , including some 500 from shippers, representing less than 6% of all traffic on the U.S. rail network.
In contrast, the Rail Customers Coalition—which represents carriers of more than half of all rail freight volume—has stated that the merger would create near-monopoly power , increasing costs for manufacturers, farmers, energy producers, and ultimately, consumers. Similarly, the Teamsters Rail Conference and the Brotherhood of Railroad Signalmen , which together represent more than half of all rail workers, warn that the merger would reduce competitiveness and increase safety risks.
“These numbers matter. The voices opposing the merger represent the vast majority of customers and rail workers who interact with UP and NS on a daily basis. As more stakeholders review the application, opposition is growing. The application is so lacking in substance that several key players have already asked the STB to reject it as incomplete. When the STB finally accepts the application as complete, it will publish a timetable that will include a short comment period. This will be your opportunity to raise your voice and protect your interests,” he stated.
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