A Nov. 24 letter to the Surface Transportation Board co-authored by 64 U.S. trade associations, chambers, and businesses—from the chemical and agribusiness sectors to the automotive dealer, plastics, building, vinyl, and pet food sectors—urged the Board to “thoroughly scrutinize” the Union Pacific-Norfolk Southern merger proposal “to ensure it does not undermine the integrity of our nation’s transportation network or disrupt the supply chain.”
The letter is one of many filed recently from groups expressing their opinions about and/or their intent to participate in the STB proceeding concerning the transaction that would combine the two Class I’s networks under common ownership and form a U.S. transcontinental.
The STB Office of Chief Counsel entered the letter from the undersigned into the public record Nov. 25, 2025. Railway Age reproduces it in full below.
“On behalf of the undersigned trade associations, chambers and businesses representing vital sectors of the U.S. economy, we write to express strong concerns regarding the proposed merger between Union Pacific Railroad and Norfolk Southern Railway.
“Our industries collectively represent millions of American workers that depend on freight rail as an important link in the supply chain. Without it, American consumers can’t affordably access the goods and services they rely on every day. Reliable and affordable freight rail service is essential to maintaining U.S. manufacturing strength, supporting energy security, and ensuring reliable supply chains.
“History has shown that increased rail consolidation leads to fewer choices, higher transportation costs, service disruptions, and reduced economic competitiveness. Today, just four Class I railroads [UP, NS, BNSF, and CSX] control more than 90% of freight rail traffic. The proposed UP/NS transaction would be the largest rail merger in history and would put control of more than 40% of rail traffic in the hands of a single railroad. It would further weaken the small amount of competition that currently exists in the railroad industry. Past rail mergers have triggered major breakdowns in the supply chain and increased costs for businesses and consumers alike.
“Given the potential for widespread economic harm, it is essential that the Surface Transportation Board proceed with great care. The creation of a transcontinental railroad must not come at the expense of competition, service reliability, or the broader health of the U.S. supply chain.
“We respectfully urge the Board to thoroughly scrutinize this merger proposal to ensure it does not undermine the integrity of our nation’s transportation network or disrupt the supply chain.
“Sincerely,
“Agribusiness Association of Iowa
“Agribusiness Council of Indiana
“Agricultural Retailers Association
“Alabama Chemistry Council
“Alliance for Automotive Innovation
“Alliance for Chemical Distribution
“American Chemistry Council
“American Coatings Association
“American Foundry Society
“American Fuel & Petrochemical Manufacturers
“AmericanHort
“Associated Industries of Vermont
“Builders Association of Minnesota
“Can Manufacturers Institute
“Chemical Industry Council of Illinois
“Chemistry Council of New Jersey
“Chlorine Institute
“Communications Cable and Connectivity Association
“Council of Producers & Distributors of Agrotechnology
“Duluth Area Chamber of Commerce
“EPS Industry Alliance
“Essential Minerals Association
“Freight Rail Customer Alliance
“Georgia Chemistry Council
“Household and Commercial Products Association
“Illinois Farm Bureau
“Independent Lubricant Manufacturers Association
“Institute of Makers of Explosives
“Kentucky Association of Manufacturers
“Maine Forest Products Council
“Maine State Chamber of Commerce
“Manufacturers Association of Maine
“Massachusetts Chemistry & Technology Alliance
“Minnesota AgriGrowth Council
“Minnesota Automobile Dealers Association
“Minnesota Crop Production Retailers
“Minnesota Farmers Union
“Minnesota Forest Industries
“Minnesota Grocers Association
“Montana Agricultural Business
“Montana Chamber of Commerce
“National Industrial Transportation League
“New York State Chemistry Council
“Nonwoven Fabrics Industry
“North Carolina Agribusiness Council
“North Dakota Association of Builders
“North Dakota Chamber of Commerce
“North Dakota Petroleum Council
“Ohio Chemistry Technology Council
“Pennsylvania Chemical Industry Council
“Performance Racing Industry
“Pet Food Institute
“Pine Chemicals Association International
“PLASTICS Industry Association
“Rail Passengers Association
“South Dakota Chamber of Commerce & Industry
“Specialty Equipment Market Association
“Spray Polyurethane Foam Alliance
“Treasure State Resources Association of Montana
“Vinyl Institute
“Wayzata West Metro Chamber
“West Virginia Manufacturers Association
“Willmar Lakes Area Chamber of Commerce
“Wisconsin Agri-Business Association”
Further Reading:
- Why a Unified Rail Network Makes Sense
- ASLRRA to Participate in STB Review of Proposed UP-NS Merger
- A Rail Merger to Put America Back on Track
- UP’s Jalali: No Hiccups With NS IT Integration
- Ag-State Senators to STB: Be ‘Rigorous’ and ‘Comprehensive’
- BNSF vs. UP, Take Three
- Justification for UP-NS Merger: Real or Not?
- UP, NS Shareholders Greenlight Merger
- Eliminating Paper Barriers is the Pro-Competitive Move
- Hoeven, Klobuchar to STB: ‘Closely Scrutinize’ UP+NS
- CPKC: UP+NS Merger ‘Not in the Public Interest’
- UP 3Q25: ‘Continued Improvements in Pursuit of What’s Possible’
- For NS 3Q25, ‘Strong Results’
